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Background Checks

Beyond the Big Three: Specialty Consumer Reporting Agencies

Mark LefflerConsumer Litigation Associates, P.C.July 11, 20269 min read
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Equifax, Experian, and TransUnion are not the only companies with files on you. Dozens of specialty consumer reporting agencies collect and sell your rental history, employment background, and criminal records, and they are often the ones most likely to cost you an apartment or a job.

More Than Three Bureaus

When people think about credit reports, they think about the big three. Those companies dominate the credit-reporting market. But they are not the only companies maintaining files on you. The Fair Credit Reporting Act covers any consumer reporting agency that assembles or evaluates consumer information for the purpose of furnishing consumer reports to third parties. That definition reaches dozens of specialty agencies most people have never heard of.

Tenant Screening Companies

If you have ever applied for an apartment, a tenant screening company likely has a file on you. These companies compile eviction records, criminal records, and prior addresses, then sell reports to landlords. The major players include:

  • CoreLogic Rental Property Solutions
  • TransUnion SmartMove and TransUnion Rental Screening Solutions
  • First Advantage Resident History
  • RealPage screening products (including On-Site and LeasingDesk)
  • Contemporary Information Corp.

When a landlord denies your application, the denial often comes from one of these companies, not from Equifax, Experian, or TransUnion.

Employment Screening Companies

Background checks for jobs run through a different set of companies. These firms collect criminal records, employment history, and education verification, and sometimes credit information. The reports go to employers making hiring decisions. First Advantage, Sterling, and HireRight are among the largest, but there are hundreds of smaller firms.

Check Verification Services

If a check has ever been declined at a retail store, a check verification service was likely involved. TeleCheck and Certegy maintain databases of consumers who have had problems with checks. A negative entry can follow you for years.

Your Rights Are the Same

Here is the important part: every one of these companies is a consumer reporting agency under the FCRA. That means they carry the same core obligations as the big three:

  • Follow reasonable procedures to assure maximum possible accuracy (1681e(b))
  • Reinvestigate disputes you submit, generally within 30 days (1681i)
  • Give you a copy of your file on request (1681g)
  • Provide a free file disclosure after an adverse action and once a year on request (1681j)

The problem is that most consumers do not know these companies exist, so they never request their files, never dispute errors, and never hold the companies accountable.

How to Find Out Who Has a File on You

  • Start with the Consumer Financial Protection Bureau's annual list of consumer reporting companies at consumerfinance.gov, which includes contact details for dozens of specialty agencies.
  • If you were denied an apartment, a job, or check-cashing privileges, read the adverse-action notice, which must identify the consumer reporting agency that supplied the report.
  • Request your file from that agency. Most require a written request and proof of identity; some offer online portals.

The Pattern of Errors

The same errors that appear on credit reports appear on tenant screening and employment reports, often worse. Criminal records get matched to the wrong person by similar names. Dismissed evictions still appear as judgments. Expunged cases still show up. Information from one state gets attributed to someone who never lived there. These errors are devastating: a false criminal record can cost a job offer, and a false eviction can cost an apartment.

What to Do

If you are applying for apartments or jobs, pull your specialty reports before you apply so you know what landlords and employers will see. If there are errors, dispute them the same way you would dispute a credit-report error: in writing, by certified mail, with documents attached. The FCRA gives you the same rights against a tenant screening company that it gives you against TransUnion.

Denied an apartment or job because of a specialty report? Have an FCRA attorney review what they reported about you.

How to Find Out Who Holds a File on You

The hard part of specialty agencies is that you cannot dispute a file you do not know exists.

The adverse action notice is the shortcut. When you are denied an apartment, a job, a bank account, or insurance based in whole or in part on a consumer report, the user must tell you and must identify the agency that supplied it. That notice is how most people learn a specialty file exists at all, which is why it is worth reading rather than filing.

Beyond that, the CFPB publishes a list of consumer reporting companies covering the specialty sector. Working through the categories that apply to your life, rental, employment, banking, insurance, medical, is tedious and it is the only comprehensive way to see what is out there.

Request a disclosure from any agency plausibly holding data on you, particularly if you have been turned down for something while your credit looked fine.

Why Errors Here Hurt More

A credit report error usually costs money: a higher rate, a smaller limit. A specialty report error more often costs the thing itself.

An employer that sees a criminal record does not negotiate terms. A landlord with an eviction on the screening report moves to the next applicant. A bank that gets a negative ChexSystems entry declines the account, and without an account the rest of ordinary financial life gets harder.

These decisions are also made faster and with less human review than lending decisions, and the consumer usually never sees the report that drove them unless they ask.

The Companies, By Name

Knowing the category is not much use when a denial letter names a company you

have never heard of. These are the agencies whose reports most often cost

someone a job, an apartment, or a bank account. Each is a consumer reporting

agency under the FCRA, with the same duties as Equifax, Experian and TransUnion.

