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#2281145 - 02/15/23 07:14 PM FCRA - DQ & CO low neg balance
KateM Offline
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Joined: Jun 2018
Posts: 10
We are looking at implementing a dollar amount in which we will not report negative information to credit reporting agencies. For example, an account we will be charging off with a negative balance of $20 will not be reported, or if a member misses their payment by $5, we will advance the due date and not report them past due. My concern is with FCRA and fair/accurate reporting.

Does anyone else have this in place and would be willing to share how you approach this?

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#2281151 - 02/15/23 08:01 PM Re: FCRA - DQ & CO low neg balance KateM
rlcarey Offline
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Joined: Jul 2001
Posts: 81,346
Galveston, TX
Since you say member, I assume you are a credit union. The NCUA never adopted the FFIEC Uniform Retail Credit Classification and Account Management Policy as far as I am aware, so I don't know their stance on some of this.

That document indicates that a payment equivalent to 90 percent or more of the contractual payment may be considered a full payment in computing past due status. If the lender considers what they receive as a full payment and updates the due date in their loan processing system, then the borrower is not late. As such, there is nothing to report.

As far as not reporting de-minimus charge off amounts, I do not think you have any issues.
The opinions expressed here should not be construed to be those of my employer:

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