Answer:
It is my opinion only, but any assignment that comes with more than one address (with the exception of a home and employment), you can pretty much assume the account has been skip-guessed…and not skip-traced.
Besides exhausting a lot of the repossessor’s resources, this poses additional legal risks; the more people you come in contact with, the more chances for third party disclosure to happen. And this is a big deal.
There is more and more legislation that governs these types of contacts. For instance, the “No Disclosure Without Consent” Rule: “No agency shall disclose any record which is contained in a system of records by any means of communication to any person, or to another agency, except pursuant to a written request by, or with the prior written consent of, the individual to whom the record pertains” [subject to 12 exceptions 5 U.S.C
I believe this piece of legislation is currently a skip-tracer’s greatest nemesis in the marketplace today! When you consider that this law can be violated simply by perception (eg.a badly placed phone message, leaving a business card displaying the collection agent’s company name on a front door, interaction with neighbors or co-workers, etc.), then almost any contact with anyone but the customer, taken within the course of a repossession-related investigation, could possibly result in a disclosure issue.
With all that said, you can check any address for the collateral, but if contact is going to made with anyone that is not signed on the contractual obligation, I strongly suggest you only have your most experienced people handle this task. It is always better to be safe than sorry especially in today’s “regulation nation”.
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Alex Price is formerly a collector for a major captive lender, and is currently a respected leader in investigator skiptracing processes and techniques.
He is the vice president of Masterfiles, a database popular with private investigators, collectors and repossessions. He also teaches skiptracing through online webinars on a regular basis. You can contact him here
