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Question & Answer
Question: We have been reporting foreclosures and write-offs on our borrowers. If we begin to also report whenever a customer is 60 or 90 days late, do we have to give any special notices to the consumer? Would this make us a consumer reporting agency subject to the FCRA?
Answer: No. As long as you report your own experience with the consumer, you are not a consumer reporter. FCRA defines a consumer reporter as one who reports on the experience of others with a given consumer. Since you are reporting your own experience, this does not make you a consumer reporter. The nature or extent of information you report does not change the status. You can report all activity, only delinquencies, or only collections. The type of information you report is up to you.
Basically, when you report your own experience with the consumer, you are reporting fact. Of course, you should be careful to report only accurate information. The new FCRA imposes stricter standards for investigation and verification of information reported when a consumer alleges an error.
Copyright © 1998 Compliance Action. Originally appeared in Compliance Action, Vol. 3, No. 1, 1/98
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