Student Loan Reporting
GENERAL REPORTING GUIDELINES
Reporters of student loan information include lenders, servicers, secondary markets, guaranty agencies, collection agencies and the U.S. Department of Education.
The following reporting guidelines refer to all reporters of student loan information:
· Report data in the standard Metro 2 Format.
· Report on a monthly basis.
· Report all open accounts monthly.
· Report transferred, paid, and government claim accounts at the end of the month in which they occur.
· Report the complete name, address and social security number of the consumer.
· In the Identification Number field, report the internal code that identifies the lender, servicer, secondary market, or guarantor where information is verified.
· All parties reporting credit information must respond to consumer inquiries.
Note: The guidelines in this document are specific to your industry and should be used in conjunction with the specifications in the Metro 2 Format. Refer to the Metro 2 Format for detailed information on segments and field information.
LENDER/SERVICER/SECONDARY MARKET REPORTING GUIDELINES
1. Account Type Code — 12 Education Loan for all accounts
2. Terms Duration — report monthly terms while the loan is in repayment
Terms Duration for loans in "initial school period" and a "grace period" should be blank filled since there are currently no terms. For loans in "forbearance", report the terms that have been set for interest payments only.
3. Account Status Codes
· 11 Current Account — Open account in good standing
Note: Do not report loans until the monies are disbursed to the student.
· 11 Current Account - with Terms Frequency D Deferred and Payment History Profile Character B — Open account/payments deferred/account was never in repayment
· 11 Current Account - with Terms Frequency D Deferred and Payment History Profile Character D — Open account/payments deferred/account was previously in repayment
Notes: Terms Frequency Code D Deferred should be used with Account Status Code 11 Current Account to show that payments are not currently being made (e.g., deferment, grace period, forbearance), but there is a future payment obligation.
Do not include deferred student loans in calculation of delinquency logic. Report an Amount Past Due = 0.
· 71 Account 30-59 days past the due date, 78 Account 60-89 days past the due date, 80 Account 90-119 days past the due date, 82 Account 120-149 days past the due date, 83 Account 120-149 days past the due date, 84 Account 180 days past the due date - the appropriate stage of delinquency (30 days to 180 or more days past the due date)
· 13 - Closed/paid/zero balance account
Notes: For paid accounts, report the Date Closed. Also, report both the Current Balance and the Amount Past Due as zero.
When reporting Account Status Code 13, the Payment Rating must also be reported.
· 88 Claim Filed with government for insured portion of balance on a defaulted loan - Claim filed with government for insured portion of balance on defaulted loan
Notes: If Status Code 88 is reported but reversed after government review, report the account as Status Code DA to delete the account. The following month, report the account with the original Date Opened, the original Consumer Account Number, and the actual status. If valid payment history is available, it can be reported in the Payment History Profile.
Status 88 should be reported for the situation called "non-matriculate," in which the student never enrolled. The claim is filed immediately.
When reporting Account Status Code 88, the Payment Rating must also be reported.
· 05 Account transferred to another office, with Special Comment Code AT Account closed due to transfer - Account closed due to transfer. (Does not include transferred to a servicer, unless that servicer is the new holder of the note.)
Notes: The Current Balance and Amount Past Due should be reported as zero.
When reporting Account Status Code 05, the Payment Rating must also be reported.
4. Payment History Profile - Provides up to 24 months of payment history. For deferred loans, report the Grid Character B for loans that have never been in repayment, and report Grid Character D for loans that were previously in repayment.
Example of Payment History Profile for a loan reaching government claim status:
Account Status Code 88, Payment Rating = 6
Date of Account Information = 01/31/2003; Date of First Delinquency = 01/31/2002
Payment History Profile = 665432111111000000000000
In the above example, the Payment History Profile represents, from left to right, 12/31/2002 through 01/31/2001. The 0's indicate the account was current from 1/31/2001 through 12/31/2001. The account became 30 days delinquent in 01/31/2002 and progressed to 180 days delinquent through 12/31/2001. A government claim was filed in 01/31/2003, resulting
in the Status Code 88.
Note: It is important that the Payment History Profile be reported in order for the lender to control and maintain the payment history.
5. Compliance Condition Codes and Special Comments
Report in conjunction with Account Status Codes to further define the accounts.
Examples:
· Special Comment AT (Account Closed due to Transfer) —with Account Status Code 05—when an account is sold to another lender.
· Special Comment BT (Principle deferred/Interest payment only)—for loans in forbearance
· Compliance Condition Code XB (Account information disputed by consumer) could be reported with Account Status Code 88.
