According to a recent action taken by the CFPB, a major background screening data provider “failed to take basic steps to assure accuracy when using database records as part of a background screening report.” The action resulted in fines exceeding $10 million in relief to harmed consumers and a $2.5 million civil penalty. In addition to the monetary penalties, the affected companies must also abide by new orders outlined by the CFPB, including revised compliance procedures, adoption of a comprehensive audit program, and retention of an independent consultant to suggest policy improvements.
It’s recommended that all CRA’s spend time reviewing CFPB case findings and assessing their own internal policies in order to make the necessary changes and avoid negligence lawsuits. Another suggestion for screening agencies assessing their accuracy is to include as many personal identifiers in the application as possible. According to the National Association of Professional Background Screeners (NAPBS), the Federal Trade Commission’s main focus for 2016 will be on matching criteria and ensuring accurate identifiers are used for applicant processing.
Middle Name Search Criteria Recommendations
An example of what some background screening technology providers have added to the application process is the option to require the applicant to provide a middle name. If the applicant does not have a middle name, they can check a box to validate that they do not have a middle name, or in the case of processors, that they did not provide a middle name. This simple step makes it far easier to enhance accuracy in the investigative steps that follow.
Collecting a middle name or middle initial when ordering a background check will help in more ways than one. For example, if a consumer has a common name, not having a middle name can negatively impact turnaround times for criminal record lead generators like an instant database of criminal or other public records. Processors must spend more time sifting through potential matches (false positives) and determining the validity of the record. Use of the middle name or initial can help reduce false positives, thus improving accuracy and response times for criminal research. Additionally, verifying a court house record returned by a researcher when a middle name is collected is made easier.
Enhancing accuracy and compliance must not be overlooked because the penalty for negligence can be overwhelming. The good news is there are simple ways to protect your company and mitigate the chance of a regulatory action. Choose the background check software provider who will help you maintain compliance. Additionally, remembering to stay up on CFPB case rulings and emphasizing accuracy by adding specific name collection criteria like middle name designations can be the difference between smooth sailing and a sinking ship.