Frequently Asked Questions

1.Question: What is the difference between ECOA Code T (Association with Account Terminated) and Z (Delete Borrower)?

Answer: ECOA code T should be reported when a consumer is no longer associated with an account (that is, loan assumption). In subsequent reporting periods, this consumer should not be reported. In the case of an assumed loan, FPS GOLD will automatically place code "T" on the Seller(s) for the effective credit reporting period and will discontinue reporting the Seller information in subsequent reporting periods.

ECOA code Z should be reported when a consumer was reported in error to credit repositories.

Note: It is imperative that only invalid consumers be deleted from the consumer reporting agencies’ files. Inaccurate information should be corrected, not deleted.

2.Question: How can an account or a specific individual be deleted from the consumer reporting agencies files?

Answer:

1.To delete an entire account for reasons other than fraud, report Account Status code DA. All individuals will be deleted, along with the account history, from the credit repositories. Once this has been reported, FPS GOLD will automatically turn off Report to Credit Bureau in subsequent reporting periods.

2.To delete an entire account due to confirmed fraud, report Account Status code DF. All individuals will be deleted, along with the account history, from the credit repositories. Once this has been reported, FPS GOLD will automatically turn off Report to Credit Bureau in subsequent reporting periods.

3To delete a specific individual associated with an account, change the ECOA code for the individual to “Z.” This will be sent to the credit repository for one reporting cycle and then will appear on the Credit Bureau Warning Report (FPSRP184), indicating that the individual should now be deleted from the account entirely.

Deleting Names from Accounts—You can delete names from accounts by using the CIS > Change Names and Addresses > Account Names and Mailing Labels screen. Select the loan from the Accounts List, then the selected individual from the Account Names list. Next, click the <Remove Name> button. IMPORTANT: If the individual you want to delete is the designated IRS Owner, you must first reassign ownership to another individual. FPS GOLD advises that the current IRS Owner and the new IRS Owner both be in the Account Mailing Label in order to change the IRS Owner.

Note: It is imperative that only invalid consumers be deleted from the consumer reporting agencies’ files. Inaccurate information should be corrected, not deleted.

3.Question: How should deceased individuals be reported?

Answer: Deceased individuals should be reported using ECOA code X. The death date should be added to the individual in CIS on the Entity Maintenance – Person screen. Note: If either of these is updated without the other, the Credit Bureau Warning Report (FPSRP184) will indicate so with warning code 5018 (INVALID ECOA CODE ON BORROWER). Both fields should be updated for accurate reporting to the credit repositories.

Adding ECOA Code X—This can be done on the Loans > Account Information > Names & Addresses screen, Lending Limit tab, for the individual.

Adding a Death Date—This can be done using the CIS > Entity Maintenance screen. Search for the individual, and then select them from the grid. Once on the Entity Maintenance – Person screen, update the Death Date.

FPS GOLD will automatically discontinue reporting a deceased individual once it has been reported to the credit repositories. A deceased indicator (BISTCR) will be set on the individual, and FPS GOLD will skip it in subsequent reporting periods. Note: If for some reason the individual was reported as deceased in error and the Death Date is removed, the deceased indicator will be cleared.

If only one individual is associated with the account and the death date has been reported, the entire account should discontinue reporting. This can be done by turning off the Report to Credit Bureau indicator located on the Loans > Account Information > Fees & Late Charges & Penalties, Late Fees tab, Late Charge Information field group.

Note: The Credit Bureau Warning Report (FPSRP184) will display Error Message 0006 (Discontinue Reporting) if the deceased individual is the only person on the account and the deceased indicator (BISTCR) is set to discontinue reporting. This will prompt the institution to turn off Report to Credit Bureau on the account.

IMPORTANT: Reporting a consumer as deceased provides valuable information on the credit report. If another consumer tries to use the identity of a deceased consumer, the “deceased” information will appear on the credit report, helping to deter the fraudulent activity.

