Sassy/LKH - Why Cap1 was wrong, why EX isn't, + other stuff

[keb]

Dammit, 3/4ths of my text disappeared, and the rest screwed up.

 

Sorry, I'll repost this later when I fix it.

[SassyinAz]

Dammit, 3/4ths of my text disappeared, and the rest screwed up.

 

Sorry, I'll repost this later when I fix it.

 

Oyyyyyyy!

 

It was a good post, keb, I was trying to get my head around it -- guess I should quote instead of clicking on refresh.

 

Sassy

[keb]

OK, here it is. I hope I didn't delete most of it again.

 

 

Some questions that I'll answer in this one thread, since they're all related:

 

1. What does EX's "date of status" mean, why was it changed, and who is at fault?

2. Can a creditor report after an account is closed with a zero balance?

3. When a creditor says "I never sent that information to the CRA", or even "I don't have any information on you at all and could not have updated", did the CRA screw up?

4. "I had a CO with a balance that last reported two years ago. When I disputed and they verified, my score tanked! Who do I blame?"

5. Which one is lying, the CA or the CRA?

 

I divide this into three parts, a preface, a discussion of some data fields, and the answers to the questions. It will take a little bit to get there, please bear with me.

 

PREFACE

 

First, understand that credit reporting and verifying is not accomplished by one person calling another on the phone. It is almost exclusively computer to computer. There are about 200,000,000 adult americans, with an average of 10 active credit lines apiece for 2,000,000,000 records reported each month, with over 100 data fields per record, for over 200,000,000,000 pieces of data. You don't handle that volume of data piece by piece, person to person.

 

That data is moved around by computers. And for the most part, it is standardized. The four major CRAs (EX, EQ, TU and Innovis) jointly designed and implement a SINGLE standard data format called METRO2. Every creditor that reports data electronically, which includes all major OCs and most major CAs, uses this one format. Each creditor sends the same data, in the same format, to all four CRAs.

 

Disputing is also standardized. The primary dispute tool used by the industry (and used by all four CRAs) is called E-OSCAR. E-OSCAR is METRO2 compliant, which means that it reports data back to the CRAs in METRO2 format, according to METRO2 standards.

 

The METRO2 format has a single, industry-defined, written standard which defines the METRO2 file format. It defines every field, describes what each field must contain, specifies when each field must (and must not) be filled out, and says exactly how each field has to look.

 

DATA FIELDS

 

I'll talk about four important data fields here. First, two dates:

 

Activity Date: "Signifies date of most recent update to balances on accounts."

 

Billing Date: "... Report the current month's billing date (i.e., statement date). ... For accounts where the Billing Date is not available, report the activity date. ... If accounts are re-reported, freeze the Billing Date as of the month the account was paid. ... The date must represent the current month's reporting period. The date should not reflect a prior month's date or a date greater than the Activity Date."

 

Note that the Billing Date definition is very poorly written. If you miss the middle part (about re-reporting and freezing the date), you will surely screw it up.

 

These two date fields are the two fields which place the rest of the data into historical context. They're the fields that say WHEN things happened.

 

The other two fields I'll be discussing:

 

Payment History Profile: "Contains up to 24 months of consecutive payment activity for the previous 24 calendar months prior to the activity date being reported. ... Paid Accounts - refer to Frequently Asked Questions #21."

 

This is a string of characters that gets decoded into the 24-month payment profile that you can see on some CRs.

 

Account Status: "Contains the status code that properly identifies the current condition of the account as of the Billing Date."

 

Note that the Payment History Profile is placed into context by the Activity Date. The Activity Date defines the END of the profile. The Account Status is defined as of the Billing Date.

 

And just for amusement:

 

"Frequently Asked Questions #21:

Question: How long should a paid account..." (paid or closed account/zero balance, and all paid in full accounts no matter what the reason) "... continue to be reported?

Answer: Use the following guidelines if paid accounts are re-reported:

1. Freeze the Payment History Profile as of the Date of Last Payment.

2. Freeze the Billing Date as of the month the account was paid.

3. Do not re-report paid accounts for more than three months."

 

THE QUESTIONS

 

1. What does EX's "date of status" mean, why was it changed, and who is at fault?

 

The Date of Status on the myfico version of the EX CR is the Activity Date. You can test this by looking at the activity date and comparing it to the last month of the 24-month payment history. They should be the same.

 

It has been contended that EX is setting the "Date of Status" equal to the date on which they verify the account. But in order for the payment history to also end on the same date, this means that EX would have to be updating the ACTIVITY DATE. Are they?

 

If EX is screwing up, you would see something like: a 24-month history that would make sense if it ended, say, two years ago when the account closed, and a status date of this month. But I do not see that. I see EITHER a status date of two years ago and a 24-month history matching that date, OR a status date of this month and a 24-month history that maps to the most recent 24 months (with a bogus status in the most recent month). And I have seen multiple examples of both show up on my EX report in the last week.

