1.3.7 Consumer Locating Services, a.k.a. “Skip Tracers”
Some businesses, known pejoratively229 as “skip tracers,” specialize in locating consumers’ contact information when the consumer has changed addresses, employment, or phone number. They will try to match the information they are given—such as Social Security number, name, former address, employer, etc.—to try to locate consumers for creditors, collection attorneys, and collection agencies.
These businesses use consumer reporting agency and other databases to find current home and work addresses, telephone numbers, and email addresses. They will also use less structured Internet sources, such as using search engines, such as www.google.com, or social networking sites, such as www.facebook.com, to get leads. Some companies have also used false pretenses to obtain current consumer contact information.230
229 The term is pejorative because most “skips” are actually people who have been forced to move to a different address because of their financial distress from unemployment, illness, or other hardships.
230 See, e.g., Romine v. Diversified Collection Servs., Inc., 155 F.3d 1142 (9th Cir. 1998) (telecommunications company sent a message asking the consumer to call Western Union for a message and then used caller ID technology to obtain the consumer’s unlisted telephone number for its debt collector client); Thompson v. Nat’l Credit Adjusters, L.L.C., 2012 WL 5372577 (D. Minn. Oct. 31, 2012) (letter fraudulently claimed that there was a message for consumers in attempt to induce call from consumer and obtain phone number for collection purposes). See also Andrea Ryan, et al., A Brief History of US Consumer Finance, Working Paper 11-058 (Harvard Bus. School, 2010) (“In many communities, the local ‘Welcome Wagon’ collected credit information on new arrivals to the town.”); United States v. Zats, 298 F.3d 182, 184 (3d Cir. 2002) (to obtain bank account information for garnishment the collection attorney “often engaged in a phone ‘survey’ in which he called the debtor, offered him or her a free gift for completing his survey, and then asked questions until he obtained enough information to identify the account”); LeVine, FTC Informal Staff Letter (Mar. 20, 1998); Stanley, FTC Informal Staff Letter (Sept. 13, 1996); Bergstrom, FTC Informal Staff Letter (Nov. 17, 1995); § 4.2.3, infra.