insideARM has learned that the three major credit bureaus — Equifax, Experian, and TransUnion — have distributed this document detailing new Furnisher Data Reporting and Process Requirement Changes.

Some of the changes are effective as soon as June 15, 2016 while others take effect over a year from now, September 15, 2017. However, the memo urges furnishers to implement the changes in advance of these dates.

The purpose of the changes is to provide consumers more transparency when interacting with consumer reporting agencies about their credit reports. The plan was produced in conjunction with the Attorneys General of several states.

The following chart summarizes the changes:

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 9/15/2017
Reporters of Authorized User Data Report full Date of Birth for new Authorized Users on all accounts 9/15/2017


insideARM Perspective

It will be interesting to see what impact these changes have on the ARM industry.  Will there be fewer companies or clients that want to report to the Credit Bureaus? Will these changes lead to more or less consumer litigation on credit bureau reporting?

Additionally, anytime there are changes to a process or new rules promulgated there are often issues that appear that were not originally contemplated. Often there are unintended consequences to the changes. insideARM would love to hear from its readers of any such concerns, issues or unintended consequences.  We will be happy to share the information with the industry.

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