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Understanding your consumer data reporting requirements

In March 2015, Experian, Equifax and Trans Union announced an agreement to enhance collecting accurate consumer information and providing consumers with a better experience interacting with the National Credit Reporting Agencies (CRA’s) about their credit reports, through the National Consumer Assistance Plan (NCAP).

Since then, a series of mandatory updates to data reporting and collections procedures have been announced and implemented.

Have you made the required changes and are you prepared for the next implementation?

Understanding how these changes affect your business and reporting processes can be difficult to navigate. Some of these changes affect all data furnishers while others are relevant to collection agencies and debt buyers only. Here’s what you need to know:

What’s coming up that ALL consumer data furnishers need to know?

Effective Sept. 15, 2017, new requirements for reporting personally identifiable information will be in place. This new minimum standard will apply to accounts reported with a date opened after Sept. 15, 2017 and must be included for the CRAs to accept these records for processing. Following the Metro 2® Format, furnishers must report:

  • Full name (First, middle or middle initial (if available), last and generation code/ suffix)
  • Address
  • Full Social Security Number (If full Social Security Number is not available, full Date of Birth (mmddyyyy) will be required)
  • Date of birth (mmddyyyy)

As of Feb. 1, 2018, consumer data will no longer be accepted by the CRAs in the older MetroTM format. Prior to the effective date you will need to take the necessary action to ensure that your organization will convert to the Metro 2® Format. You can access information about the Metro 2® Format on the Consumer Data Industry Association website. Should you have any questions about your Experian conversion, we’re here to help, contact us at Experian Experian_Metro2_Conv@experian.com

Do you report Authorized User trades?

Effective Sept. 15, 2017 you must report the full date of birth for newly added authorized users on all pre-existing and newly opened accounts.

If you are a collection agency or debt buyer, the following changes are ALSO applicable to your business:

As of Sept. 15, 2017, you will need to stop reporting medical debt collection accounts until they are at least 180 days past the date of first delinquency with the original creditor and delete any accounts that are being paid by insurance or paid in full through insurance.

Effective Sept. 1, 2016, you must report a full file monthly. This means reporting all accounts monthly, including open collection accounts, collection accounts paid in full, and accounts requiring deletion or correction.

In June 2016, the CRA’s agreed to adopt a certain industry standard with respect to the reporting of debts that did not arise from a contract or agreement to pay. Experian’s policy even prior to June 2016 is not to accept any data that falls outside of a 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.

Also, the name of the Original Creditor and Creditor Classification Code became requirements to include in all reporting per the Metro 2® Format.

These changes are important to the quality of our data and ultimately provide a positive impact to the consumer and your business. Are you prepared?