Student Loan Reporting Guidelines & FAQ

While all applicable fields within the Metro 2® Format should be reported, these guidelines provide specific values that apply to the options available when a lender (creditor) agrees to temporarily postpone regular payments on an account. Based on the type of temporary relief payment plan, the consumer may be making reduced payments, interest-only payments or no payments. "Temporary" for this Metro 2® credit reporting purpose is defined as a short-term schedule change to regular monthly payments that has an identified end date and is not permanent. When the temporary relief payment plan concludes, for subsequent reporting, the standard guidelines described within the Field Definitions module should be followed for all Metro 2® fields.

Your business policies/procedures as identified by your legal/compliance department should:

• Determine which reporting option is most applicable to follow when a consumer enters into a temporary relief payment plan
• Identify the duration of how long applicable temporary relief payment plan options will last in compliance with federal and state guidance pertaining to a consumer's willingness to repay the obligation
• Include provisions for when a consumer does not fulfill the required obligation(s) of the temporary relief payment plan (including working out a payment plan) after being given an opportunity to comply. These provisions should also clearly state when standard delinquency reporting/progression, including Date of First Delinquency calculations as described in Exhibit 9, can resume for the account.

Important Note: Do not update the entries in the Payment History Profile for the month's representative of the temporary relief payment plan, after the plan period has ended. If the account becomes paid while in the payment plan, refer to FAQ 39 for standard reporting guidance for paid in full accounts.

Option 1 -- Report the account in a Payment Holiday/Skip-a-Pay

Report the following Base Segment fields as specified:

• Terms Frequency = frequency for payments due (Not value D for deferred)
• Scheduled Monthly Payment Amount = new payment due (If no payments are due during this time period, zero fill.)
• Account Status = appropriate code that specifies the status of the account for each month the account is in the Payment Holiday/Skip-a-Pay (e.g., Current, 30 days delinquent, 60 days delinquent) (If no payments are due during this time period, report Account Status 11.)
• Payment History Profile = appropriate code that specifies the previous month's Account Status for each month the account is in the Payment Holiday/Skip-a-Pay time period, plus prior history. (Increment the Payment History Profile with value D if no payments are due during this time period.)

Important Note: Additionally, if the consumer was delinquent going into the Payment Holiday/Skip-a-Pay, the two fields below must be considered when the consumer comes out of this time period and begins repayment:

• Account Status Code = appropriate code that specifies the status of the account when the account comes out of the Payment Holiday/Skip-a-Pay
• Date of First Delinquency = if the Account Status is delinquent, the original date that led to the Account Status being reported prior to the Payment Holiday/Skip-a-Pay

Option 2 -- Report the account as Deferred
Refer to FAQ 44 for complete reporting guidance for Deferred Accounts.

Option 3 -- Report the account in Forbearance
Refer to FAQ 45 for complete reporting guidance for accounts in Forbearance.

Report the following Base Segment fields as specified:

• Terms Duration = blank
• Terms Frequency = D (Deferred)
• Highest Credit or Original Loan Amount = the total amount borrowed, excluding interest
• Scheduled Monthly Payment Amount = zero
• Account Status Code = 11 (Current account)
• Payment History Profile = Use Character B to indicate accounts which have never been in repayment. Use Character D to indicate accounts that were previously in repayment but are now deferred. Note: When an account goes into deferment, do not change the previously-reported account history in the Payment History Profile.
• Current Balance = outstanding balance amount
• Amount Past Due = zero

In the K4 Segment, report the Specialized Payment Indicator 02 for Deferred Payment. Also, report the Deferred Payment Start Date as the date the first payment will be due. If the deferred payment start date is not known, do not report the K4 Segment.

Important Notes: When the account goes into repayment, stop reporting the K4 Segment and begin reporting monthly payment information. Report valid values as per the repayment agreement in the following fields:

• Terms Duration
• Terms Frequency (other than D)
• Scheduled Monthly Payment Amount

Additionally, if the consumer was delinquent going into the deferment period, the two fields below must be considered when the consumer comes out of deferment and begins repayment.

