Data Furnisher Strategies for Accuracy and Integrity

Explore strategies to maintain data furnishing accuracy and integrity, which will ensure best-in-class data furnishing.

Once you figure out what it takes to become a best-in-class data furnisher and implement all the necessary processes and controls to achieve that status, shift your focus to maintenance. Watch this webinar for tips to get to best-in-class status.

Apply these useful tactics used by best-in-class furnishers to maintain accuracy and integrity of furnished data:

• Keep up-to-date data mapping and conversion documentation.
• Implement appropriate controls and risk indicators to measure performance.
• Document policies and procedures for every task performed.
• Create process maps for any process being done by the furnishing team.
• Establish a governance structure to monitor third-party vendors.

Best-in-Class Tactics to Maintain Data Furnishing Accuracy and Integrity

Update Data Mapping and Conversion Documentation to Quickly Identify Gaps

An essential tool is a Data Mapping and Conversion document. It describes field-to-field generation of the Metro 2^® file from your system(s) of record, detailing how data within fields are derived. Yet, financial organizations assume they accurately furnish information, only for customers to discover multiple gaps and discrepancies.

After developing your Data Mapping and Conversion document, remember the following points:

1. Annual Data Mapping and Conversion Document Review

• Review the Credit Reporting Resource Guide^® (CRRG^®) upon release from CDIA^®.
• Identify and socialize necessary changes due to revisions in the CRRG^®.
• Open tickets to perform process or system enhancements to accommodate changes.

2. Data Mapping and Conversion Reconciliation

• After system or process enhancements, promptly reconcile the Data Mapping and Conversion document.
• Verify that changes have not compromised data integrity.
• Stay informed and regularly engage with your organization’s change management routines to be aware of all internal changes, both systemic and operational.

3. Monitor Revision History

• Keep track of all revisions to trace changes back to specific initiatives.

Use Appropriate Furnishing Controls to Maintain Data Furnishing Accuracy

Best-in-class furnishers emphasize the importance of implementing appropriate data furnishing controls. Put controls and Key Risk Indicators (KRIs) in place to measure the performance of the data being reported in your Metro 2^® file.

Consider using tools such as Bridgeforce Data Solutions’ Data Quality Scanner^® for quality assurance. This tool analyzes your Metro 2^® file before and after furnishing, identifying illogical reporting values, and using various metrics to build KRIs. The tool verifies that risk thresholds are maintained and routinely tests critical fields after implementing system enhancements to ensure accuracy and integrity of your Metro 2^® file.

Policies and Procedures: Documenting all Tasks

Effective documentation, especially through clear policies and procedures, is universally acknowledged as essential. In fact, the CFPB’s Part 1022 of Appendix E of Regulation V explicitly outlines the need for reasonable written policies and procedures related to data furnishing.

A best-in-class furnisher always stresses the importance of documenting every task, outlining procedures and policies for each, and verifying adherence to the guidelines. Without approved standard documentation and evidence, you cannot demonstrate consistent and accurate task completion.

Once you document and implement your policies and procedures, consider the following actions:

1. Annual Review: Review all policies and procedures to ensure alignment between documented actions and executed tasks.
2. Timely Updates: Don’t wait for annual reviews to incorporate process or control changes. Instead, promptly document and submit updates through your organization’s change control process.
3. Revision History: Maintain a revision history section in all policies and procedures, including:

• Indication if it’s new or part of an annual review.
• Date of completion and approval for policy and/or procedure reviews.
• Details of who reviewed and approved changes.
• Documentation of material changes made.

Develop Process Maps for Data Furnishing

Just as policies and procedures are important, process maps play an equally vital role. When executed by the furnishing team, any process should be accompanied by a well-structured process map. Here’s why:

• Turn-by-Turn View: Process maps provide clear visual representations of how each process and control is completed. Also, they guide furnishers through steps ensuring consistency.
• Identifying Control Points: Process maps help identify critical control points, such as system-to-system updates or hand-offs to other departments. These controls safeguard the accuracy and integrity of furnished information.
• Annual Review Integration: Including process maps in your organization’s control change process for annual reviews ensures consistency across the organization.
• Timely Updates: If processes change between annual reviews, you can promptly update your process maps for up-to-date documentation. Then, submit these changes through the document control change management workflow.

Process mapping helps prevent unnecessary fire drills and ensures you are always prepared for internal compliance, audits, or regulator visits.

Take Responsibility for Contracted Servicers and Collectors with Third-Party Vendor Management Governance

If your organization retained a third-party vendor for servicing or collections, you share the responsibility for the accuracy and integrity of the credit reporting data they furnish.

So, you must establish a governance structure like the one outlined below, which is what best-in-class furnishers use.

1. Quality Reviews: Regularly review results to monitor accuracy of furnished data.

2. Monitor Controls:

• Track and oversee controls implemented by the vendor.
• Establish a formal process for approving and reviewing action plans in case of control breaches.

3. Policy Reviews:

• Actively participate in annual policy and procedure reviews.
• Challenge the vendor if changes are not promptly documented.

4. Stay Informed:

• Ensure you receive copies of correspondence from credit reporting agencies.
• Monitor metrics from the CRAs including stats, rejections and illogical feedback.
• Confirm volume thresholds align with your organization’s risk appetite and contractual agreements.

Data Furnishing Accuracy and Integrity: Final Steps to Become Best-in-Class

In addition to the items listed above, stay updated on regulatory changes, and hold routine meetings with key stakeholders and furnishing and disputes teams. Ensure that they have the most recent news and information available to guarantee your organization’s success in being a best-in-class furnisher.

For 24 years, Bridgeforce has elevated organizations to a best-in-class furnisher status. Get a closer look at what you need to become best-in-class with our on-demand webinar series. Use these as steppingstones for organizational excellence. Bridgeforce provides the manpower, technical expertise, and a forward-thinking approach to eliminate the uncertainty from data furnishing. Reach out to learn more and get started with a trusted advisor.

[Editor’s note: this article was written by Dianna Cooper, former Senior Program Manager at Bridgeforce]