How to Verify Someone’s Identity Before Doing Business
Almost every guide to this question starts in the wrong place. It tells you how to check a person, and it never asks what you are about to do with the answer – which is the only fact that determines what you are lawfully allowed to check at all. There are two layers here, and they sit under two different bodies of law. The first is the entity: does this LLC or corporation exist in a state’s records, who is named as its registered agent, who signed the last annual report, is there a secured creditor filed against it. That layer is corporate filing research. It is not reached by the Fair Credit Reporting Act, the Driver’s Privacy Protection Act, or Gramm-Leach-Bliley, because none of those statutes governs a document a company files about itself. The second layer is the natural person standing behind the entity, and that layer has real rules. So the order matters: work the unregulated, largely free, frequently decisive layer first, then escalate to the person with a stated lawful purpose. People Locator Skip Tracing is a skip-tracing and public-records research firm; nobody here holds a private investigator’s license, and none of this work needs one. We serve the business-counterparty case – you are about to sign, wire, ship, or take delivery. We do not serve employment screening, tenant screening, or consumer credit decisions: those are the law’s eligibility decisions, they belong to a regulated consumer reporting agency, and we are not one. For a workable request with a lawful, legitimate purpose, a first read typically comes back within 24 hours. This page is general information, not legal advice.
The Short Version
Verify in two layers, in this order. Layer one is the entity – is the company registered, who is its registered agent, who signed for it, is anything filed against it. Corporate filings are not consumer data, driver records, or bank customer files, so no privacy statute stands between you and them, and this layer alone settles a surprising number of deals. Layer two is the person behind the entity, and here the rules bite. The Fair Credit Reporting Act attaches to a use, not to a record: if your answer will decide someone’s eligibility for a job, a tenancy, or consumer credit, that is a consumer report and it must come from a regulated CRA. We are not a CRA and we route those requests out rather than serve them. What we do serve is the transaction case – you are about to sign or wire, and you want the counterparty confirmed from lawful records. We never pretext, never touch private financial account contents, and we report a clean record as plainly as a discrepancy. A first read typically comes back within 24 hours. General information, not legal advice.
Watch: Entity First, Then the Person
Why the order changes what you may check.
Watch Overview
Check the Company First, Then the Person
One layer is unregulated. The other is not.
A company’s own filings are the cheapest evidence in this whole exercise and the last place most buyers look. When a business registers with a state, it puts its formation date, its status, its registered agent and an address on a public record, and it renews that record on a schedule. Nothing in the Fair Credit Reporting Act reaches that document, because the FCRA’s subject is a consumer, and the statute defines the word without any room to argue: “The term ‘consumer’ means an individual.” A limited liability company is not an individual. The Driver’s Privacy Protection Act governs personal information out of state motor vehicle records, and Gramm-Leach-Bliley governs what financial institutions do with customer information. An annual report is none of those things. So the entity layer carries no permissible-purpose problem at all, and it is where the check should start.
It also has a habit of ending the inquiry. A corporation that was administratively dissolved two years ago, a registered agent resigned and never replaced, a formation date three weeks older than the “twenty years in business” line on the website, a name that is one letter off the established company it is imitating – these are not subtle findings, they show up in the first pass, and they are dispositive. Reading corporate records well is its own discipline, and if you want to work that layer yourself, the mechanics of checking whether a business is legitimate and of a UCC lien search are set out in detail elsewhere on this site rather than duplicated here.
The entity layer stops where the human being starts. Filings name people, but they do not confirm that the named person is the person emailing you, and a determined shell operator can put a real name on a real filing and still be someone else entirely. That is the point at which the second layer opens – tying a name to a traceable individual in public records, ruling out the several people who share it, and testing whether the details handed to you hold up. Tracing the individual behind an entity is the same work as finding the owner of an LLC, and the same discipline we apply when a fiduciary has to confirm the identity of a person claiming an inheritance. The rules change when you cross that line, which is what the next two sections are about.
