What reports may be used for

Listen instead

The same material, read aloud and told more loosely than it is written. Nothing is said in it that this page does not also say.

That same recording, with the writing lit line by line as it plays and the sections listed beside it, is on its own page.

There is no permissible-use dropdown

Anyone who has held a TLOxp or an Accurint login has been trained to choose a use before the search will run. That habit comes from 15 U.S.C. 1681b(f), which says a person shall not use or obtain a consumer report unless the purpose is one the section authorizes and the purpose is certified, generally or specifically, under 1681e.

We collect no such attestation. No credentialing and no site inspection, because there is nothing here to apply for. Read that as a description of our intake: it is a statement about what we ask you for, not a finding about what any statute asks of us.

Where the records come from

Instruments recorded in a county register, plus records from the agencies that publish them.

ACRIS for the New York City register. Broward's official records. Parcel files from all 67 Florida county property appraisers. Parcel rolls and transfer records from counties in 45 more states and DC. Corporate registries in eleven states. The FAA aircraft registry. New York State's own docketed warrants. Every line cites the document it came from and the date it was retrieved, so you can pull the instrument yourself.

What is absent matters as much. No credit file. No application data a person handed to a lender, no motor vehicle record, nothing bought from an aggregator. How each source was obtained is written out in full.

What you accept when you use a report

One restriction, and it is short. Reports are not used for credit, employment, insurance or tenant screening decisions.

You accept that at signup. It is a term, not a characterization of the data, and it binds whether or not any statute reaches the same place. A report answers whether a judgment is worth enforcing. If your question is an eligibility decision about a person, this is the wrong product, and we would rather say so now.

FCRA, GLBA and DPPA, in their own words

These three carry most of the compliance vocabulary in this market, so here is what their text says. None of it is an opinion about how any of it applies to a Collecteral report.

• FCRA. 15 U.S.C. 1681b(a) lists the circumstances in which a consumer reporting agency may furnish a consumer report, and adds "and no other". The list runs from a court order, through the written instructions of the consumer and the eligibility uses at 1681b(a)(3) that everybody knows, out to a child support enforcement agency at 1681b(a)(4). Then 1681b(f) turns the duty around and puts it on whoever obtains the report.
• GLBA. 15 U.S.C. 6809(4) defines nonpublic personal information as personally identifiable financial information provided by a consumer to a financial institution, resulting from a transaction with that consumer, or otherwise obtained by the institution. Subparagraph (B) excludes publicly available information as defined by the regulations under 6804. What gets called the three key rules sits at 6802 and 6803 (privacy notice and disclosure), at 6801(b) (the safeguards standards regulators must set), and at 6821, which makes it a violation to obtain customer information of a financial institution by a false statement to the institution or its customer. 6823 attaches a criminal penalty.
• DPPA. 18 U.S.C. 2721(a) binds a State department of motor vehicles and its contractors. 2722(a) goes wider, making it unlawful for any person knowingly to obtain personal information from a motor vehicle record for a use not permitted under 2721(b), a list that includes the enforcement of judgments at 2721(b)(4). We hold no motor vehicle records. What follows from that is yours to work out.

On skip tracing

People reach this page having searched whether skip tracing is legal. We cannot answer that. Anybody who answers it in one word is selling something.

Read the three statutes above again and the shape repeats in each of them: what is named is an act, not an occupation. So here is the list of acts we do not perform. No bank or brokerage is ever contacted. No pretext, and no representation of any kind, is made to anybody holding a record. No credit header is bought. No motor vehicle record is queried, in any state, for any reason.

The sentence missing from this page

You will not find us telling you that reports are not consumer reports, or that the records are not nonpublic personal information.

Both are legal conclusions, and Collecteral is run by one person who is not a lawyer. A conclusion is worth what its author is qualified to say, which here is nothing. The second reason is the practical one. That kind of characterization can turn on what the holder of a report does with it, so the vendor is not the party who can settle it in advance. You get the sources, the restriction and the statutory text, and your firm's counsel reaches the conclusion on your facts.

If a compliance review needs something signed before a pilot starts, say so in the first email rather than the last. What reports cannot answer is the other half of this page.