If the first date of delinquency is > than 7 years, should the bank exclude this information from the file that is sent to the credit reporting agencies? Or if we send it, is it the responsibility of the credit reporting agencies to not include items older than 7 years in the consumer credit reports? I am just trying to understand whose responsibility it is.

Please see FCRA 605(a), which restricts consumer reporting agencies from reporting certain items for greater than seven years. However, you should also set up your system to cease reporting of accounts once they reach the seven year mark, since data furnishers have a responsibility to report accurate information.

The agency that we report to now kicks back a report of those that we reported that in some way don't conform to the appropriate standard. Our core also runs a test of the data prior to submission and gives us a list of those that don't conform to the appropriate standard.

Sometimes, the file error is something like the a coding error like 1 person as sole responsibility and 1 person as joint responsibility. Or, the loan is showing a code that the loan was paid from proceeds of collateral, but also still showing a balance on it. Sometimes, its that there has been no activity in over 7 years and it is still marked to report on our system (thus, still reporting).

I'd see what kind of reports to which you have access.

Thank you both!