6. FCRA Compliance/Date of First Delinquency - report the date as described in the Metro 2 Format.
7. Consumer Information Indicators - used to specify that a consumer has filed bankruptcy or a consumer cannot be located. Refer to Exhibit 9 in the Metro 2 Format for a list of available indicators.
8. Deferred Payment Start Date — report for deferred loans.
For Multiple Disbursements of the Same Loan:
· Combine multiple disbursements into a single account.
· Retain the original Consumer Account Number.
· Retain the original Date Opened of the first disbursement.
· Increase the Original Loan Amount, Current Balance, and Scheduled Monthly Payment Amount (when in repayment) to include totals for all disbursements.
Example: If the loan is for $10,000 and the first disbursement is for $2,000, report the Original Loan Amount field as $2,000. As additional disbursements are made, increase the Original Loan Amount field to include additional disbursements.
· Change Terms Duration if appropriate.
For Multiple Loans:
· Multiple loans must be reported as separate accounts.
· When multiple loans are consolidated, report the new loan as Account Status Code 11 and each multiple loan as Account Status 13, with the appropriate Payment Rating.
For Loans Transferred in from Another Lender:
· If the previous reporter's Consumer Account Number is available, report the L1 Segment to change the Consumer Account Number. The Base Segment should contain the previous reporter's Consumer Account Number, and the L1 Segment should contain the reporter's New Consumer Account Number. The L1 Segment should only be reported the first time the new account number is reported.
· Retain the previous lender's Date Opened.
· Report the Portfolio Purchased From code at least one time, to show the name of that lender and avoid confusion for the consumer.
Example: If XYZ Bank buys accounts from ABC Bank, XYZ Bank or their servicer should report a K2 Segment containing ABC Bank.
Note: Notify your consumer reporting agencies the first time this situation occurs, for testing purposes.
For Loans Reported by a Servicer:
· The Identification Number should refer to the current holder of the note.
Note: Verification of accounts will be done with the servicer.
For Loans that are Forgiven when a School Closes:
· Report Account Status Code DA to delete the account.
For Loans that are Forgiven when a Student becomes Disabled:
· If the loan had been in repayment prior to the student becoming disabled, report Account Status Code 13, Payment Rating 0, Current Balance 0, and Amount Past Due 0 to indicate a paid/closed account, along with the appropriate Date Closed.
· If the loan had never been in repayment, report Account Status Code DA to delete the account.
For Loans that are Forgiven due to "Teacher Forgiveness":
· If the loan had been in repayment prior to being forgiven, report Account Status Code 13, Payment Rating 0, Current Balance 0 and Amount Past Due 0 to indicate a paid/closed account, along with the appropriate Date Closed.
· If the loan had never been in repayment, report Account Status Code DA to delete the account.
For Loans that were Falsely Certified:
· Report Account Status Code DA to delete the account.
GUARANTY AGENCY/U.S. DEPARTMENT OF EDUCATION REPORTING GUIDELINES
· Do not report the account during the review period.
· Do not report the account if it is returned to the lender.
· Guaranty agencies should follow the reporting guidelines for Lender/Servicer/Secondary Market when reporting loans that are not guaranteed by the government.
GENERAL REPORTING GUIDELINES
1. Consumer Account Number - report the new number as assigned by the guaranty agency.
2. Portfolio Type - o (open)
3. Date Opened — report the date the defaulted claim was paid to the lender.
4. Terms Duration - 001 (one payment as scheduled)
5. Terms Frequency - Blank
6. FCRA Compliance/Date of First Delinquency - report the date of the first delinquency with the original lender that led to the defaulted claim. If multiple defaults are reported as one loan (compressed), the Date of First Delinquency must be the date of the first delinquency that led to the earliest default.
Effective March 31, 2004, the FCRA states that "provided that the consumer does not dispute the information, a person that furnishes information on a delinquent account that is place for collection, charged for profit and loss, or subjected to any similar action, complies with this paragraph, if
(i) the person reports the same date of delinquency as that provided by the creditor to which the account was owed at the time at which the commencement of th delinquency occurred, if the creditor previously reported that date of delinquency to a consumer reporting agency;
(ii) the creditor did not previously report the date of delinquency to a consumer reporting agency, and the person establishes and follows reasonable procedures to obtain the date of delinquency from the creditor or another reliable source and reports that date to a consumer reporting agency as the date of delinquency; or
(iii) the creditor did not previously report the date of delinquency to a consumer reporting agency and the date of delinquency cannot be reasonably obtained as provided in clause (ii), the person establishes and follows reasonable procedures to ensure the date reported as the date of delinquency precedes that date on which the account is placed for collection, charged to profit or loss, or subjected to any similar action, and reports such date to the credit reporting agency.
