CRA’s Implement Significant Reporting Changes September 2017

Equifax, Trans Union, and Experian, the three largest consumer credit reporting agencies (CRA’s) entered into an agreement with multiple states attorneys general and the federal government to implement more “consumer friendly” policies. September 15, 2017 marks the end of that three year plan and the final implementation is being but into place across the country.  This program, labeled the National Consumer Assistance Plan, (http://www.nationalconsumerassistanceplan.com/) has several components and goals to make credit reporting and credit reports more accurate and better for all consumers.  There are three major items going into effect in 2017, which we will summarize in this article.  Full details can be found at the NCAP website link above. 1). Metro II Data Format requirement for all data submissions, and a full data file each month from collection agencies. Southern has been complying with both of these items for quite some time and this date will have no effect on our clients, other than we must have EITHER a full date of birth OR social security number to report a debt.  Southern’s policy has been for a full social for over two years, we have been using the Metro II format for over eight years, and we have been supplying a full data file since early 2017. 2). Medical debt must be 180 days past the date of delinquency before it can be put on a consumer’s credit report.  This impacts ALL types of medical debt; hospital, clinic, dental, chiropractic, physical therapy, ALL!  The date of delinquency is calculated by each office’s policy on when an account has gone into default.  Southern has been gathering this information from our clients for many years, so implementing the date of delinquency will not impact our current day-to-day operations or our clients data submissions.  However, the debt must now be 180 days older than the date of delinquency to place on a consumer’s report.  Most of our clients have a date of delinquency between 60 and 120 days from the date of last charge, so for an office with a 90 day delinquency policy the debt will be at least 270 days from the last date of service before we can place it on a consumer credit report. 3). Finally, you may have read in the national news that the CRA’s will no longer be placing most civil judgment data onto credit reports effective this year.  They estimate about 90% of all civil judgments will be removed from consumer credit reports because they lack the full DOB or SS# now required to properly identify and report credit data.

 

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