Furnisher Data Reporting and Process Requirement Changes
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Furnisher Data Reporting and Process Requirement Changes
National Consumer Assistance Plan |
Equifax,
Experian and TransUnion recently announced the National Consumer
Assistance Plan that will enhance their ability to collect complete and
accurate consumer information and will 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 reporting requirements and
collection procedures. The resulting initiatives will impact
furnisher reporting. |
Initiatives |
Below is a summary of
upcoming initiatives, impacted furnishers, and 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 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 |
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All Data
Furnishers |
Minimum reporting
requirements for consumer personally identifiable information |
9/15/2017
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Reporters of
Authorized User Data |
Report full Date of Birth
for new Authorized Users on all accounts |
9/15/2017
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Recommended Action |
It is strongly advised that
all Data Furnishers:
- 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.
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Initiative
Details by Furnisher
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Collection Agencies/Debt Buyers |
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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 |
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Do not report debt that
did not arise from a contract or agreement to pay |
Do not report debt that
did not arise from a contract or agreement to pay (including, but not
limited to, certain fines, tickets, and other assessments).
|
6/15/2016 |
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Report a full file monthly |
Report your full file
monthly including accounts that are open, that are paid in the last 90
days, or that require deletion or correction.
|
9/1/2016
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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 First
Delinquency.
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9/15/2017 |
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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 |
There will be greater
reliance on collecting and reporting broader consumer identification
information (Full Name and Address along with Social Security Number
and Date of Birth). You should collect and report all consumer
identifiable information.
Further details will be
communicated in the coming months.
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9/15/2017 |
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Reporters of Authorized User Data |
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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.
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9/15/2017 |
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Article
Provided By:
Experian
Information Solutions
475
Anton Blvd.
Costa
Mesa, CA 92626
www.experian.com
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