4.Question: How should a business account be reported when a consumer is personally liable?

Answer: Business information can be sent to credit repositories only in association with individuals. Business information alone should not be sent to credit repositories and will not be added to the consumer credit databases. Businesses should always have an ECOA code of W (Business/Commercial). Associated individuals should be set up with an applicable ECOA code.

Adding ECOA Code W—This can be done on the Loans > Account Information > Names & Addresses Screen, Lending Limit tab, for the entity.

Note: If an individual/entity ends up with an ECOA code of W (Business/Commercial) and no other individuals are linked to the account, a warning code 5018 (INVALID ECOA CODE ON BORROWER) will appear on the Credit Bureau Warning Report (FPSRP184).

To resolve this, you will need to do one of the following:

•Assign the individual/entity a valid ECOA code on the Loans > Account Information > Names & Addresses screen, Lending Limit tab.

•Link an individual to the account with a valid CIS Ownership code and ECOA code. This can be done on the CIS > Change Names and Addresses > Account Names and Mailing Labels screen.

•Turn off the Report to Credit Bureau indicator located on the Loans > Account Information > Fees & Late Charges & Penalties screen, Late Fees tab, Late Charge Information field group.

5.Question: What causes duplicate tradelines?

Answer: Changes to the Portfolio Type field on the Loans > Account Information > Credit Reporting screen and/or Date Opened field may cause a duplication and should be done with caution. Consumer reporting agencies should be notified directly prior to these types of changes.

6.Question: How should an account that has been included in bankruptcy be reported when a consumer is making payments or has paid the account in full, even though the account has not been reaffirmed?

Answer: Unless the account has been reaffirmed through the Bankruptcy Court, the account is still included in bankruptcy. For credit reporting purposes, the appropriate bankruptcy Consumer Information Indicator (CIID) located on the Loans > Account Information > Names & Addresses screen, Lending Limit tab, must be reported. The CIID code is automatically assigned when the corresponding bankruptcy transaction is performed.

IMPORTANT: The CIID code is typically only updated using the Loans > Collections > Bankruptcy Transaction screen. Any maintenance to this field should be done by running the applicable transaction from this screen. Updating this field manually may result in other key fields not being correctly updated. Available transactions affecting the CIID code for the individual are as follows:

•Bankruptcy (Chapters 7, 11, 12, and 13)

•Convert to Chapter

•Discharge

•Dismiss

•Withdraw

•Reaffirmation

•Remove Bankruptcy

7.Question: Is there a preferred method of reporting a completely reaffirmed loan in bankruptcy?

Answer: For accounts that are completely reaffirmed in bankruptcy, report the appropriate Account Status and the Consumer Information Indicator (CIID) R (Reaffirmation of Debt). The CIID should be reported for each consumer who was involved in the bankruptcy.

When a loan is completely reaffirmed, use the Bankruptcy Transaction screen to process the reaffirmation.

Bankruptcy Transaction - Reaffirmation—This transaction is run by accessing the bankruptcy through the Loans > Collections > Bankruptcy Transaction screen, then selecting the <Lookup> button either by Bankruptcy or by Name. Once you have accessed the bankruptcy, the Bankruptcy Transactions field group information will be file maintainable. Select the Reaffirmation radio button and the appropriate individual(s), then click the <Run Transaction> button. The designated individuals will be flagged with the CIID code R (Reaffirmation of Debt).

If the reaffirmation is rescinded, you will need to manually restore the loan to its desired state for reporting purposes. A CIID code V (Chapter 7 Reaffirmation of Debt Rescinded) should be placed on the affected individual(s) for a credit reporting cycle. The Credit Bureau Warning Report (FPSRP184) will flag any individuals with a CIID code V once it has been reported with a warning code 5021 (CIID CODE EXPIRED – UPDATE CIID OR REMOVE ACCOUNT) so the account and individual(s) can be updated to reflect the current bankruptcy status going forward.