Two Layers, Two Rulebooks
Which body of law reaches which record.
| What you are checking | Where it lives | Which law reaches it |
|---|---|---|
| Does the company exist | State business registry, annual reports | None of the three. A filing is not a consumer, a driver record, or a bank customer file. |
| Who stands behind it | Registered agent and officer filings, UCC-1 records | Still corporate filings – no permissible-purpose gate. |
| Is the person real | Public records about an individual | The FCRA reaches it only when the use is an eligibility decision (15 U.S.C. 1681a(d)(1)). |
| Do the details they gave you hold up | Records including state motor vehicle data | The DPPA permits verification in the normal course of business (18 U.S.C. 2721(b)(3)(A)). |
| Hiring, renting, or extending consumer credit | A regulated consumer reporting agency | 15 U.S.C. 1681b(a)(3) – employment at (B), credit at (A), tenancy reached through (F)(i). Not us. Routed out |
Read that table downward and it tells you something the identity-verification software vendors on this search never say: the constraint is not the record, it is the decision. The same address history is unremarkable in one hand and a regulated consumer report in another, and what moved it was the question the reader intends to answer with it. That is why we ask what the check is for before we ask who it is about – not as a formality, but because the answer determines whether we are the right firm at all.
What the Statutes Actually Permit
Three provisions, quoted, doing three different jobs.
A consumer report is defined by use, not by data
The most common misunderstanding in counterparty checks is that certain records are “FCRA records.” They are not. The statute defines a consumer report as a communication by a consumer reporting agency bearing on a consumer’s credit worthiness, character, general reputation, personal characteristics or mode of living, which is
“used or expected to be used or collected in whole or in part for the purpose of serving as a factor in establishing the consumer’s eligibility for – (A) credit or insurance to be used primarily for personal, family, or household purposes; (B) employment purposes; or (C) any other purpose authorized under section 1681b of this title.” 15 U.S.C. 1681a(d)(1)
Every operative word there is about purpose. Confirming that the company invoicing you is registered, that its principal exists, and that the bank details match what the entity filed is not an eligibility determination about a consumer’s access to credit, insurance or a job. It is a decision about whether you enter a contract. That is why this page can be built out of public records rather than out of a regulated report – and it is also why the same lookup would be off-limits if you were making a hiring decision with it.
The DPPA wrote the counterparty case into the statute
State motor vehicle records are closed by federal law, with a list of enumerated exceptions. One of them is not a loophole; it is a direct description of what a business does when a stranger hands it personal details:
“(3) For use in the normal course of business by a legitimate business or its agents, employees, or contractors, but only – (A) to verify the accuracy of personal information submitted by the individual to the business or its agents, employees, or contractors; and (B) if such information as so submitted is not correct or is no longer correct, to obtain the correct information, but only for the purposes of preventing fraud by, pursuing legal remedies against, or recovering on a debt or security interest against, the individual.” 18 U.S.C. 2721(b)(3)
Two things about that provision are worth holding onto, and the second is the one nobody says out loud. First, Congress contemplated exactly this situation: a legitimate business checking whether what a counterparty gave it is true. Second, the permission is narrow and conjunctive. Subparagraph (A) covers information the individual submitted to you – it is not a warrant to look up a stranger who submitted nothing, and (B) opens only after (A) has shown the submitted information is wrong. A firm that describes this provision as general permission to run anyone has misread it. We work inside (A), we say so on the file, and the request that does not fit gets declined rather than reshaped until it does.
