What reports may be used for

0:30There is no permissible-use dropdown

Start with the dropdown, because its absence is the thing people notice first.

If you've held a TLOxp or an Accurint login, you've been trained to choose a use before the search runs. That habit comes from 15 U.S.C. 1681 B, subsection F. It says a person shall not use or obtain a consumer report unless the purpose is one the section authorises. And unless that purpose is certified, generally or specifically, under 1681 E.

We collect no such attestation. No credentialing. No site inspection, because there's nothing here to apply for.

Now hear exactly what I just said, because it's narrow. That's a description of our intake, and a statement about what we ask you for. What any statute asks of us is a separate question, and this answers none of it.

1:27Where the records come from

So where do the records come from.

Instruments recorded in a public county register. Plus public bulk files, 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. 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 go pull the instrument yourself.

And what's absent matters as much as what's there. 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.

2:15What you accept when you use a report

Then there's what you accept when you use a report.

2:19FCRA, GLBA and DPPA, in their own words

One restriction, and it's short. Reports aren't used for credit, employment, insurance or tenant screening decisions.

You accept that at signup. It's a term you agree to, 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 I'd rather say so now than after you've bought it.

Three statutes carry most of the vocabulary here. FCRA, GLBA and DPPA. The page sets out what each one's text actually says. None of it is an opinion about how any of it applies to a Collecteral report.

3:01On skip tracing

Which brings up skip tracing.

People reach this page having searched whether skip tracing is legal. I can't answer that. Anybody who answers it in one word is selling you something.

But read those three statutes again and the same shape repeats in every one of them. What's named is an act. Every one of them, an act.

So here's the list of acts we don't 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.

3:36The sentence missing from this page

And now the sentence that's missing from this page, because I think its absence is the most useful thing on it.

You won't find me telling you that reports aren't consumer reports. Or that the records aren't nonpublic personal information.

Both of those are legal conclusions, and Collecteral is run by one person who isn't a lawyer. That's me. A conclusion is worth what its author is qualified to say, which here is nothing.

And there's a practical reason on top of the honest one. That kind of characterization can turn on what the holder of a report does with it. So the vendor isn't the party who can settle it in advance. I couldn't settle it for you even if I were qualified to.

So you get the sources. You get the restriction. You get the statutory text. And your firm's counsel reaches the conclusion, on your facts.

One last thing. If a compliance review needs something signed before a pilot starts, tell me in the first email rather than the last.

Everything I've described is on the site in full, the sources and the limits together, before you hand me anything at all. Read it first, and bring your counsel's questions with you.