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FCRA Requirements

Question: The Fair Credit Reporting Act requires certain information to be reported with regard to returned checks. What are those requirements?

Answer: For companies who report returned checks, such as collection agencies, factoring companies or check guarantee companies, there are four reporting guidelines:

The Date Opened should contain the date of the check.
The Highest Credit or Original Loan Amount should contain the original amount of the check, excluding fees and interest.  
The Original Creditor Name should contain the name of the payee.
The FCRA Compliance/Date of First Delinquency should contain the date the check was returned for nonsufficient funds. If not available, report the date of the check.
Question: How do I comply with the reporting requirements of the 1997 Fair Credit Reporting Act?

Answer:

Date of First Delinquency

When an account is delinquent, Field 25 —the FCRA Compliance/Date of First Delinquency should reflect the date of the first delinquency (in an unbroken chain) that led to the status being reported. Refer to Exhibit 8 for a detailed explanation and examples.


Closed Accounts

XA- This Compliance Condition Code should be reported to indicate that the account was closed at the consumer's request. Applies to accounts with Portfolio Types C (Line of Credit), O (Open) and R (Revolving).


Disputed Accounts
XB- This Compliance Condition Code should be reported to indicate that the account information is disputed by the consumer.

XC - This Compliance Condition Code should be reported to indicate "Completed investigation of FCRA dispute - consumer disagrees"


Closed and Disputed Accounts  

XD - This Compliance Condition Code should be reported to indicate that the account was closed at the consumer's request and account information is disputed by the consumer. Applies to accounts with Portfolio Types C (Line of Credit), O (Open) and R (Revolving).

XE - This Compliance Condition Code should be reported to indicate that the account was closed at the consumer's request and dispute investigation completed - consumer disagrees. Applies to accounts with Portfolio Types C (Line of Credit), O (Open) and R (Revolving).

 Note: Compliance Condition Codes are reported in Field 20.


Medical Debts  

Third-party data providers who report medical debt information must report the K1 Segment with the Original Creditor Name and Creditor Classification 02 (Medical/Health Care).  

Original creditors who report medical payment information must report Account Type Code 90 (Medical Debt). 
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