Yes And No For Now!


 Effective July 1st, credit headers require the same permissible purpose of a full credit bureau to access. However, most current providers have found a little known clause that seems to keep them alive under very strictive access for now. Credit headers, also known as Social Security Tracing has been the single most important computer search investigators have used to locate missing persons and conduct skip trace investigations. Permissible purposes include employment, debt collection and/or judgement enforcement. The search can no longer be used for general skip tracing, locates of witnesses and those types of cases.

Credit headers had pulled the top portion of the credit bureau report that included name and address information. They had been accessed with either the Social Security number or the full name and last known address.

Permissible purposes specificlly state that the search can only be run under the following circumstances:

 In response to the order of a court having jurisdiction to issue
such an order, or a subpoena issued in connection with proceedings
before a Federal grand jury.

In accordance with the written instructions of the consumer to
whom it relates.

To a person which it has reason to believe--

(A) intends to use the information in connection with a credit
transaction involving the consumer on whom the information is to be
furnished and involving the extension of credit to, or review or
collection of an account of, the consumer; or

(B) intends to use the information for employment purposes; or

(C) intends to use the information in connection with the
underwriting of insurance involving the consumer; or

(D) intends to use the information in connection with a determination
of the consumer's eligibility for a license or other benefit granted by
a governmental instrumentality required by law to consider an
applicant's financial responsibility or status

Because you must obtain the same permissible purposes for obtaining credit header information as a full credit bureau, the search is likely to die since the searcher is likely to go ahead and run the full credit report instead of just the header since the permissible purposes for both searches are the same. But wait!

For the time being--many information providers are using the following provisions to keep SSN tracing alive with the following clause issused:

 "To protect against or prevent actual fraud, unauthorized transactions, claims or other
liability" and "For required institutional risk control or for resolving consumer disputes or inquiries."

This clause in the Financial Privacy Act of 1999 seems to permit limited and restricted use of SSN Tracing for those with a ligitimate need to run the search but it's not yet known what the FTC will rule of the clause.