Since you have not reported data before, CBA knows you have historical as well as current borrowers for whom reporting is an important opportunity.
Decide which Loans to Report
CBA has discussed with the credit bureaus that your first Metro2 file can include historical as well as current information on your loan portfolio and borrowers. Subsequent monthly files would include all active loans plus new loans as they are originated.
Please make a portfolio-based decision, and then report on all clients that fit that definition categorically. CBA strongly discourages lenders to make reporting decisions on a loan-by-loan basis.
Some definitions CBA members have used to define the loans they report:
- All active loans from their respective date of origination
- All loans originated as of a certain date:
- a recent date (i.e. since loan document was updated January 07); or
- a historical date from which you have good data
- Specific loan products – you may decide to report a specific loan product and not other, i.e. all loan products you service.
Please know that most Metro2 software is set to report on all co-signers and loan guarantors as well. If you do not want to do this, work with CBA and your software provider to change the settings.
Our FAQs can help you answer additional questions. Have another question we missed? Contact us!
Inform your Borrowers
Per the FTC, the FACT Act amendment to the FCRA related to consumer privacy and protection OBLIGATES data furnishers to inform their clients if they are reporting negative data (i.e. delinquencies, defaults, collections) to a consumer reporting agency (aka credit bureau).
Read more about this and other FTC guidance outlining what information providers need to know.
CBA strongly encourages lenders to inform all of their borrowers and all associated loan guarantors before beginning to report data to a credit bureau.
Here are strategies CBA Member’s are using to inform their clients:
- Send a letter to all Borrowers, Cosigners and Personal guarantors
- Add a clause to loan documents
- Create a credit history release document (may be included in an information release agreement)
View Sample Letters drafted by CBA members to inform their clients.
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