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Update 8/10/2017

Many Credit Reporting Agencies (CRAs) have started enforcing these new policies, please review communications from your reporting CRA to determine if you are still compliant with Metro 2 ® Reporting Guidelines and NCAP.

Data Furnisher Reporting & Process Requirement Changes May 2016

If you have not been reading your email or you are about to start reporting credit history using the Metro2® format. Read on! there are subtle but important changes you will want to use right away so you are not stuck on a weekend at the office figuring it out the week before the deadlines.

There are several deadlines, some affect all industries and others are for Collections and Debt Buyers. Please read on and contact your credit bureau representatives for assistance in their interpretation for your company type.

National Consumer Assistance Plan

In 2015, Equifax, Experian and TransUnion announced the National Consumer Assistance Plan to enhance their ability to collect complete and accurate consumer information and provide consumers more transparency when interacting with consumer reporting agencies about their credit reports. The plan was announced after cooperative discussions and an agreement with the Attorneys General of multiple states.

Impact of the Plan

The agreement provides for updates to mandatory data reporting requirements and data collection procedures.  The resulting initiatives will impact Data Furnisher reporting.  The requirements listed are in addition to reporting requirements of any individual CRA.

Actions Required By Data Furnishers

Data Furnishers must:

  • Review the list of initiatives and the details that follow to understand which changes will affect you.
  • Forward this communication within your organizations in order to disseminate the requirements widely (Technology, Compliance, Operations, etc.).
  • Ensure that your organizations successfully implement these initiatives in all affected systems and departments on or before the Effective Dates listed above.
  • Monitor your data on an ongoing basis to ensure these requirements are met.

Initiatives

Below is a summary of upcoming initiatives, impacted furnishers, and the Effective Dates. You should implement these data reporting changes in advance of the Effective Dates.  Details of each initiative are provided further down:

 

Who is Impacted?
What is Required?
Effective Date
Collection Agencies and Debt Buyers
Report the name of the Original Creditor and Creditor Classification Code
6/15/2016
Collection Agencies and Debt Buyers
Do not report debt that did not arise from a consumer contract or agreement to pay
6/15/2016
Collection Agencies and Debt Buyers
Report a full file monthly
9/1/2016
Collection Agencies and Debt Buyers
Do not report Medical Debt collection accounts less than 180 days old
9/15/2017
Collection Agencies and Debt Buyers
Report a delete for accounts that are being paid or were paid in full through insurance
9/15/2017
All Data Furnishers
Report using the newly established minimum reporting requirements for consumer personally identifiable information
9/15/2017
 
Reporters of Authorized User Data
Report full Date of Birth for new Authorized Users on all accounts
9/15/2017
 

 

Initiative Details by Furnisher

Collection Agencies/Debt Buyers

Initiative
Furnisher Action
Effective Date
Report the name of the Original Creditor and Creditor Classification Code
Report the Original Creditor Name and the valid Creditor Classification Code according to the Metro 2® format. These fields are required for each account or item reported.
6/15/2016
Do not report debt that did not arise from a consumer contract or agreement to pay
Do not report debt that did not arise from a consumer contract or agreement to pay, including, but not limited to, certain fines, tickets, and other assessments.  For example, library fees or fines, parking tickets, speeding tickets, and court fees or fines.
6/15/2016
Report a full file monthly
To avoid potential deletion of data by the CRAs, you must report your full file monthly including accounts that are open, that are paid in the last 90 days, or that require deletion or correction.
Reminder – Do not report collections that exceed the seven-year reporting period as specified by the Fair Credit Reporting Act (FCRA).
9/1/2016
Do not report Medical Debt collection accounts less than 180 days old
Do not report Medical Debt collection accounts (as defined by Creditor Classification Code 02) until they are at least 180 days past the Date of the
First Delinquency with the original creditor that led to the account being sold or placed for collection.
9/15/2017
Remove Debt paid or being paid by insurance
Report a delete for accounts that are being paid by insurance or were paid in full through insurance (not by the consumer).
9/15/2017
Reporting of consumer personally identifiable information
A new minimum standard has been established to expand the CRAs’ capabilities to match credit data to the file of the appropriate consumer.
 
This new minimum standard will apply to accounts reported with a Date Opened after 9/15/2017 in order for the CRAs to accept these records for processing.
 
Following the Metro 2® format, Furnishers must report: 
  • Full name (First Name, Middle Name or Middle Initial (if available), Last Name and Generation Code/Suffix)
  • Address
  • Full Social Security Number
  • Date of Birth (mmddyyyy) 
 
If full Social Security Number is not available, full Date of Birth (mmddyyyy) will be required.
 
Data will be monitored to ensure these requirements are met.
9/15/2017

Reporters of Authorized User Data

Initiative
Furnisher Action
Effective Date
Report full Date of Birth for new Authorized Users on all accounts
Report the full Date of Birth (month, day, and year – MMDDYYYY) for newly added authorized users (ECOA “3”) on ALL pre-existing and newly opened accounts.
9/15/2017

 

As you can see, there are changes for everyone. Thanks for reading.