12 C.F.R. § 1022.123

Appropriate proof of identity

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(a) Consumer reporting agencies shall develop and implement reasonable requirements for what information consumers shall provide to constitute proof of identity for purposes of sections 605A, 605B, and 609(a)(1) of the FCRA. In developing these requirements, the consumer reporting agencies must:

(1) Ensure that the information is sufficient to enable the consumer reporting agency to match consumers with their files; and

(2) Adjust the information to be commensurate with an identifiable risk of harm arising from misidentifying the consumer.

(b) Examples of information that might constitute reasonable information requirements for proof of identity are provided for illustrative purposes only, as follows:

(1) Consumer file match. The identification information of the consumer including his or her full name (first, middle initial, last, suffix), any other or previously used names, current and/or recent full address (street number and name, apt. no., city, state, and zip code), full nine digits of Social Security number, and/or date of birth.

(2) Additional proof of identity. Copies of government issued identification documents, utility bills, and/or other methods of authentication of a person's identity which may include, but would not be limited to, answering questions to which only the consumer might be expected to know the answer.

Notes of Decisions

Cited in 4 cases (3 in the last 5 years), 2020–2026 · leading case: McAfee (S.D. Ohio 2025).

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McAfee (S.D. Ohio 2025). · cites it 5× “12 C.F.R. § 1022.123 . Relying on these provisions and some case law with certain factual parallels to McAfee’s allegations, DataX’s motion argues that DataX’s requirement that McAfee produce copies of his Social Security card, W2, or 1099 form is a “reasonable” means of…”

Connecticut Fair Hous. Ctr v. CoreLogic Rental Prop. Solutions, LLC (D. Conn. 2023). “” 12 C.F.R. § 1022.123 (b). 1. 12 C.F.R. § 1022.”

Hicks v. Smith (W.D. Ky. 2020). “12 C.F.R. § 1022.123 . “A primary purpose[] of the statutory scheme provided by the disclosure in § 1681g(a)(1) is to allow consumers to identify inaccurate information in their credit files and correct this information via the grievance procedure established under § 1681i.”

CFHC v. CoreLogic Rental Prop. Sols. (2d Cir. 2026). “” 12 C.F.R. § 1022.123 (a). The district court explained that “[w]here state law defines the validity of an identification document,” the state-law requirements for establishing validity inform what qualifies as “‘proper identification’ under the FCRA.”

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