7. Consumer Information Indicator - used to specify that a consumer has filed bankruptcy or a consumer cannot be located. Refer to the Consumer Information Indicators section under Reference for a list of available indicators.
8. Original Creditor — report the complete name of the lender to whom the claim was paid in the Original Creditor Name field. Also, report Creditor Classification Code 07 to indicate Educational.
Note: Original Creditor is required for all accounts reported, regardless of Account Status Code.
For Defaulted Loans:
Account Status Codes - report only the following:
· 93 - Account assigned to internal or external collections. (Status 93 should be reported immediately after the review period if retained.)
Notes: If a consumer is making payments, continue to report the account as a Status Code 93, but report the declining balance.
If accounts are turned over to a Collection Agency and the Collection Agency reports the accounts to the credit bureaus, the guaranty agency should report the accounts as Status DA to delete them. These accounts cannot be reported by both agencies, causing duplication. The FCRA Compliance/Date of First Delinquency should contain
the date of the first delinquency with the original lender that led to the default. The K1 Segment should contain the complete name of the original lender/servicer/secondary market to whom the claim was paid, as well as Creditor
Classification Code 07.
· 62 - Account paid in full/was a collection account.
For Rehabilitated Loans:
Report Account Status Code DA to delete the account.
Note: The claim reported by the original lender will remain on the file until purged according to FCRA guidelines.
For Accounts Sent to DOE (Guaranty Agencies Only):
Report Account Status Code DA to delete the account.
For Accounts with a Balance under Total and Permanent Disability:
Report Account Status Code 62 to indicate the account is paid.
For Accounts with a Balance and Consumer who is Responsible for the Account is Deceased:
Report Account Status Code 62 and ECOA Code X.
For Guaranty Agencies Dissolving or Undergoing Bankruptcy:
Contact the Consumer Data Industry Association (CDIA) to determine the appropriate steps in the reporting process that would be unique to the agency's specific situation.
For Loans that are Forgiven when a School Closes:
Report Account Status Code DA to delete the account.
Reporters of student loan information include lenders, servicers, secondary markets, guaranty agencies, collection agencies and the U.S. Department of Education.
The following reporting guidelines refer to all reporters of student loan information:
· Report data in the standard Metro 2 Format.
· Report on a monthly basis.
· Report all open accounts monthly.
· Report transferred, paid, and government claim accounts at the end of the month in which they occur.
· Report the complete name, address and social security number of the consumer.
· In the Identification Number field, report the internal code that identifies the lender, servicer, secondary market, or guarantor where information is verified.
· All parties reporting credit information must respond to consumer inquiries.
Note: The guidelines in this document are specific to your industry and should be used in conjunction with the specifications in the Metro 2 Format. Refer to the Metro 2 Format for detailed information on segments and field information.
LENDER/SERVICER/SECONDARY MARKET REPORTING GUIDELINES
1. Account Type Code — 12 Education Loan for all accounts
2. Terms Duration — report monthly terms while the loan is in repayment
Terms Duration for loans in "initial school period" and a "grace period" should be blank filled since there are currently no terms. For loans in "forbearance", report the terms that have been set for interest payments only.
3. Account Status Codes
· 11 Current Account — Open account in good standing
Note: Do not report loans until the monies are disbursed to the student.
· 11 Current Account - with Terms Frequency D Deferred and Payment History Profile Character B — Open account/payments deferred/account was never in repayment
· 11 Current Account - with Terms Frequency D Deferred and Payment History Profile Character D — Open account/payments deferred/account was previously in repayment
Notes: Terms Frequency Code D Deferred should be used with Account Status Code 11 Current Account to show that payments are not currently being made (e.g., deferment, grace period, forbearance), but there is a future payment obligation.
Do not include deferred student loans in calculation of delinquency logic. Report an Amount Past Due = 0.
· 71 Account 30-59 days past the due date, 78 Account 60-89 days past the due date, 80 Account 90-119 days past the due date, 82 Account 120-149 days past the due date, 83 Account 120-149 days past the due date, 84 Account 180 days past the due date - the appropriate stage of delinquency (30 days to 180 or more days past the due date)
· 13 - Closed/paid/zero balance account
Notes: For paid accounts, report the Date Closed. Also, report both the Current Balance and the Amount Past Due as zero.
