ECOA Requirements

Question: How do I comply with ECOA?
  • Answer: While ECOA requires only the reporting of spouse information, industry practices encourage the reporting of all consumers associated with an account. The correct ECOA Code should be reported in the Base, J1 and J2 Segments.

Question: How is an ECOA change reported?
  • Answer: Change the ECOA Code to the new value in the segment that has changed. Refer to field descriptions for a list of ECOA Codes.

Question: What is the difference between ECOA Codes T (Association with Account Terminated) and Z (Delete Consumer)?
  • ​Answer:
  1. ​ECOA Code ‘T’ should be reported when a consumer is no longer associated with an account. In subsequent reporting periods, this consumer should not be     reported. The account, including payment history reported prior to the termination will be retained, but future updates will not be applied to the account for this consumer.     ​
  2. ECOA Code ‘Z’ should be reported when a consumer was reported in error and the account, including payment history, should be deleted from this   consumer’s file. It is imperative that ECOA Code ‘Z’ is reported only on the consumer who was inaccurately reported. In subsequent reporting periods, this consumer should not be  reported.
Note: Only inaccurately reported consumers should be deleted. Additionally, Accounts included in Bankruptcy Chapter 7, 11, 12 & 13:, authorized users should be deleted from accounts included in bankruptcy since authorized users are not contractually responsible for payments.