8.Question: How are “payment reversal” transactions handled when reporting Date of Last Payment, Date of First Delinquency, Payment History Profile, and Actual Payment Amount?

Answer: A “payment reversal” transaction usually occurs when a check is returned for non-payment (NSF). If the change is made in the following month’s reporting cycle, the following adjustments should be made:

1.The Date of Last Payment will be adjusted with the payment correction transaction to reflect the date the last payment was actually posted prior to the corrected payment.

2.Action code 194 should be placed on the account with the applicable date representing the Date of First Delinquency (DOFD). This date should reflect the first time the consumer was 30 days past the due date that led to the status being reported (that is, the DOFD should represent the month of the returned check if that is the first time the consumer would have been 30 days past due.)

Note: If the loan is delinquent at monthend and there is no action code 194, the system will update it and the action date will become the loan due date.

3.The 2 Year Payment History will need to be updated to reflect the corrected payment. You will do this on the Loans > Account Information > Credit Reporting screen, Monetary, Dates & Late Info tab, 2 Year Payment History. See the example below of a December 2015 payment that was corrected

JFMAMJJASOND4 JFMAMJJASOND5

000000000000 000000000001

The field below the month (D – December) should be changed from 0 (Current) to 1 (30 to 59 days delinquent). This will automatically update the loan Two Year Late Pattern and History field on the Loans > Account Information > Fee & Late Charges & Penalties screen and be reported in subsequent reporting periods.

Note: If the 2 Year Payment History that is sent to the credit repositories is out of sequence, a warning code 5019 (24 MONTH HISTORY PROFILE POSSIBLY IN ERROR) will appear on the Credit Bureau Warning Report (FPSRP184). This warning occurs if the 24 month history information appears to be out of sequence. This information is stored in the 2 Year Payment History field. The field updates sequentially each month, so if account information has been modified or payments are corrected or back dated over a monthend, the 2 Year Payment History may also need to be corrected.

An example of a 24 month history out of sequence is:

SOND3 JFMAMJJASOND4 JFMAMJJA5

0000 000000000000 00000013

Instead, a correct 24 month history should look like:

SOND3 JFMAMJJASOND4 JFMAMJJA5

0000 000000000000 00000012

9.Question: How should the different stages of foreclosure be reported?

Answer: Use the following guidelines:

Potential Foreclosure—No specific code is available for reporting with this designation. Continue reporting the correct Account Status code that defines the current condition of the account.

Foreclosure Started—Action code 94 and the date of occurrence should be added on the Loans > Account Information > Account Detail screen, Letters & Actions tab, in addition to hold code 7 (legal hold–foreclosure FHLMC) or 9 (legal hold–foreclosure). At monthend, when the credit bureau record is created, Special Comments code BO (Foreclosure Proceedings Started) will be added on the Loans > Collections > Credit Reporting screen and sent to the credit repositories. This special comment should be reported each month as long as the comment applies.

Foreclosure Cancelled—No specific code is available for this situation. Therefore, if Special Comments code BO had been reported previously, stop reporting it (that is, blank out the Special Comments code on the Loans > Collections > Credit Reporting screen and remove any applicable hold codes added on the Account Detail screen, Letters & Actions tab), it will then be deleted from the consumer reporting agencies files.

Foreclosure Started / Now Paid—Previously added hold code 7 (legal hold–foreclosure FHLMC) or 9 (legal hold–foreclosure) should be replaced with hold code 94 (paid account; foreclosure started) on the Account Detail screen, Letters & Actions tab. Special Comments code BO (Foreclosure proceedings started) should be manually removed. At monthend, the Account Status code of 65 (Account paid in full. A foreclosure was started) will be updated when the credit bureau record is created, indicating to the credit repositories that foreclosure proceedings had been started, but the consumer subsequently paid the account balance in full. The appropriate Payment Rating will be updated at that time and sent in conjunction with this Account Status.

