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During this week’s Research Assistant Peer Call we discussed the confusion and pitfalls related to the Metro 2 Compliance Condition Codes XB, XH, and XC. 

The quandary arises once you have designated the account as disputed using the XB compliance condition code. Should you maintain the account in XB, reasoning that a dispute remains valid until the consumer opts to withdraw it? Alternatively, should you conclude your reasonable investigation and switch the account to XH (account previously in dispute – now resolved, reported by data furnisher), or opt for XC (completed investigation of FCRA dispute – consumer disagrees)? 

We have been made aware that the Consumer Financial Protection Bureau (CFPB) has explicitly expressed dissatisfaction with organizations retaining the XB condition code on consumers’ tradelines. However, consumer attorneys are inclined to initiate legal actions if you remove XB and report XH or XC. 

This presents data furnishers with a risk assessment dilemma, potentially yielding varied decisions. 

As we navigate the complexities of Metro 2 Compliance Condition Codes XB, XH, and XC, it becomes evident that evaluation of our procedures for risk analysis is imperative. Balancing regulatory expectations from bodies like the Consumer Financial Protection Bureau (CFPB) with the legal considerations posed by consumer attorneys necessitates a nuanced approach. Each decision regarding the designation of these codes carries inherent risks, underscoring the importance of thorough investigation and informed judgment.  

Documents and Crowdsourced Materials: 

• Member Questions: Texting, Credit Reporting Codes, Sanctions, and Aliases 

Top Reads: 

• Massachusetts AG Provides Guidance on Intersection of Artificial Intelligence and Existing State Laws 

• CFPB Bites of the Month – April 2024 – Won’t Get Fooled Again, CFPB 

• Credit Reporting Disputes: 11th Cir Decision Brings Clarity and Uncertainty 

Upcoming Webinars/ Other Announcements: 

• RA Compliance Corner: Internal Controls- When and How to Effectively Use Them on June 12, 2024, at 2:00 ET. Register for the webinar here! 

• Please make a note of our updated email addresses:  

• Sara Woggerman, sara_consultant@roundtables.us  

• Missy Meggison, mmeggison@roundtables.us   

• Have topics you want to discuss during the peer call? Please send them to: Sara_Consultant@roundtables.us by Thursday to ensure it makes it on our agenda!