Understand Reporting Fundamentals
Consumer data reporting is regulated by the Fair Credit Reporting Act (FCRA) as well as other federal and state legislation. The FCRA establishes the responsibilities for submitting data to a consumer reporting agency database (i.e. credit bureau) as well as verifying consumer disputes.
To meet their obligations under the FCRA, the four major credit bureaus came together and defined unified formats for receiving data from furnishers. As such, the major credit bureaus will only accept consumer data in a Metro2 format and only accept verification of consumer disputes through e-Oscar .
Get Organizational Buy-In
CBA believes that community lenders have both a right and a responsibility to report. We believe it is integral to the organizational mission of community lenders to help their clients become financially self-sufficient.
CBA is pleased to bring you this opportunity and is committed to ensuring you are successful. It is important that each community lender is also committed for the long-term.
Please take the time to educate all stakeholders in your organization whose commitment and time are needed for you to be a successful Reporter including:
- Lending staff
- Management team
- Board of Directors
- Loan committee
Consult your Lawyer
CBA strongly encourages you to talk with your legal counsel and other advisors about the specific implications of reporting for your organization.
CBA members are asking themselves and their lawyers:
- Does my organization understand and is it comfortable with the responsibilities of a data furnisher as described in the FCRA and other applicable laws?
- Is our organization’s current professional liability, indemnity and other insurance relevant and sufficient to cover activities related to reporting consumer data?
- Are our loan applications, loan agreements and other applicable information and materials compatible with sharing borrower data with credit reporting agencies?