Note: If Special Comments code BO is not manually removed, a warning message (5007 - SPECIAL COMMENT "BO" REQUIRES HOLD CODE 7 OR 9) will appear on the Credit Bureau Warning Report (FPSRP184) and should be removed before the final credit bureau report runs.

Foreclosure Completed—When a foreclosure has been completed, you should place hold code 1 (foreclosure completed) on the Account Detail screen, Letters & Actions tab. An H (foreclosure) will automatically be placed in the 2 Year Late Pattern History on the Loans > Fees & Late Charges & Penalties screen. The Account Status code 94 (Foreclosure completed; there may be a balance due) will be updated when the credit bureau record is created. The appropriate Payment Rating will be updated at that time and sent in conjunction with this Account Status. Special Comments code BO (Foreclosure proceedings started) will be automatically removed.

Note: If the consumer is not responsible for the remaining balance on the account, make the appropriate entries to zero out the balance of the loan and report the Current Balance of the loan a zero to the credit repositories. The Date Closed should be the date the foreclosure was completed.

If the consumer is responsible for the remaining balance on the account, make the appropriate entries to the balance of the loan so the Current Balance is reported accurately. As payments are made by the consumer, FPS GOLD will report a declining balance. When the Current Balance reaches zero, the Date Closed should be reported as the date the account was paid in full.

Do not report Account Status code 97 (Charge-off) after Account Status code 94 (Foreclosure completed) has been reported.

10.Question: How should alternatives to foreclosure (that is, Deed in Lieu and Short Sale) be reported?

Answer: Use the following guidelines:

Deed in Lieu—Enter a Charged Off date on the Loans > Account Information > Account Detail screen, Valuation and Credit Risk tab. This is a required field when adding hold code 6 (Deed in Lieu of foreclosure). Add hold code 6 (Deed in Lieu of foreclosure) and action code 94 (Date of Occurrence) on the Account Detail screen, Letters & Actions tab. At monthend when the credit bureau record is created, Account Status code 89 which specifies “Deed received in lieu of foreclosure on a defaulted mortgage; there may be a balance due,” will automatically be place on the account and reported to the credit repositories. The appropriate Payment Rating will also be reported in conjunction with this account status.

Note: If the consumer is not responsible for the remaining balance on the account, make the appropriate entries to zero out the balance and report the Current Balance of the loan as zero to the credit repositories. Report the Date Closed as the date the deed was received in lieu of foreclosure.

Do not report Account Status code 97 (Charge-off) after Account Status code 94 has been reported.

Short Sale—A short sale occurs when the proceeds from the sale of real estate fall short of the balance owed on the loan. In a short sale, the lender agrees to discount the loan balance typically due to an economic or financial hardship on the part of the consumer. The following fields should be reported as specified:

•The Scheduled Monthly Payment Amount should be reported as zero. If the loan has been closed on the system this will happen automatically.

•The Actual Payment Amount will contain the amount actually received for this reporting period. This is done by reading history backwards to the last time the credit bureau was updated. In particular, we look for transaction codes 510, 550, 580, 600, 690, 830, and 850 and their reversals.

•The Account Status code should be reported as 13 (Paid or closed account/zero balance) or 65 (Account paid in full, a foreclosure was started). The system will change this automatically if not overridden by file maintenance to the screen or other overriding parameters.

•The Payment Rating will be calculated and reported indicating whether the account is current or past due within the activity period being reported.

•A Special Comment of AU (Account paid in full for less than the full balance) should be manually added to the Credit Reporting screen (Loans > Account Information > Credit Reporting screen, Descriptors tab, Special Comments field).

•The Current Balance and Amount Past Due should be reported as zero. If the loan has been closed on the system, this will happen automatically.

•The Date of Account Information will be the Closed Date if the loan has been closed on the system.

11.Question: How long will Closed, Released, or Charge-off loans be reported?

