Legal and Regulatory Announcements and Requirements

National Consumer Assistance Plan

The National Consumer Assistance Plan is an initiative launched by the three nationwide consumer credit reporting companies – Equifax, Experian and TransUnion – to make credit reports more accurate.

Under the plan, which was launched in March, 2015, the three companies have taken a number of steps to improve data accuracy and quality and make it easier for consumers to understand their credit information. The companies implemented the plan over a three-year period with full implementation in March 2018.

Data Reporting Initiatives

Below is a summary of implemented initiatives, impacted furnishers, and the Effective Dates. These data reporting changes must be implemented in advance of the Effective Dates.
Who is Impacted? What is Required? Effective Date
Collection Agencies and Debt Buyers Report the name of the Original Creditor and Creditor Classification Code 6/15/2016
Collection Agencies and Debt Buyers Do not report debt that did not arise from a contract or agreement to pay 6/15/2016
Collection Agencies and Debt Buyers Report a full file monthly 9/1/2016
Collection Agencies and Debt Buyers Do not report Medical Debt collection accounts less than 180 days old 9/15/2017

Collection Agencies and Debt Buyers

Report a delete for accounts that are being paid or were paid in full through insurance

9/15/2017

All Data Furnishers

Report using the newly established minimum reporting requirements for consumer personally identifiable information:

This new minimum standard will apply to accounts reported with a Date Opened after 9/15/2017 in order for the CRAs to accept these records for processing.

Following the Metro 2® format, Furnishers must report:

  • Full name (First Name, Middle Name or Middle Initial (if available), Last Name and Generation Code/ Suffix)
  • Address
  • Full Social Security Number
  • Date of Birth (mmddyyyy)

9/15/2017

 

Reporters of Authorized User Data

Report full Date of Birth for new Authorized Users on all accounts

9/15/2017

 

Enhanced Public Records Standards

Coupled with these initiatives we are working to ensure that the Public Record data we maintain is as accurate and up-to-date as possible.
Last year, Equifax, Experian and TransUnion (the “NCRAs”) announced and implemented enhanced standards for the collection and timely updating of public record data included in consumer credit reports as part of the National Consumer Assistance Plan (“NCAP”).

Upon implementing the NCAP enhanced standards for public records, the NCRAs removed all civil judgments and the majority of tax liens from their consumer credit reporting databases last July.

Since then, our ongoing review and monitoring of tax lien data transmitted by our third party vendor has led TransUnion to decide to cease reporting tax lien data and to remove all remaining tax liens from our consumer credit reporting database in order to ensure compliance with the enhanced standards of the NCAP and to resolve pending litigation. All tax liens will be removed from consumer credit reports the week of April 16, 2018. We are advised that Experian and Equifax have also decided to cease reporting tax lien data and will take similar action in April 2018. Bankruptcy public record data will continue to be reported.

TransUnion's internal analysis of likely impact on our credit reporting database performed prior to the purge in July 2017 revealed the following:

  • Approximately 9% of the population had either a tax lien or a civil judgment reported on their file, which may result in a credit score impact.
  • The impact across eight TransUnion generic scores tested is expected to be modest. Any score shifts are anticipated to range between 2.5% and 6.4% with most scores increasing.
  • There is no loss in the predictive performance of the scores tested since they capture other derogatory-type behavior. We are not conducting any further analysis as we feel that these results would be indicative of the full removal.

See the TransUnion Enhanced Public Record Standards White Paper and the TransUnion Insurance Enhanced Public Record Standards White Paper.

If you have any questions about the NCAP requirements or TransUnion’s implementation of these requirements, please feel free to email us at TUDAS@transunion.com.

Last Updated: 05/04/2017
Last Updated: 08/17/2016
Last Updated: 04/18/2018
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