Trans Union:Mixed Files:Disclosure Algorithm Differs

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Trans Union:Mixed Files:Disclosure Algorithm Differs

Postby Administrator » Mon Oct 03, 2005 8:17 pm

21 Q But what I'm saying is, whether it's the
22 William Porter data file, what we've identified as
23 the file No. 2 or No. 3 on Exhibits 2 and 3, that
24 regardless of whether it's one of those two data

1 files or some other data file that has some
2 different information than that of the plaintiff, it
3 should keep it from permanently combining with such
4 a file, correct?
5 A Correct.
6 Q Now, the -- the "do not merge" tag will not
7 prevent two different data files from being returned
8 as part of the same credit report; is that true?
9 MR. CENTO: Object to the form.
10 A I don't know.

11 BY MR. Szwak:
12 Q Well, let me ask you. In your
13 understanding of how a "do not merge" tag operates,
14 does it prevent two different data files from being
15 returned as part of the same consumer disclosure?
16 A I know in consumer relations it doesn't.

17 Q Okay. And let me give you an example
18 and -- and make sure I understand correctly.
19 MR. CENTO: David, do you want to finish
20 this question? And then I think the
21 videographer needs to change his tape.
22 MR. Szwak: Okay. That's good. Let me --
23 let me do this question.
24 How are we on time, Mr. Videographer?

1 THE VIDEOGRAPHER: Well, we've got ten
2 minutes left on the tape. If you want -- if you
3 want to roll ten more minutes, that will be
4 fine.
5 BY MR. Szwak:
6 Q If I understand correctly, by example, if
7 the plaintiff requested her consumer disclosure from
8 TransUnion tomorrow, that TransUnion could return to
9 her a consumer disclosure that would have copies of
10 her credit file, the data file No. 1 we've
11 identified, and the William Porter data file that we
12 identified as file No. 2 shown in Exhibits 2 and 3
13 as part of the same report; is that true?
14 MR. CENTO: Object --
15 A No.
16 MR. CENTO: -- to the form.
17 BY MR. Szwak:
18 Q So that would not occur; is that true?
19 A They won't be returned to the consumer.
20 Q They would not be returned to the consumer,
21 but that's based upon your consumer disclosure
22 policies and practices, correct?
23 A Correct.

24 Q However, is it possible that those two

1 files could be returned to a subscriber as part of a
2 subscriber version credit report?
3 MR. CENTO: Object to the form.
4 A I don't know if that occurs once the tag is
5 put on.

6 BY MR. Szwak:
7 Q Is there any documentation about how this
8 particular tag functions?
9 A I'm sure that we have some type of
10 documentation.
11 Q Do you have any of it in your office?
12 A We may, yes.
13 Q I mean, I'm assuming that if this is a
14 system capability that you have available to you to
15 use in your job and for your -- your employees, that
16 you would have some sort of documentation explaining
17 how it functions; is that a fair statement?
18 A Yes. We -- we know how it functions as far
19 as consumer relations is concerned, and we place
20 that tag on there to prevent the files from merging.
21 Q Okay. And what is it -- what is it that
22 you define as "merging"? Is that the combining, the
23 actual combining of two different data files to
24 create one resultant file?

1 A Yes.

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