FCASPL 366 (Guidance for Public Children Services Agencies and Private Child Placing Agencies Regarding Credit Reports for Youth in Foster Care)
Family, Children and Adult Services Procedure Letter No. 366
January 27, 2021
TO: All Family, Children, and Adult Services Manual Holders
FROM: Kimberly Henderson, Director
SUBJECT: Guidance for Public Children Services Agencies and Private Child Placing Agencies Regarding Credit Reports for Youth in Foster Care

The purpose of this procedure letter is to provide guidance to public children services agencies (PCSAs) and private child placing agencies (PCPAs) on requirements for ensuring accurate credit information for youth in care. In accordance with the Preventing Sex Trafficking and Strengthening Families Act and Ohio Administrative Code 5101:2-42-19, custodial agencies must annually request a credit report for all youth 14 years of age or older from each of the three credit reporting agencies (CRA). The requests may be completed simultaneously or separately throughout the year, in order to monitor any credit activity being conducted in the child’s name. Should inaccuracies be discovered, the PCSAs and PCPAs must work with the Ohio Attorney General’s Office (AGO) to resolve any identified discrepancies.  Each CRA has a different procedure for requesting a minor’s credit report, which are outlined below.   

Obtaining a Youth's Credit Report

The following information must be sent to each CRA to request the credit report:

 

  • A copy of the youth’s birth certificate, social security card, and other available legal documentation of the youth's full name and age.
  • Verification that the agency has the legal authority to request the credit report information (e.g., the court award letter).
  • Documentation that the youth is in foster care (e.g. a court order or other document).
  • Identification and verification that the agency staff making the request has the right to do so on behalf of the minor child. This method shall be developed by each agency; some have used copies of agency ID badges to fulfill this requirement.
  • Address of the agency where the credit report is to be sent.
  • Other available information that would assist the CRA in completing the credit search.  This shall include but is not limited to: the youth's current address and any other addresses of residence from the previous two years, nicknames, and social security number.

Instructions for Contacting Each CRA

EQUIFAX

Equifax CRA provides access to credit report histories through the Equifax e-Port system.  Each agency is required to have a password protected profile with a primary contact person to obtain youth credit reports through e-Port.

To establish a profile, the agency director must send the name and e-mail address for the primary contact person (i.e., staff person who will be requesting youth credit reports) to the Transition Age Youth team at: Transitional-Youth-Programs@jfs.ohio.gov.

EXPERIAN

We have now established a new electronic process with Experian CRA. You now have the option of sending the requests via mail or electronically, as described below.

Send the required information manually by mail to:

Experian National Consumer Assistance Center

PO Box 9701

Allen, Texas 75013

Experian recommends using the USPS Priority, UPS or FedEx for tracking. Sensitive information may be redacted from the court order if the identification on the minor remains intact. The CRA’s response will be “No Record” or the credit report will be sent to the requestor (agency) through regular mail. For security purposes, the envelope will not indicate it is from Experian. There is no charge for this process.

To sign up for Experian’s electronic database, send inquires to publicsectorsupport@experian.com and include the following information: Agency name, county, contact name, address (e-mail and regular mail), phone number and state.  Experian will have the agency complete a membership application and sign an “Agreement for Credit Reports for Foster Youth”. Following the approval, Experian’s Membership department will set up an online account and contact the county’s designated contact for final installation and setup. There is no charge for this sign up or for this service.

TRANSUNION

Agencies are able to obtain credit report histories from TransUnion CRA through the TransUnion Direct database. The agency is responsible for executing a no- cost agreement with TransUnion for access to the system.

Requests may be completed electronically individually or by multiples (batch) of no more than 50. Use the email listed below for more information on executing an agreement with TransUnion CRA.

fostercare@transunion.com

Resolving Credit Report Discrepancies

A minor cannot enter into an agreement with a business, agency, or entity, and therefore should have no credit bureau record associated with the child. A finding would indicate an error or evidence that the child has been a victim of identity theft. If the credit report shows any irregularities or inconsistencies, the agency shall contact the Ohio Attorney General’s (AGO) office to request assistance in resolving the issue.

To make a referral to the AGO, the agency must send copies of all information related to the credit report, including, correspondence with the CRA, a cover letter on agency letterhead, and the completed AGO ID Theft Affidavit with all supporting documents (see attachment) containing the youth’s signature and attesting that to the best of his or her knowledge, he or she did not open the accounts. County caseworkers or the agency designee are to also provide the AGO with contact information and identify where responses are to be sent.  This information is to be faxed to:

1- 866-364-2065.

INSTRUCTIONS:

The following chart depicts what materials should be deleted from the Family, Children and Adult Services Manual (FCASM) and what materials should be inserted in the FCASM.

LOCATION REMOVE AND FILE AS OBSOLETE INSERT/REPLACE
Procedure Letters FCASPL No. 330 FCASPL No. 366