FCRA

Posted By: Bville

FCRA - 03/02/04 03:08 PM

I have been asked to research and try to clarify what is meant by "complete and accurate" reporting as it relates to the FCRA. I realize that banks are not required to report at all but,

1) If we report that John has a past due note to us are we required to also report the same information on all coborrowers and cosigners on the same note? Or,

2) If we report that John is past due on one note are we obligated to report every note that John is associated with as borrower, coborrower, or cosigner?

I can't find anything that explains "complete and accurate" but there is discussion going on here as to when we may or may not be required to report on cosigners. I've been elected to find the answer. Have any of the regulators written any interpertations of this act?
Posted By: Andy_Z

Re: FCRA - 03/02/04 03:13 PM

I am thinking out loud, but 1) You are reporting that a loan is delinquent and then who is on the loan. So in my mind all obligors on the loan are delinquent and should be shown as such.

2) If you are reporting those loan types/products, why not. Certainly you may be reporting consumer, but not commercial loans.