Employment screening. Checkr, HireRight, Sterling, First Advantage, Asurint,

Orange Tree, InfoMart, IntelliCorp, GoodHire, General Information Services, and

the employment verification database The Work Number.

Tenant screening. CoreLogic Rental Property Solutions, SafeRent Solutions,

AmRent, RentGrow, LeasingDesk and OnSite (both RealPage), AppFolio, and

TransUnion's own SmartMove.

Deposit accounts and checks. ChexSystems and Early Warning Services decide

whether a bank will open an account for you. Certegy and TeleCheck decide

whether a retailer accepts your check.

Insurance, risk and data aggregation. LexisNexis Risk Solutions, including

its Accurint and C.L.U.E. products, and Verisk. MIB Group holds medical

application history used in life and health underwriting.

Subprime and alternative credit. Clarity Services, Teletrack, SageStream

and Innovis, which many consumers never think to check at all.

Driving records. Motor vehicle reports pulled through a screening agency sit

under the FCRA too, which matters enormously to anyone driving for a living.

Why the Gig Economy Made This Worse

Rideshare and delivery platforms run continuous background and driving record

checks, not just one at hire. A report refreshes, something lands on it, and an

account is deactivated by an automated decision before any person looks.

The consequence is that an error does not cost you an interview. It cuts off

income that already exists, often the same week, and the platform usually points

at the screening company while the screening company points at the platform.

The law does not leave you between them. The platform using the report is a user

with adverse action obligations. The screening company is a consumer reporting

agency owing accuracy and reinvestigation. Both have duties, and both are

reachable.

Common Questions

What is a specialty consumer reporting agency?

Any consumer reporting agency outside the three nationwide bureaus that compiles a narrower category of information: tenant screening, employment screening, check writing and deposit history, insurance claims, or medical application history.

Does the FCRA cover them?

Yes. The definition turns on assembling information about consumers and furnishing reports for covered purposes, not on what the company calls itself. They owe the same core duties: reasonable procedures to assure maximum possible accuracy, reinvestigation of disputes, and file disclosure on request.

Can I get a free report from them?

Many must provide a free annual disclosure on request. You have to ask each one separately; nothing collects them in one place the way AnnualCreditReport.com does for the nationwide bureaus.

How do I know which agency reported about me?

The adverse action notice names it. A user that takes adverse action based on a consumer report must identify the agency that supplied the report.

How do I dispute an error on a specialty report?

In writing, to that agency, with your evidence attached, sent certified mail with return receipt. The reinvestigation obligations work the same way they do with a nationwide bureau.

Why did my application get denied when my credit is good?

Often because the decision ran on a specialty report rather than a credit report. Employment, tenant, and deposit account screening frequently do, and a clean credit file says nothing about what those agencies hold.

How long does negative information stay on a specialty report?

The same obsolescence rules in 15 U.S.C. § 1681c apply to consumer reporting agencies generally, not only to the nationwide bureaus. An eviction or a deposit account entry that is years old is worth checking against the reporting period rather than assumed to be permanent.

Can I freeze a specialty file?

Some of the larger specialty agencies offer a freeze or a security alert, though it is not as uniform as it is with the three nationwide bureaus. If you have been a fraud victim, ask each agency what it offers rather than assuming a credit freeze covers you.

Do these agencies have to investigate my dispute?

Yes. A consumer reporting agency owes the same reinvestigation duty whatever its size, and the same deadlines apply. Send the dispute in writing and keep proof of delivery.

Who are the specialty consumer reporting agencies?

Employment screeners such as Checkr, HireRight, Sterling and First Advantage;

tenant screeners such as CoreLogic, SafeRent, AmRent and RentGrow; deposit

account databases ChexSystems and Early Warning Services; check services

Certegy and TeleCheck; and data aggregators including LexisNexis and Verisk.

How do I find out which company reported about me?

The adverse action notice names it. Anyone who denies you employment, housing,

credit, insurance or a bank account based on a consumer report must identify the

agency that supplied it.

Can I get my file from these companies?

Yes. They owe you file disclosure on request, and many must provide a free

annual disclosure. Each has to be asked separately; nothing collects them in one

place the way AnnualCreditReport.com does for the three nationwide bureaus.

Does the FCRA really cover a company I have never heard of?

Yes. The definition turns on assembling information about consumers and

furnishing reports for covered purposes, not on size or on what the company

calls itself.

My rideshare account was deactivated over a background check. What now?

Dispute the report with the screening agency in writing and tell the platform in

writing that the report is disputed. The platform is a user of the report with

its own adverse action obligations, and the screening company owes you a

reinvestigation.

How long do these companies have to investigate?

The same deadline as a nationwide bureau: generally 30 days from receiving your

dispute, extended to 45 if you supply additional information during that period.

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