• Account Status Code = appropriate code that specifies the status of the account when the account comes out of deferment
• Date of First Delinquency = if the Account Status is delinquent, the original date that led to the Account Status being reported prior to deferment

Forbearance is a period of time during repayment in which a borrower is permitted to temporarily postpone making regular monthly payments. The debt is not forgiven, but regular payments are suspended until a later time. A forbearance agreement is most commonly applied to mortgages and student loans. However, forbearance is applicable to any type of loan. As an example, forbearance may be granted if a borrower is experiencing temporary financial difficulty. The consumer may be making reduced payments, interest-only payments or no payments.

If the account is in forbearance, report:

• Terms Duration = terms of the loan, which can be changed if the terms of the loan are contractually extended (If no payments are due during the forbearance period, blank fill.)
• Terms Frequency = frequency for payments due (If no payments are due during the forbearance period, report code D for deferred.)
• Scheduled Monthly Payment Amount = new payment due (If no payments are due during the forbearance period, zero fill.)
• Account Status = appropriate code that specifies the status of the account for each month the account is in forbearance (e.g., Current, 30 days delinquent, 60 days delinquent) (If no payments are due during the forbearance period, report Account Status 11.)
• Payment History Profile = appropriate code that specifies the previous month's Account Status for each month the account is in forbearance, plus prior history. (Increment the Payment History Profile with value D if no payments are due during the forbearance period.)
• Special Comment Code = CP (Account in forbearance)
• Current Balance = outstanding balance amount, reflecting any payments made
• Amount Past Due = total amount that is 30 days or more past the due date, if the account is delinquent during the forbearance period
• Specialized Payment Indicator = 02 and Deferred Payment Start Date when payments are deferred during the forbearance period

Important Note: Additionally, if the consumer was delinquent going into the forbearance period and no payments were required during forbearance, the two fields below must be considered when the consumer comes out of forbearance and begins repayment.

• Account Status Code = appropriate code that specifies the status of the account when the account comes out of forbearance
• Date of First Delinquency = if the Account Status is delinquent, the original date that led to the Account Status being reported, prior to forbearance.

There are two options for reporting accounts that are being transferred internally or to a servicer:

Option 1: This option is preferred if account history can be verified by the new department or servicer:

The new department or servicer should report the L1 Segment to change the Identification Number(s) and/or the Consumer Account Numbers. Use of the L1 Segment allows the consumer reporting agencies to retain all prior account history.

Notes: For full L1 Segment reporting details, refer to the L1 Segment field description in the Field Definitions module. In order to report the L1 Segment, the new department or servicer must have the originally reported Identification Number(s) and/or the originally reported Consumer Account Numbers. Do not report the transferred Special Comment (AT or O) when the L1 Segment is used to change the Identification Number(s) and/or the Consumer Account Numbers.

Option 2:

This option results in two tradelines on a consumer's file: the first as transferred and the second for the ongoing account. The original department or servicer should report specific fields for the transferred account, and the new department or servicer should report the ongoing account with appropriate history indicators.

Prior to reporting accounts that have been sold to another company, it is imperative that the seller and purchaser work together with the data representatives at the consumer reporting agencies to discuss the various options for reporting and to facilitate a smooth transition. In addition, refer to Exhibit 15 -- Data Conversion Checklist, which helps data furnishers focus on the critical steps and questions that must be answered prior to reporting the purchased accounts.

SELLER: If the company that purchased the accounts is converting the account history to their system and will report the prior history, the seller should not report the accounts as sold. Discontinue reporting the accounts. After the final reporting of the account by the seller, reporting by the purchaser should begin in the following month's reporting period.

PURCHASER: When the seller's account history is being converted to the purchaser's system and the account history can be verified, report specific Base Segment, K2 Segment and L1 Segment fields to ensure proper account conversion and history retention.

For this situation, the seller will report the accounts as sold and the purchaser will report the accounts from the point of purchase going forward. Prior to reporting, it is imperative that the seller and purchaser work together with the data representatives at the consumer reporting agencies to facilitate a smooth transition. In addition, refer to Exhibit 15 -- Data Conversion Checklist, which helps data furnishers focus on the critical steps and questions that must be answered prior to reporting the purchased accounts.

SELLER:

If the company that purchased the accounts will not report the prior history, do not report the L1 Segment. The seller must report the accounts as sold to retain the account history and reflect the final disposition of the account. Report specific fields including Special Comment AH (Purchased by another company) and discontinue reporting after the sale date.

PURCHASER:

If the seller reported the accounts as "purchased by another company", report the accounts from the purchase date forward with appropriate indicators showing the account was purchased. Do not report payment history that occurred with the seller.