Just curious...who do you report to your CRA on? Consumer purpose loans only? Do you include loans to individuals for business/investment purpose? Guarantors?
Let me know what your current practice is. Thanks!

It has been a few years now, but consumer loans were reported and each obligor on them would be shown.

We also report on commercial/ag purpose loans (to individuals only) as long as they have regular payments, be it monthly, semi-annually, or annually.

Thanks for the replies. Have a good weekend!

Is there any specific guidance on how a bank should report its loans to the credit bureau? I've reviewed some of the other threads and it appears that it is a bank decision. The question is coming up about reporting guarantors/co-signers (on consumer loans). If the guarantor/co-signor is the one who has the secondary liability, should the loan be reported on their credit bureau? Or would it only be reported if there was problem (i.e. default)? I've never really been clear on this and would appreciate any direction. Thank you.

The only guidance I am aware of is the "please do not withold worthwile information" letter put out by the regulators when they got mad at CapitalOne for not reporting credit limits on their credit cards.

As an institution, we have decided not to report guarantors unless they fail to honor their commitment to step-in in event of default. This is based on the premise that guarantors do not get payment books or coupons and only find out a loan is past due after-the-fact. Therefore, reporting a loan as 30 days delinquent on the guarantor's credit report both does not help the bank and creates an unecessarily adversarial position with the guarantor before we have asked them to cover the debt.

Thank you SavannahOne. I thought I was through with this, but in doing some more review I came across some articles in the BOL InfoVault and would appreciate some clarification. Some of this goes back to the Reg B/Reg AA definitions but I am leaving it in this thread as I'm trying to get back to the credit reporting issue. For Reg B purposes if two people apply together and the intent is for them to be joint applicants, then they will both sign the note document and the "assumption" is that both names will be reported to the credit bureau. However it is possible that one of the applicants may be a co-signer or guarantor. For purposes of Reg AA, if this is the case then the co-signer would receive the appropriate Reg AA co-signer notice. I understand that. However, you indicated you do not report guarantors to the credit bureau. I am making an assumption we are both referring to consumer loans. If a co-applicant can also be a co-signer, wouldn't you report the loan? My head is spinning a little on this and I may be the only one confused but would appreciate any clarification so I can get back on track. Thank you!

For my purpose, commercial or consumer is irrelevant, but I understand you are coming from the consumer angle.

I've always thought the "Notice to Co-Signer" should have been entitled "Notice to Guarantor" to avoid confusion, but that's just me.

Look carefully at the notice and you will see it states "If this debt is ever in default, that fact MAY (emphasis added) become a part of your credit record." "May" means "at our option" and we opt to report it only if the guarantor/co-signer (as opposed to a true joint applicant) does not step-up to the plate when called.

Aside - be careful of "assumptions" when speaking of reporting to the credit bureaus. Joint signers either are, or are not, reported and there should be a code or system setup somewhere that tells you which you are doing.