The fork: your decision routes the request
The permissible-purpose section of the FCRA names the two branches side by side. A person who
“intends to use the information for employment purposes” … or who “otherwise has a legitimate business need for the information – (i) in connection with a business transaction that is initiated by the consumer” 15 U.S.C. 1681b(a)(3)(B), (F)(i)
is standing at a fork. The employment branch is the one we decline and hand off. The transaction branch describes the counterparty case, and it is worth being precise about what that does and does not mean for us: subparagraph (F)(i) is a permissible purpose for a consumer reporting agency to furnish a report. It is not a license for anyone else to become one, and we do not read it as one. What it does establish is that federal law itself treats a transaction the consumer initiated as a different animal from an eligibility determination – which is the distinction this whole page turns on. We work the transaction case out of public records, and we are not a consumer reporting agency either way. None of this is legal advice; if you are unsure which branch your decision sits on, that is a question for your own counsel, and the honest answer to an unclear case is to treat it as covered.
Hiring, Renting, or Lending? This Is the Wrong Page
Where to go instead, and why we say no.
A large share of people who search for how to verify someone’s identity are not doing a deal at all. They are about to employ somebody, rent them a unit, or extend them credit, and they have arrived at a page about counterparty verification because the phrasing sounds close enough. It is not close enough, and the difference is not a technicality about which vendor you buy from – it is the difference between a business decision you make about a contract and an eligibility decision the law makes you take through a regulated channel with disclosure, written consent and adverse-action notices attached.
So, plainly: if the answer will decide whether someone gets a job, we do not run it. The employment-screening question has its own requirements and its own workflow, which are set out in verifying a job applicant’s identity, and the report itself has to come from a consumer reporting agency operating under the Fair Credit Reporting Act. The same applies to screening a rental applicant and to extending consumer credit or insurance. We are not a consumer reporting agency, we do not furnish consumer reports, and we will not let non-FCRA research be relabeled and used for an FCRA-covered decision – not because the research would be worse, but because the consumer’s statutory rights to notice, to dispute and to a copy of the file simply do not exist outside that channel.
The line is genuinely narrower than people expect, and it is worth testing your own case against it before you send us anything. Vetting a supplier before you place an order: ours. Vetting the person who will drive your truck: not ours. Confirming that an investor introducing themselves by email is a real individual behind a real entity: ours. Deciding whether to approve that person’s application for a store credit account: not ours. If your case sits on the wrong side of that line, saying so at intake costs you a conversation and saves you a compliance problem, and we would rather turn the work away than take it.
The Moments That Cost People Money
Where an unverified counterparty turns into a loss.
The Deposit Before the Work
Money moves first, the entity is never checked.
The Invoice With New Bank Details
A familiar supplier, an unfamiliar account.
The Supplier You Only Know Online
A polished site, no verifiable registration.
The Partner Whose History You Cannot See
Prior entities that were never mentioned.
The Buyer Who Wants Goods Shipped First
Delivery on terms, before payment clears.
The Offer That Found You
You did not go looking for this deal.
A Callback Proves the Line, Not the Person
Why the standard anti-fraud advice stops one step short.
The advice every bank and accounting firm gives before a payment goes out is to confirm through a second channel: do not use the number in the email, look up a known number and call it back. That is good advice and you should follow it. It is also incomplete, and the gap in it has widened. A callback confirms that the number you dialed reaches someone who answers as expected. It does not confirm who that person is, and synthetic voice has quietly removed the last informal check most people were relying on – the sense that the voice on the line sounded right. Treating a familiar-sounding voice as corroboration is now a habit worth retiring.
The structural point is this: every channel a counterparty controls can be re-routed by whoever controls it. The email domain, the phone number, the web form, the reply address on an invoice – all of them are things the other side supplied, and an impersonator who has taken over the relationship has taken over the channel with it. A record trail is the exception, because it was created by third parties on their own schedule and for their own reasons, and the person trying to deceive you has no way to reach back and edit a state’s filing history or a county’s index. That asymmetry is the whole reason records-based verification is worth doing at the moment money moves.
