I agree with Jeanine.  It's a bandage for the wrong boo-boo.

 I guess, if they are dead-determined to do so, my input is this:

1.  Have it online and open for anyone to access and search:  include not only the index but the underlying records themselves.

2.  Model it on PACER or some Secretary of States' offices (like CA) where UCC Financing Statements can be filed and viewed.  Only, in this case, force the financial institutions to BOTH file it in the Federal system, BUT record first in the local county records (no federal filing accepted without a county recorders stamp on it first).

 3.  Create a reasonable grace period for both banks and insurers before anyone will be held liable for checking and reporting on matters in a flawed system.

4.  Ensure that the online search has a effective date range for both start and finish clearly posted on it.

5.  Have a notation system publicly viewable for tracking index updates when errors are spotted and corrected.  The old, misindex data should show and the new data should show and both must display in search results with clear annotations as to the matter:  when originally indexed and when changed.