Here are a few areas to tackle as part of your journey to data furnishing accuracy and control.
The CFPB expects that you, as furnishers, have written documentation to explain how you’ve populated various Metro 2® fields from your systems of record. Our data mapping and conversion documentation approach addresses that expectation and provides a useful foundation for managing accuracy of Metro 2® file production.
Three Things You Should Be Doing for Accuracy and Control
- Conduct a deep review of the Metro 2® furnishing file that is submitted to the Nationwide Credit Reporting Agencies (NCRAs)
- Develop a detailed Metro 2® data mapping and conversion document to examine system of record code that produces the Metro 2® file
- Review upstream operational processes to identify trigger events and data that impact contents of the Metro 2® file
As part of #1 and #2 above, we have uncovered four important areas that would likely be flagged by regulators. While these steps can be time-consuming and highly detailed, what they reveal can help you ensure data accuracy prior to submission to NCRAs.
Do You Understand How Your Metro 2® File Is Created?
Do you have clear knowledge—or documentation—of how your systems of record map to your Metro 2® files prior to sending them to NCRAs, including those generated by your third-party processors? If you don’t, you can wind up with inaccurate furnishing, an increase in complaints and disputes, and ultimately regulators knocking on your door.
Recording how your Metro 2® file is created with a detailed, audit-ready data mapping and conversion document is a key component to meeting the evolving regulatory expectations for consumer reporting accuracy.
Top 4 Areas You Can Fix to Improve Accuracy
The following examples are typical opportunities for system and/or operational enhancements that you can make to ensure the data going to the NCRAs is accurate.
1. System Limitations for Compliant Reporting
- Inability to generate certain Metro 2® file segments
- Limited capture / storage of information (6 months vs. 7 years)
- Reporting of delinquent accounts for greater than 7 years
- Consolidation of data elements into one field requiring manual parsing (Surname, First Name, Middle Name)
- Missing logic required to report Metro 2® fields (e.g., reporting spaces instead of the Generation Code)
- Not flagging required Metro 2® fields as mandatory (e.g., Social Security Number)
2. Logic Potentially Results in Inaccurate Reporting
- Inaccurately counting days past due for account status assignment
- Lacking logic to report “Last Good Payment” date after a payment reversal due to NSF
- Mass overwriting of dates (e.g., Date of Account Information)
- Missing best practice controls (e.g., if account is current and in bankruptcy, Date of First Delinquency should not be blank)
- Reporting the most recent Actual Payment Amount value rather than totaling all payments receiving during the reporting period
3. Inconsistency Among Correlated Fields
- Failure to update all relevant downstream data elements when manually overriding Metro 2® fields (e.g., Account Status)
- Inaccurate or incomplete reporting when an account is closed (e.g., Date Closed is not populated, Current Balance is greater than $0)
- Inconsistent date progression (e.g., Date of Account Information is a date later than the timestamp of the file)
- Inappropriate representation of Metro 2® fields related to Account Status (e.g., Payment Rating is not populated when required, Payment History profile does not reflect the prior month’s Account Status)
4. Missing and Inaccurate Field Values
- Invalid assignment of Portfolio Type and/or Account Type values
- Inaccurate values furnished for Special Comment Code, ECOA, Consumer Information Indicator, and Compliance Condition Code fields
Ensure Data Accuracy Now and into the Future
We’ve shared the typical issues that can drive disputes and draw regulatory scrutiny. If you want to delve into how your data maps to Metro 2®, we can help you.
We offer a program with a series of pre- and post- transmission activities that validate data accuracy when furnishing data to consumer reporting agencies. Our program, along with a system of continued control monitoring implemented with furnishers of all sizes and types, has contributed to our 95% client re-engagement rate.
Your Metro 2® files likely need a detailed check for accuracy. Our related company, Bridgeforce Data Solutions (BDS), has experience working with over 40 different clients to improve their furnishing accuracy and minimize consumer harm. They’ve seen results that have reduced disputes volumes by up to 30%.
Whether using the BDS industry-leading Data Quality Scanner solution or undergoing a detailed Metro 2® data mapping exercise, we can help position you for success in your consumer data reporting and disputes management journey.
Contact us today.