Answer:

•At the time the account is closed, released, or charged-off, FPS GOLD will freeze the Account Status, Payment Rating, Payment History Profile, and Date of Account Information as monthend date.

•FPS GOLD will report closed, released, or charged-off accounts for three months.

12.Question: How should full loan assumptions be reported?

Answer:

Because the Consumer Account Number remains the same for the consumer who is assuming the loan, the consumers must be reported in separate reporting periods.

1.The first month, FPS GOLD will report the original borrower(s) with ECOA code T (Terminated) and Special Comments code H (Loan assumed by another party). Note: Special Comments code H will not be updated on the Credit Bureau screen, but it will be reflected in the Credit Bureau Report (FPSRP293) and will be sent to the credit repositories. FPS GOLD will report the Current Balance as zero.

2.The following month, FPS GOLD will report the new borrower(s) account information. Account information should be changed as it pertains to the new borrower if applicable. The 2 Year Payment History will be replaced with Bs indicating “No payment history prior to this time” and will update going forward with the new borrower(s) payment history.

13.Question: How should a secured debt (e.g., mortgage account) be reported when a consumer completes the required payments through a Bankruptcy Chapter 12 or 13 plan, but the account is still open and the consumer is continuing to make payments?

Answer: While the consumer is making payments through the plan, Consumer Information Indicator (CIID) should either be reported with a C (Petition for Chapter 12 Bankruptcy) or D (Petition for Chapter 13 Bankruptcy), whichever applies.

If the account is still open when the plan payments have been completed, you will update the Consumer Information Indicator (CIID) to Q to remove the petition indicator so that ongoing payments made by the consumer can be reported. This can be done on the Loans > Collections > Bankruptcy Information screen, Names tab. The hold code 4 (Bankruptcy – Chapter 7, 11, or 12) or 5 (Bankruptcy – Chapter 13) should also be removed.

14.Question: How should an account be reported when merchandise has been repossessed or the consumer has voluntarily surrendered the merchandise?

Answer: Use the following guidelines:

Repossession—When a repossession takes place, an Account Status code 96 (Repossessed; may have balance due) should be reported. This is done by manually updating the Account Status field on the Credit Reporting screen (Loans > Account Information > Credit Reporting screen, Descriptors tab).

If the consumer is not responsible for the remaining balance on the account, make the appropriate entries to loan so the Current Balance is reported as zero to the credit repositories. Report the Date Closed as the date the merchandise was repossessed.

If the consumer is responsible for the remaining balance on the account, make the appropriate entries to the loan so the Current Balance is reported accurately. As payments are made by the consumer, FPS GOLD will report a declining balance.

When the consumer pays the outstanding balance in full, report Account Status code 63 (Account paid in full, was a repossession). This is done by manually updating the Account Status field on the Credit Reporting screen (Loans > Account Information > Credit Reporting screen, Descriptors tab). The Current Balance and Amount Past Due should be zero, and the Date Closed should be the date the account was paid in full.

Voluntary Surrender—When a voluntary surrender applies, an Account Status code 95 (Voluntary surrender; may have a balance due) should be reported. If the consumer is not responsible for the remaining balance on the account, make the appropriate entries to the loan so the Current Balance is reported as zero to the credit repositories. Report the Date Closed as the date the consumer voluntarily surrendered the merchandise.

When the consumer pays the outstanding balance in full, report Account Status code 61 (Account paid in full, was voluntary surrender). The Current Balance and Amount Past Due should be zero and the Date Closed should be the date the account was paid in full.

15.Question: How should an account included in bankruptcy be reported if a “Relief from Stay” is granted to the creditor?

Answer: Report the appropriate Consumer Information Indicator (CIID) for the individual who included the account in bankruptcy (filer).

Note: Even though the creditor can pursue collection of collateral under the Relief from Stay, the account is still included in bankruptcy. The reporting of the CIID has no impact on the creditor's ability to collect.