When reporting Account Status Code 13, the Payment Rating must also be reported.
· 88 Claim Filed with government for insured portion of balance on a defaulted loan - Claim filed with government for insured portion of balance on defaulted loan
Notes: If Status Code 88 is reported but reversed after government review, report the account as Status Code DA to delete the account. The following month, report the account with the original Date Opened, the original Consumer Account Number, and the actual status. If valid payment history is available, it can be reported in the Payment History Profile.
Status 88 should be reported for the situation called "non-matriculate," in which the student never enrolled. The claim is filed immediately.
When reporting Account Status Code 88, the Payment Rating must also be reported.
· 05 Account transferred to another office, with Special Comment Code AT Account closed due to transfer - Account closed due to transfer. (Does not include transferred to a servicer, unless that servicer is the new holder of the note.)
Notes: The Current Balance and Amount Past Due should be reported as zero.
When reporting Account Status Code 05, the Payment Rating must also be reported.
4. Payment History Profile - Provides up to 24 months of payment history. For deferred loans, report the Grid Character B for loans that have never been in repayment, and report Grid Character D for loans that were previously in repayment.
Example of Payment History Profile for a loan reaching government claim status:
Account Status Code 88, Payment Rating = 6
Date of Account Information = 01/31/2003; Date of First Delinquency = 01/31/2002
Payment History Profile = 665432111111000000000000
In the above example, the Payment History Profile represents, from left to right, 12/31/2002 through 01/31/2001. The 0's indicate the account was current from 1/31/2001 through 12/31/2001. The account became 30 days delinquent in 01/31/2002 and progressed to 180 days delinquent through 12/31/2001. A government claim was filed in 01/31/2003, resulting
in the Status Code 88.
Note: It is important that the Payment History Profile be reported in order for the lender to control and maintain the payment history.
5. Compliance Condition Codes and Special Comments
Report in conjunction with Account Status Codes to further define the accounts.
Examples:
· Special Comment AT (Account Closed due to Transfer) —with Account Status Code 05—when an account is sold to another lender.
· Special Comment BT (Principle deferred/Interest payment only)—for loans in forbearance
· Compliance Condition Code XB (Account information disputed by consumer) could be reported with Account Status Code 88.
6. FCRA Compliance/Date of First Delinquency - report the date as described in the Metro 2 Format.
7. Consumer Information Indicators - used to specify that a consumer has filed bankruptcy or a consumer cannot be located. Refer to Exhibit 9 in the Metro 2 Format for a list of available indicators.
8. Deferred Payment Start Date — report for deferred loans.
For Multiple Disbursements of the Same Loan:
· Combine multiple disbursements into a single account.
· Retain the original Consumer Account Number.
· Retain the original Date Opened of the first disbursement.
· Increase the Original Loan Amount, Current Balance, and Scheduled Monthly Payment Amount (when in repayment) to include totals for all disbursements.
Example: If the loan is for $10,000 and the first disbursement is for $2,000, report the Original Loan Amount field as $2,000. As additional disbursements are made, increase the Original Loan Amount field to include additional disbursements.
· Change Terms Duration if appropriate.
For Multiple Loans:
· Multiple loans must be reported as separate accounts.
· When multiple loans are consolidated, report the new loan as Account Status Code 11 and each multiple loan as Account Status 13, with the appropriate Payment Rating.
For Loans Transferred in from Another Lender:
· If the previous reporter's Consumer Account Number is available, report the L1 Segment to change the Consumer Account Number. The Base Segment should contain the previous reporter's Consumer Account Number, and the L1 Segment should contain the reporter's New Consumer Account Number. The L1 Segment should only be reported the first time the new account number is reported.
· Retain the previous lender's Date Opened.
· Report the Portfolio Purchased From code at least one time, to show the name of that lender and avoid confusion for the consumer.
Example: If XYZ Bank buys accounts from ABC Bank, XYZ Bank or their servicer should report a K2 Segment containing ABC Bank.
Note: Notify your consumer reporting agencies the first time this situation occurs, for testing purposes.
For Loans Reported by a Servicer:
· The Identification Number should refer to the current holder of the note.
Note: Verification of accounts will be done with the servicer.
For Loans that are Forgiven when a School Closes:
· Report Account Status Code DA to delete the account.
For Loans that are Forgiven when a Student becomes Disabled:
· If the loan had been in repayment prior to the student becoming disabled, report Account Status Code 13, Payment Rating 0, Current Balance 0, and Amount Past Due 0 to indicate a paid/closed account, along with the appropriate Date Closed.
