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#2120044 - 03/01/17 04:58 PM Not reporting current payments?
purllow182 Offline
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purllow182
Joined: Apr 2014
Posts: 69
Hello - i was wondering if anyone out there does NOT furnish mortgage payment history to the credit bureaus (unless delinquent)? I'm being asked if we could NOT report the payment history until we have 12 months of it - only on good accounts. I have no idea on the WHY right now.

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#2120293 - 03/02/17 07:24 PM Re: Not reporting current payments? purllow182
Reg Warrior Offline
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Joined: Jan 2017
Posts: 214
Why would you not report a customers payment history? If the customer is paying on time, the reporting of the payment history is beneficial to your customer. By not reporting, the customer's credit report would be inaccurate if another lender is looking at their credit history. Look at 1022.42 and Appendix E of 1022 (Interagency Guidance)

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#2120298 - 03/02/17 07:33 PM Re: Not reporting current payments? purllow182
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
And I believe if you report to the CRAs you report everything. You can't pick and choose what you do and/or don't want to report.
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#2120303 - 03/02/17 07:53 PM Re: Not reporting current payments? purllow182
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
First, read your contract with the credit bureau. Second, consider any disparate impact implications.
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#2120378 - 03/03/17 02:13 PM Re: Not reporting current payments? purllow182
Beachbum, CRCM Offline
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Joined: Dec 2006
Posts: 499
Knee Deep in Regs
Is this a new trend? I have been asked whether we have the option to report on consumer credit for a new loan product. Lending would like to use the feature as a selling point.
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#2120391 - 03/03/17 02:34 PM Re: Not reporting current payments? purllow182
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,363
Galveston, TX
Reporting is optional, but if you read your credit bureau contract, it is usually all or none for any specific class of consumer credit. You can't pick and choose which individual loans you report. Credit reporting is going to be a very hot topic. Read the new CFPB report that came out yesterday:

http://files.consumerfinance.gov/f/docum...ial-Edition.pdf
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#2120427 - 03/03/17 03:48 PM Re: Not reporting current payments? purllow182
purllow182 Offline
Member
purllow182
Joined: Apr 2014
Posts: 69
Thank you all. I did not agree with the thought of not reporting the on time payments. We will not be implementing that. I read FCRA front to back and came up with the same rlcarey - reporting is optional; however, i did not realize to check the credit bureau contract. I dont even know who would have that within our large institution. But good to know there's still additional places to look. THANK YOU!!!!!!!

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