In practice that means the payment-change email is answered with a records question rather than a phone question: is the entity on this invoice the entity we contracted with, is it still in good standing, does the name on the receiving account correspond to anything that entity has ever filed, and did the details we were given about the individual signing hold up. Where an unsolicited approach looks engineered rather than merely unfamiliar, the sequence for handling it without tipping anyone off is covered in our approach to verifying suspicious contacts. Verification that depends on a ruse is not verification, and it would not survive being explained afterward.
From Filing to Person, In That Order
Four steps, cheapest and least regulated first.
Name the Decision
What the answer will be used for, first.
Tie the Entity to a Filing
Status, formation, agent, secured creditors.
Reach the Person Behind It
A traceable individual, namesakes ruled out.
Test What You Were Given
Their details against independent records.
Where Our Work Stops
The limits, stated before you ask.
We report what the record shows and we do not tell you whether to proceed. A confirmed entity and a confirmed principal are not a promise of good faith, and a discrepancy is not proof of fraud – it is a thing to weigh, usually alongside price, terms and how much you can afford to lose. Each finding goes back with the source it came from and an honest note on how confident we are in it, and a record that comes back entirely clean is reported as plainly as one that does not.
On method, three limits are absolute. We never pretext, impersonate, or use a ruse to draw information out of the subject or a third party. We never reach into private financial account contents or balances – what a company has filed is fair game, what sits inside its bank account is not. And we work only under a permissible purpose that we ask you to state before we start; a request that cannot name one is declined rather than quietly narrowed until it passes. On what we are: this is a skip-tracing and public-records research firm, not a private investigation agency. Nobody here holds a private investigator’s license, we do not offer surveillance, and we do not cite the licensed-investigator exemptions in the privacy statutes, because they are not ours to cite.
There is one misuse this particular page invites, and it is worth naming rather than leaving to intake. “I need to verify who this person really is” is also the sentence used by someone trying to locate a partner or former partner who has deliberately cut contact – and a commercial framing does not change what the search would do. Where a request looks like it is about reaching a person rather than closing a transaction, it gets more scrutiny at intake, not less: we ask what the deal is, who the entity is, and what is being signed, and where the answers do not describe a transaction we decline the work. We do not run searches that would help locate someone who is hiding from an abusive situation or who is protected by a protective order, and we do not take that decision back once it is made. A counterparty check has an entity at the center of it; if there is no entity and no deal, this is not the service being asked for.
Finally, the obvious one: this page is general information about how these checks are structured, not legal advice, and none of the statutes quoted above is reproduced here as a substitute for reading them or for asking your own counsel how they apply to your facts.
Who Brings Us This Question
Transaction-side requests, lawful purpose stated.
Small Business Owners
A new supplier before the first order
Franchise Buyers
The entity selling the territory
Freight and Logistics
A broker or carrier on a first load
Equipment Buyers
A high-value seller met online
Deal Attorneys
A counterparty confirmed pre-signing
Nonprofit Boards
A grantee or contractor before award
What these requests have in common is a deadline and a signature. Somebody is waiting on a wire, a purchase order or an executed agreement, and the question is not “is this person a good person” but “does this counterparty exist as described.” Tell us the entity name and state, whatever the other side gave you about the individual behind it, and what you are about to sign or send. A first read typically comes back within 24 hours.
What We Put Our Name To
We work the entity layer before the person layer, we tell you which of the two answered your question, and we show the source behind each finding with an honest note on how far it can be pushed. We state a permissible purpose before we start, we never pretext and never reach into private financial account contents, and nobody here holds a private investigator’s license because this work does not require one. Hiring, tenancy and consumer-credit decisions go to a regulated CRA – we are not one and we do not furnish consumer reports. Lawful records research since 2004; a first read typically comes back within 24 hours.
Frequently Asked Questions
Should I check the company or the person first?
