19. How should deceased borrowers be reported?
Answer: Deceased borrowers should be reported with ECOA Code X
2. the borrower is reported as deceased and
3. the account has been reported with an ECOA Code X.
2. remove deceased borrower from account once they have been reported with ECOA CODE X
3. if the deceased borrower was the primary borrower another borrower must be updated from a joint borrower to the primary borrower
Important: Do not report ECOA Code X until you have received a legally-sufficient death notice; e.g., death certificate.
Data furnishers should consult with internal Legal counsel or Compliance area regarding what constitutes a legally-sufficient death notice. Reporting a consumer as deceased provides valuable information on the credit report. If another consumer tries to use the identity of a deceased consumer, the “deceased” information will appear on the credit report, helping to deter the fraudulent activity.
Note: Debt Buyers and Third Party Collection Agencies should refer to the Debt Buyer/Collection Agency section under General Reporting Guidelines for guidance on reporting deceased borrowers
- An ECOA Code X should be reported only for the deceased consumer; not all consumers associated with the account.
- Stop reporting the entire account if
2. the borrower is reported as deceased and
3. the account has been reported with an ECOA Code X.
- Do not report the account with a trustee or estate name.
- For joint accounts where one borrower is deceased continue reporting the account following these adjustments
2. remove deceased borrower from account once they have been reported with ECOA CODE X
3. if the deceased borrower was the primary borrower another borrower must be updated from a joint borrower to the primary borrower
Important: Do not report ECOA Code X until you have received a legally-sufficient death notice; e.g., death certificate.
Data furnishers should consult with internal Legal counsel or Compliance area regarding what constitutes a legally-sufficient death notice. Reporting a consumer as deceased provides valuable information on the credit report. If another consumer tries to use the identity of a deceased consumer, the “deceased” information will appear on the credit report, helping to deter the fraudulent activity.
Note: Debt Buyers and Third Party Collection Agencies should refer to the Debt Buyer/Collection Agency section under General Reporting Guidelines for guidance on reporting deceased borrowers
