Debt Buyers & Collections Reporting Guidelines & FAQ

When reporting returned checks there are four reporting guidelines:

• Date Opened should contain the date of the check.
• Highest Credit or Original Loan Amount should contain the original amount of the check, excluding fees and interest.
• The Original Creditor Name (Outside Agencies tab in M2R program) the name of the payee/company to which the check was written.
• Report the Creditor Classification (Outside Agencies tab in M2R program) to identify the original creditor's type of business. Note: that code 02 (Medical/Health Care) is used to identify an account as a medical collection debt in accordance with FCRA section 623.
• Date of First Delinquency should contain the date the check was returned for nonsufficient funds. If this date is not available, report the date of the check.

Use ECOA code X to report deceased borrowers (Customer and Joint Customer tabs in M2R program)

• When reporting ECOA Code X, it should only be used for the deceased consumer. Do not use it for other consumers associated with the account.
• If there is a single borrower on the account and the borrower is reported as deceased, stop reporting the account after submitting ECOA Code X.
• If an account has a trustee or estate name do not report
• In instances where multiple borrowers are associated with an account and one borrower has been reported as deceased, continue to report the account. Cease reporting the information pertaining to the deceased borrower following submission of the ECOA Code X for that borrower.
• If there are multiple borrowers linked to an account and the primary borrower is deceased, a different associated borrower should be assigned as the primary party in future reporting.

Important: ECOA Code X should not be reported until a legally-sufficient death notice, such as a death certificate, has been received. Data furnishers are advised to consult their internal Legal counsel or Compliance department for clarification on what qualifies as a legally-sufficient death notice. Reporting a consumer as deceased adds a status to the credit report. If another individual attempts to use the identity of a deceased consumer, the "deceased" information will appear on the credit report, which may help prevent fraudulent activity.

Note: Refer to Metro 2® General Reporting Guidelines for Debt Buyers & Collection Agencies for guidance on reporting deceased borrowers.

Apply these reporting guidelines when it is confirmed that an account has been impacted by a natural or declared disaster (such as hurricane, wildfire, or flood), according to internal policies and procedures.

Notes: Reporting an account with Special Comment AW is optional and can be used temporarily for narrative purposes. Reporting an account as affected by a natural or declared disaster should not be used as a substitute for temporary relief payment plan reporting. For further details on reporting accounts with temporarily postponed payments, refer to FAQ 43 (What are the available options for reporting an account that has regular payments temporarily postponed?).

• Open Accounts and Closed Accounts with Balances Owing with account status codes 11, 71, 78, 80, 82, 83, or 84 should be reported using the applicable Account Status code as determined by the credit grantor. Include Special Comment AW for accounts affected by natural or declared disasters.
• Derogatory Accounts -- Includes codes 88 (Government Claim), 89 (Deed in Lieu), 93 (Collection), 94 (Foreclosure Completed), 95 (Voluntary Surrender), 96 (Repossession), and 97 (Charge-off). Report these statuses with the addition of Special Comment AW (Affected by disaster).
• Debt Buyers and Collection Agencies -- For accounts with Status Code 93 (Collection), add Special Comment AW (Affected by natural or declared disaster). For accounts that are sold to another company or returned to the original creditor, report Account Status Code DA which will delete the account.