Red Flag is a very big deal come August 1st. Every credit report that is pulled, whether it turns into an application or not is required to be run through the Red Flag scenario. My understanding is that we must make a minimum of 2 attempts with the consumer to resolve any Red Flag issues, whether it turns into an application or not. So this will be a new set of information that we will be required to retain so that we can prove our compliance with this new law. It's going to be time consuming and require some plan to retain the information. if you use Calyx for your LOS the latest versions have a File Box that you can scan and retain information.
Our company is going to do it through Kroll Factual Data. At the time a credit report is run we will also have the Red Flag report run. They call it TruAlert. It tells you exactly the things that need to be addressed.
I would suggest that you get with whomever you do your credit reports with to see what they offer. Our company uses 5 different reporting agencies but are only going to use Kroll for the Red Flag requirement. So just from a time standpoint it makes sense to me to use them for both.
This is big business for the credit reporting companies as it's a new source of revenue which the consumer is going to end up paying for.