The company, almost always. Corporate filings are open records, they cost little or nothing to pull, and no privacy statute stands between you and them, because a filing is not a consumer, a driver record or a bank customer file. They also settle a lot of deals outright – a dissolved status, a resigned registered agent, or a formation date that contradicts the sales pitch ends the conversation before anyone looks at a person. Only when the entity checks out does it make sense to spend effort, and permissible purpose, on the individual behind it.
Is a counterparty check a background check, and does the FCRA apply?
It depends entirely on what you will do with the answer. The Fair Credit Reporting Act defines a consumer report by use: information used as a factor in establishing a consumer’s eligibility for credit or insurance for personal, family or household purposes, for employment, or for another purpose listed at 15 U.S.C. 1681b. Deciding whether to sign a contract with a business is none of those. Deciding whether to hire, rent to, or extend consumer credit to someone is. The first is research you can commission; the second has to come from a regulated consumer reporting agency. We are not one.
I am about to hire this person – can you run the same check?
No, and we will say so at intake rather than after. An employment decision is an eligibility determination under 15 U.S.C. 1681b(a)(3)(B), which means the report has to come from a consumer reporting agency, with the disclosure, written authorization and adverse-action steps the statute requires. Those are the applicant’s rights, and they do not exist outside that channel, so relabeling non-FCRA research as a “verification” would strip them. Employment screening has its own workflow, and a regulated provider is where that request belongs.
Is it lawful to check the personal details a counterparty gave me?
Where the information came from the person and you are a legitimate business acting in the normal course of business, federal law addresses this directly. The Driver’s Privacy Protection Act permits use of protected motor vehicle data “to verify the accuracy of personal information submitted by the individual” at 18 U.S.C. 2721(b)(3)(A). Note how narrow that is: it covers what they submitted to you, not a general lookup of a stranger, and the follow-on permission at (B) opens only if what they gave you turns out to be wrong. We work inside that limit and decline requests that do not fit it.
They emailed asking me to wire to a new account. What should I do first?
Do not use any contact detail from that message, and do not treat a callback as settled proof – a second channel confirms the line, not the identity of the person on it, and a familiar-sounding voice is no longer corroboration. Ask records questions instead: is the entity on this invoice still in good standing, is it the same entity you contracted with, and does the receiving account name correspond to anything that entity has filed. We can run that quickly. We will not contact the other side for you or play along with a suspected fraud.
Where does the information come from, and is any of it private?
State business registries, annual reports and registered-agent records, UCC filings, county property and court indexes, and investigative-grade sources used under a permissible purpose you state before we begin. We never pretext, impersonate or use a ruse to pull information out of the subject or a third party, and we never reach into private financial account contents or balances. What an entity has filed is open; what sits inside its bank account is not, and no client request changes that. If a request has no lawful purpose behind it, we decline it.
What happens if everything checks out?
You get told so directly, with the same detail as an adverse finding: entity registered and in good standing since a stated date, principals named on the filings, details you were given corroborated against independent records, and an honest note wherever a record is thinner than we would like. A clean answer is the more common one and it is worth exactly what you paid for it, because proceeding with a documented basis is a different position from proceeding on a feeling. We do not invent concerns to make a report look busier.
What do you need from me, and how long does it take?
The entity name and the state it claims to be registered in, whatever the other side told you about the individual behind it, the documents in front of you, and one sentence on what you are about to sign or send – that last part decides whether we are the right firm at all. For a workable request with a lawful, legitimate purpose, a first read typically comes back within 24 hours, and time-sensitive deals with money waiting go first. You get sourced findings and a clear statement of what is confirmed, what is not, and what is still open.
Confirm the Entity – Then the Person
Before the wire leaves or the signature goes on, take the two layers in order: the company in the state’s own records, then the human being behind it, with the reason for the check stated up front. Send us the entity name and state, whatever you were given about the individual, and one line on the deal – typically a first read within 24 hours, sourced, with an honest note on anything we could not stand behind. Hiring, tenancy and consumer-credit checks go to a regulated CRA; we are not one. Contact us to get started.
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