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#2257884 - 08/09/21 06:04 PM 30 days past due
Likes to Comply Offline
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In the mountains
I'll try my best to word this correctly...and sorry if it seems like a stupid question...

For credit bureau reporting/eOSCAR dispute resolution, if a payment is made on the 30th day past the due date, it this considered 30 days delinquent? Or is it only 30 days delinquent if a payment had not been made on the 30th day past the due date, but rather paid on the 31st day or more?

For example, payment is due 8.1.2021 but the customer makes the payment on 8.31.2021. 8.2.2021 being 1 day past due, 8.31.2021 being the 30th day. Payment is made on the 30th day. Is this considered 30 days past due?

Or was the account 29 days past due because the payment was made on the 30th day?

Thanks in advance!
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#2257902 - 08/09/21 07:24 PM Re: 30 days past due Likes to Comply
rlcarey Offline
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Galveston, TX
The “clock” for a 30-day delinquency starts 30 days after the due date, as opposed to the billing date. It was 30 days past due when they made their payment.
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#2257906 - 08/09/21 07:38 PM Re: 30 days past due Likes to Comply
MainStreeter Offline
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Joined: Jun 2014
Posts: 41
If they hit the 30 day mark after the due date, they are 30 days delinquent. They can still make a payment on day 30, that will just prevent them from being 31 days past due.
We found we needed to go back to our core system to ensure our interpretation from a credit reporting standpoint matched what was being done on the system so we were confident in how we were doing things.

In your example, if your customer is making their payment on 8/31 they would be considered 30 days delinquent.

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#2257909 - 08/09/21 07:48 PM Re: 30 days past due Likes to Comply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,597
Galveston, TX
Credit Bureau reporting may be different than your call report, as you have an option, For the call report, a payment on 31st may not trigger the loan as being past due.

Closed-end installment loans, amortizing loans secured by real estate, and any other loans and lease financing receivables with payments scheduled monthly are to be reported as past due when the borrower is in arrears two or more monthly payments. (At a bank's option, loans and leases with payments scheduled monthly may be reported as past due when one scheduled payment is due and unpaid for 30 days or more.) Other multipayment obligations with payments scheduled other than monthly are to be reported as past due when one scheduled payment is due and unpaid for 30 days or more.
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#2257916 - 08/09/21 07:58 PM Re: 30 days past due Likes to Comply
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As Likes to Comply was asking about credit bureau reporting, my response was in reference to that, not Call Report.

Likes to Comply- the Payment History Profile in your Metro 2 guide (p 4-12) might shed a little more light on this. And FAQ 10.

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#2257918 - 08/09/21 08:05 PM Re: 30 days past due Likes to Comply
rlcarey Offline
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rlcarey
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Posts: 78,597
Galveston, TX
Nicki - I was not referring to your previous answer which said the same thing as my previous answer - I was just pointing out that there can be differences - so it was just a warning not to let that confuse the FCRA reporting situation as depending on who they are talking to in IT, they may be thinking of different rules.
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#2258054 - 08/11/21 03:53 PM Re: 30 days past due Likes to Comply
Likes to Comply Offline
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Joined: Nov 2008
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In the mountains
Another scenario...

If a payment is due 7.5.2021 and the payment is made on 8.4.2021 then it would be 30 days past due. If the credit bureau reporting file is created as of end of day on 8.4.2021, then the Account Status will report as 11 current account because the payment has been made. Then next month when the Payment History is reported for the month of August it will NOT report 1 30-59 days past due, even though in August the July payment was in fact past due at one point. The vendor said this is because in order for Payment History to report a month as past due, the previous months credit bureau reporting file must have reported the Account Status as being past due.

So it is a matter of dates - if a past due payment is made before the file is sent to the credit bureau, it will report as current.

Fast forward to a year from now and a dispute processor works an eOSCAR dispute. When reviewing the Payment History on the eOSCAR dispute the processor will see for August 2021 the reporting is 0 0 payments past due. When they compare this information with the loan history and see the July payment was 30 days past due in August, they will update the reporting for August 2021 to report as 1 30-59 days past due.

Because it is a matter of dates - when the payment was made and when the credit reporting filing was made - we will sometimes have past dues for Payment History on the credit report not reporting the same as the past due history in our Core system.

Are we wrong to update the Payment History on the dispute to reflect what is in the loan history on the account? or should we be keeping it the same as what was originally reported during the monthly file sent to the CRA?
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#2258057 - 08/11/21 04:41 PM Re: 30 days past due Likes to Comply
MainStreeter Offline
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My view, based on the Metro 2 guide and FCRA, if the consumer was 30 days we have a duty and responsibility to report that accurately- not give them an extra 4-13 days (or whatever timeframe until your upload) because of the timing of when the data gets sent out to the CRAs.

Perhaps I'm barking up the wrong tree, but I don't think the 'system' people have an understanding of credit reporting requirements or our data furnisher responsibilities, but I would lean towards pushing back on that side to get it right in the first place, which seems likely an uphill battle.

In your dispute example, you have a duty to report accurate information, which would be that the account was 30 days past due, and likely what your system is going to say too as you document your dispute response. That's certainly going to cause consumer harm being updated a year(s) down the road from when it actually occurred, and create some questions and headaches, making it all the more reason to push back on the system side to get it right in the first place and leave it at 30 days once it hits.

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