Are we required to report partial payments to ChexSystems for charged off accounts (reducing the amount owed) or is it okay to only make changes to the account status on Chex when the account is paid in full? We will update information if we receive a dispute (we average maybe 5 a year) but have never sent updated information each time a payment had been made. Although this has been our procedure for years, one of our examiners is questioning it this year. Any direction I can get would be great - thanks!

What does your agreement with ChexSystems say and what are the reporting parameters for previously charged off accounts?

Sadly that's part of my problem - the business unit hasn't been able to provide me with a current agreement. We have some very old procedures that state the parameters of our reporting (only if >$100 not including fees/charges) and if we report as charged off and then recover the full amount, we do send an update to show it was paid in full. So we update for full payment, and in response to a dispute, but not on the small, incremental payments we might receive from time to time.

Well, it has been a long-long time - but that actually sounds correct from the recesses of my mind. You probably need to get a hold of your ChexSystems rep and get some new source material to show your regulator if they push this.

We've had the same long term employee perform this task for the last 10 or 15 years I believe, so maybe it's time to dust it off a bit. It's just never been that high on our list. Thanks for the advice!