Financial institutions that submit credit reporting data to credit bureaus are required to comply with the reporting provisions of the Fair Credit Reporting Act (FCRA). Recently there has been enhanced scrutiny placed on information that is reported to credit reporting agencies. Financial institutions report a minimum of 25 data points on every reported loan and 16 data points on every reported customer, with some loans containing an additional 40 fields. These fields are required to be accurately reported to credit bureaus.
The 2020 CFPB Summer Supervisory Highlights noted that examiners were identifying errors with FCRA programs regarding permissible purpose for pulling credit, inadequate dispute resolution processes, and inaccurate information reported to credit bureaus. According to feedback received from other institutions, regulators have also been reviewing Metro 2 data in recent exams. Depending on the complexity of the financial institution and the severity of errors identified, some institutions have been required to conduct significant corrections to their data and reporting processes or have been cited with level 2 violations. Courts have also found that compliance with the Metro 2 reporting guide can serve as a valid defense for civil litigation stemming from litigants that assert a financial institution reported inaccurate information (e.g. Grossman v. Barclays Bank Delaware, Toliver v. Experian Info. Solutions).
Steve H. Powell & Company offers a variety of FCRA and Metro 2 compliance reviews to help identify and correct potential FCRA violations or reporting errors in Metro 2 data reported to credit agencies. In the past year, reviews have uncovered errors in reporting information specific to loans, loan history, and customer specific data. Frequent errors relative to Metro 2 data include, failure to report accurate transaction histories, failure to report the correct social security number of the borrower(s), errors in reporting charge-off accounts, errors in reporting correct payments, and most commonly, errors in reporting the correct loan types or payment features.
For additional information about our FCRA and Metro 2 compliance review services please contact Steve Shepherd @ firstname.lastname@example.org.