· If the loan had never been in repayment, report Account Status Code DA to delete the account.
For Loans that are Forgiven due to "Teacher Forgiveness":
· If the loan had been in repayment prior to being forgiven, report Account Status Code 13, Payment Rating 0, Current Balance 0 and Amount Past Due 0 to indicate a paid/closed account, along with the appropriate Date Closed.
· If the loan had never been in repayment, report Account Status Code DA to delete the account.
For Loans that were Falsely Certified:
· Report Account Status Code DA to delete the account.
GUARANTY AGENCY/U.S. DEPARTMENT OF EDUCATION REPORTING GUIDELINES
· Do not report the account during the review period.
· Do not report the account if it is returned to the lender.
· Guaranty agencies should follow the reporting guidelines for Lender/Servicer/Secondary Market when reporting loans that are not guaranteed by the government.
GENERAL REPORTING GUIDELINES
1. Consumer Account Number - report the new number as assigned by the guaranty agency.
2. Portfolio Type - o (open)
3. Date Opened — report the date the defaulted claim was paid to the lender.
4. Terms Duration - 001 (one payment as scheduled)
5. Terms Frequency - Blank
6. FCRA Compliance/Date of First Delinquency - report the date of the first delinquency with the original lender that led to the defaulted claim. If multiple defaults are reported as one loan (compressed), the Date of First Delinquency must be the date of the first delinquency that led to the earliest default.
Effective March 31, 2004, the FCRA states that "provided that the consumer does not dispute the information, a person that furnishes information on a delinquent account that is place for collection, charged for profit and loss, or subjected to any similar action, complies with this paragraph, if
(i) the person reports the same date of delinquency as that provided by the creditor to which the account was owed at the time at which the commencement of th delinquency occurred, if the creditor previously reported that date of delinquency to a consumer reporting agency;
(ii) the creditor did not previously report the date of delinquency to a consumer reporting agency, and the person establishes and follows reasonable procedures to obtain the date of delinquency from the creditor or another reliable source and reports that date to a consumer reporting agency as the date of delinquency; or
(iii) the creditor did not previously report the date of delinquency to a consumer reporting agency and the date of delinquency cannot be reasonably obtained as provided in clause (ii), the person establishes and follows reasonable procedures to ensure the date reported as the date of delinquency precedes that date on which the account is placed for collection, charged to profit or loss, or subjected to any similar action, and reports such date to the credit reporting agency.
7. Consumer Information Indicator - used to specify that a consumer has filed bankruptcy or a consumer cannot be located. Refer to the Consumer Information Indicators section under Reference for a list of available indicators.
8. Original Creditor — report the complete name of the lender to whom the claim was paid in the Original Creditor Name field. Also, report Creditor Classification Code 07 to indicate Educational.
Note: Original Creditor is required for all accounts reported, regardless of Account Status Code.
For Defaulted Loans:
Account Status Codes - report only the following:
· 93 - Account assigned to internal or external collections. (Status 93 should be reported immediately after the review period if retained.)
Notes: If a consumer is making payments, continue to report the account as a Status Code 93, but report the declining balance.
If accounts are turned over to a Collection Agency and the Collection Agency reports the accounts to the credit bureaus, the guaranty agency should report the accounts as Status DA to delete them. These accounts cannot be reported by both agencies, causing duplication. The FCRA Compliance/Date of First Delinquency should contain
the date of the first delinquency with the original lender that led to the default. The K1 Segment should contain the complete name of the original lender/servicer/secondary market to whom the claim was paid, as well as Creditor
Classification Code 07.
· 62 - Account paid in full/was a collection account.
For Rehabilitated Loans:
Report Account Status Code DA to delete the account.
Note: The claim reported by the original lender will remain on the file until purged according to FCRA guidelines.
For Accounts Sent to DOE (Guaranty Agencies Only):
Report Account Status Code DA to delete the account.
For Accounts with a Balance under Total and Permanent Disability:
Report Account Status Code 62 to indicate the account is paid.
For Accounts with a Balance and Consumer who is Responsible for the Account is Deceased:
Report Account Status Code 62 and ECOA Code X.
For Guaranty Agencies Dissolving or Undergoing Bankruptcy:
Contact the Consumer Data Industry Association (CDIA) to determine the appropriate steps in the reporting process that would be unique to the agency's specific situation.
For Loans that are Forgiven when a School Closes:
Report Account Status Code DA to delete the account.