First Time Reporters
Question: Are there any special reporting requirements for a first time reporter when sending data to the consumer reporting agencies?
Answer: It is very important to ensure that the FCRA Compliance/ Date of First Delinquency is reported accurately. When historical credit information is reported in the Payment History Profile (Field18), the Date of First Delinquency must reflect the date of the first delinquency that led to the earliest delinquency reported in the Payment History Profile. In this situation, the Date of First Delinquency must be reported, regardless of the Account Status Code being reported.
Example 1
Account Status = 93 (Collection)
Payment History Profile = GGGGGGGGGGGG666654321100
Billing Date = 10/31/2003
Date of First Delinquency = 12/31/2001
In the above example, 12/31/2001 represents the date of the earliest 30-day delinquency represented in the Payment History Profile that led to the Collection (Code G) being reported.
Example 2
Account Status = 11 (Current Account)
Payment History Profile = 000000GGGGGGGGGGGGGGGGGG
Billing Date = 10/31/2003
Date of First Delinquency = 03/31/2000
In the above example, 03/31/2000 represents the date of the earliest 30-day delinquency that led to the Collection (Code G) reported in the Payment History Profile. In this scenario, the 30-day delinquency was outside the time period represented in the Payment History Profile.
Answer: It is very important to ensure that the FCRA Compliance/ Date of First Delinquency is reported accurately. When historical credit information is reported in the Payment History Profile (Field18), the Date of First Delinquency must reflect the date of the first delinquency that led to the earliest delinquency reported in the Payment History Profile. In this situation, the Date of First Delinquency must be reported, regardless of the Account Status Code being reported.
Example 1
Account Status = 93 (Collection)
Payment History Profile = GGGGGGGGGGGG666654321100
Billing Date = 10/31/2003
Date of First Delinquency = 12/31/2001
In the above example, 12/31/2001 represents the date of the earliest 30-day delinquency represented in the Payment History Profile that led to the Collection (Code G) being reported.
Example 2
Account Status = 11 (Current Account)
Payment History Profile = 000000GGGGGGGGGGGGGGGGGG
Billing Date = 10/31/2003
Date of First Delinquency = 03/31/2000
In the above example, 03/31/2000 represents the date of the earliest 30-day delinquency that led to the Collection (Code G) reported in the Payment History Profile. In this scenario, the 30-day delinquency was outside the time period represented in the Payment History Profile.