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#1377430 - 04/20/10 06:42 PM E-Oscar and FACT Act
mbernard Offline
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We use E-Oscar to dispute things on a Credit Report. With the new accuracy, integrity, and direct-dispute provisions, will we not be able to use E-Oscar any more? Or is E-Oscar still considered disputing directly with us, the FI?

Thanks!

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#1377605 - 04/20/10 08:35 PM Re: E-Oscar and FACT Act mbernard
Still Smiling Offline
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I believe you will still use E-Oscar for communicating responses to disputes that come through that source.
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#1380011 - 04/23/10 01:11 AM Re: E-Oscar and FACT Act Still Smiling
jlroberts Offline
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jlroberts
Joined: Sep 2009
Posts: 1,574
Ohio
We currently receive disputes through e-OSCAR and address them through e-OSCAR and receive disputes directly from the borrower. If we find that the borrowers dispute is valid then we correct it using e-OSCAR. This "new" provision does not effect us as we have already been doing what is now required.

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#1380178 - 04/23/10 01:33 PM Re: E-Oscar and FACT Act jlroberts
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
Ditto for us; however, it seems the new provisions are also concerned with info reported where the cust has not yet disputed (accuracy and intregity). The self check provisions are to ensure that info is consistently reported correctly.

A cust may not obtain new credit for years and perhaps would not be aware of any errors on their credit report, if they don't take advantage of the free annual cr rept.
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#1381151 - 04/24/10 01:03 AM Re: E-Oscar and FACT Act ahou
jlroberts Offline
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jlroberts
Joined: Sep 2009
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Ohio
Before we send out our deliquent notices we review them for things like: do they have two loans and both payments got posted to one because they wrote one check or was the payment short because they had a recent payment change.

We also get a monthly report from our core processor that shows what data we sent to the credit agencies. This seems to be the only addition to our procedures:
Appendix E
d) Establishing and implementing appropriate internal controls regarding the accuracy and integrity of information about consumers furnished to consumer reporting agencies, such as by implementing standard procedures and verifying random samples of information provided to consumer reporting agencies.

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#1381487 - 04/26/10 05:29 PM Re: E-Oscar and FACT Act jlroberts
Always In Training Offline
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Where the Green Grass Grows
E-oscar isn't a direct to FI dispute method. It is the credit bureau's way to communicate a dispute to them from the consumer (called an ACDV). I'd had a rush of these lately as the credit repair businesses can now be ignored when disputing directly with the FI.

You CAN use E-Oscar to correct a credit file. That's an AUD. And I think I'll have to filing (and paying for) more of these since the accuracy & integrity stuff is now going to be finalized. Since there are so many little things that can screw up a credit file. (A payoff error, a loan renewal problem, joint borrowers reported when it should only be an individual, a posting error that wasn't known about when the credit file was uploaded to the bureaus.)

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#1383320 - 04/28/10 09:21 PM Re: E-Oscar and FACT Act jlroberts
It's not easy Offline
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Once you get a monthly report from your core processor that shows what data was sent, what's your process from that point on. Is it in an easy format to identify information that is missing, or do you just perform a general review of some data each month?

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#1384031 - 04/29/10 09:42 PM Re: E-Oscar and FACT Act It's not easy
Always In Training Offline
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Where the Green Grass Grows
My CO has done a risk assessment re: what needs to be verified. My core processor runs a data verification to make sure that the data makes "sense". (No ECOA codes of Individual that have co-makers, no paid off loans that show open balances, etc.)

We do a post loan closing review of every loan on the books, so we know at that point whether the credit data profile was built correctly. If it wasn't - and it's already been reported - we do an AUD to fix it for NOW, and then we correct what's on our system that is incorrect (ex: wife isn't being reported and she's obligated too) and then the next time we update we know that it's right. I keep a separate log of credit corrections.(Separate from my credit disputes.)

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#1384736 - 04/30/10 11:20 PM Re: E-Oscar and FACT Act Always In Training
jlroberts Offline
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jlroberts
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Ohio
Our report is in a easy to read format. We can export it to a text file and do a "find" by status code. We can also import into a excel spreadsheet and sort it by status code. We'll take a sample each month from everything that is not coded as an 11 (Account in good standing). Fortunately for us we might be able to look at the account not in good standing becuase we have a very few delinquencies.

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#1384791 - 05/02/10 03:10 PM Re: E-Oscar and FACT Act Always In Training
TheQueen Offline
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Joined: Jun 2006
Posts: 85
CT
Would yo be willing to share your risk assessment, or perhaps some of the risks that were reviewed?

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#1385778 - 05/04/10 07:29 PM Re: E-Oscar and FACT Act TheQueen
lucyc Offline
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lucyc
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I would be interested in the risk assessment as well.

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#1403028 - 06/12/10 03:25 PM Re: E-Oscar and FACT Act Always In Training
complygirl Offline
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Joined: Oct 2004
Posts: 822
midwest
Is a risk assessment specifically required in the new rules somewhere? Also, I read in another bankersonline thread that a log for disputes should be developed. Couldn't we just rely on a report from E-OSCAR of disputes filed rather than creating a new log? Any feedback is appreciated. Thanks.

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#1403057 - 06/13/10 07:25 PM Re: E-Oscar and FACT Act complygirl
jlroberts Offline
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jlroberts
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Posts: 1,574
Ohio
If you have a direct dispute and the dispute is found to be accurate, there would be no record in e-OSCAR for that dispute to be on their report, you would be responding to the consumer directly. We have maintained a log since 2004 and it's really easy to maintain. These are the columns:

Date
Name
Account Number
Dispute type (e-OSCAR, Letter, Verbal)
Response Date
Response (Accurate, Modify, Delete)
Comments (Not same person, 2nd dispute this year, etc..)

Our deposit department also records any Chexsystem disputes on a separate log maintained in their department.

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#1426067 - 08/09/10 06:24 PM Re: E-Oscar and FACT Act TheQueen
Always In Training Offline
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Where the Green Grass Grows
I've PMed about this out the whazoo. It wasn't MY risk assessment. It was my Compliance Officer's. He did it, and we talked about the particulars so that he could tweak the FACT/FCRA manual and policy. He still had in our policy that we submitted via magnetic tape. Which we hadn't done in YEARS.

Sorry I can't share. It's locked up in his computer desktop. I'm pretty sure he got it after a webinar.

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