Two mandatory data reporting requirements go into effect June 15, 2016.
Equifax, TransUnion and Experian issued a memo to all data furnishers in March providing notification of new initiatives and upcoming changes to certain furnishing requirements. Two initiatives in the memo, which impact the furnishing activities of debt collectors and asset buyers, are effective June 15, 2016. According to the memo, it is “strongly advised” that all furnishers implement these initiatives on or before the effective date.
Collection agencies and debt buyers must 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. Also, they should not report debts that did not arise from a contract or agreement to pay - including, but not limited to: certain fines, tickets and other assessments. Other examples include library fees or fines, parking tickets, speeding tickets, and court fees or fines.
Additional furnisher reporting and process requirement changes will also take effect later in 2016 and 2017. These requirements can all be found in the referenced memo from Equifax, TransUnion and Experian.
As previously reported by ACA, these new furnishing requirements were first announced by the consumer reporting agencies (CRAs) and the Consumer Data Industry Association in 2015. The changes are being implemented nationwide, and stem from a consent decree between the CRAs and a number of state Attorneys General (AGs). [Note that the consent decree with state AGs included deadlines for implementation; however, some of the changes required by the decree have already been instituted and a number of other initiatives are being rolled out by the CRAs in advance of the deadlines listed in the consent decree].
ACA will continue to monitor and provide details on these initiatives as more information becomes available. Questions regarding the initiatives are best directed to CRAs, as they are in the best position to clarify any changes to the furnishing process. The CRAs can be contacted via the email addresses below.