 

So, in my considered opinion, the fault here lies with the creditors. The creditors are specifying the wrong activity date. They are NOT supposed to put the current month in the activity date field when updating closed accounts. The activity date is the last date the BALANCE was updated, which was the date on which the account was CLOSED and ZEROED.

 

2. Can a creditor report after an account is closed with a zero balance?

 

See the quoted "Frequently Asked Questions #21". Even if they did re-report, it should not change anything other than the date last reported (which does NOT affect the scoring) unless they screw up somehow.

 

3. When a creditor says "I never sent that information to the CRA", or even "I don't have any information on you at all and could not have updated", did the CRA screw up?

 

Most likely no. Just because the creditor sees one thing on their computer screen does NOT mean that they sent it correctly. An example:

 

I have a two-field screen where I fill in first name and last name. I fill it in so my screen shows:

 

First name: John

Last name: Smith

 

I send it to a CRA, which reports:

 

First name: Smith

Last name: John

 

I GUARANTEE this is not the CRAs fault. It is the fault of the program that I wrote to extract data and put it into the METRO2 format that I then sent to the CRA. It would only be the CRAs fault if EVERY REPORT had the same error, and they don't.

 

And if you call a creditor on the phone and they insist they have no record of your account and they further insist that they could not possibly be reporting you to the CRA, the best bet is that they are wrong.

 

The verification process at the CRAs end is automated. The CRAs did NOT just randomly decide to verify for the hell of it. They got something back from the creditor that says that the record is verified. This happens because the date source that the creditor uses to supply information to the CRAs is NOT THE SAME DATA SOURCE that they are looking at when they are sitting at their desks. The online data is NOT historical, and it is NOT complete. Their query databases could not possibly run fast enough if they had all of the data in them, they only have CURRENT data on CURRENT accounts in them. The rest of the stuff is stored in big, honking data files on big, honking mainframes that run big, honking programs (that run for hours and hours) to extract reporting data.

 

The ONLY people at any major creditor who can tell you for sure if your data is or is not being reported are the data geeks, NOT THE CSRS OR THE SUITS. And I am betting that none of you are talking to those people.

 

4. "I had a CO with a balance that last reported two years ago. When I disputed and they verified, my score tanked! Who do I blame?"

 

You blame yourself, really. The creditor was screwing up by not reporting it on a month-to-month basis. He is required to continue reporting until the account is closed with a zero balance, and he was not doing so. You were benefitting from him being incompetent. When he verified, he did what he was supposed to, which was to show that your account is still currently CO with a balance. You need to be aware of the fact that you may pay that price (hopefully only temporarily) if you try to dispute off a valid bad account that hasn't been reporting for awhile. If they verify, your score will drop. It is supposed to drop. It was supposed to be that low all along.

 

5. Which one is lying, the CA or the CRA? Which one is wrong?

 

Usually neither one is lying. And usually the creditor is wrong.

 

Lying and wrong: "2+2=3" when I know it equals 4.

Guessing and wrong: "2+2=3" when I have no clue.

Honestly wrong: "2+2=3" when I really thought it equalled 3.

 

Look at your CRs and (objectively) see how much is reporting correctly (and, be honest, MOST of the individual pieces of data on there are correct enough). Then consider this: every one of those creditors, the ones where the data looks right and the ones where the date looks wrong, used the SAME DATA FORMAT that was interpreted by the SAME COMPUTER PROGRAM. If some are right and one is wrong, the one that is wrong is not wrong because the CRA screwed it up, no matter how insistent the creditor is about it. It is wrong because the CREDITOR screwed it up. He just THINKS he did it right.

 

-------------

 

I don't let the CRAs off the hook entirely.

 

If I give a task to 20 students, and 19 do it right, it was a fair and easy task and the 1 who got it wrong needs to pay more attention.

 

If I give a task to 20 people and 1 does it right, it was an unfair and difficult task that was possible to accomplish, but I obviously didn't design it right or explain it well.

 

Credit reporting should be designed to make it possible to get it right almost all of the time. The fact that so many screw it up, particularly when disputes happen, is the CRAs fault. The data format is not well designed (particularly when it comes to BK reporting), the data standards are not clearly written, and there are too few examples given to make things clear.

 

But it is still the responsibility of the creditors to ensure that data reports correctly. And, difficult though it may be to get some things right, it is still them we have to blame when data is wrong. Because it IS possible to get it right.

[keb]

Yay!

 

Edited to add to my "Yay!":

 

The first time through, I tossed in some stuff about BK (since I happen to care about it), but I haven't figured it out enough. Just note that BK is not a "status". It is a separate flag. And it is not in any way clear how the BK gets tied to a date. Which really sucks.

 

Also, note that EVERY creditor who submits data to ANY of these CRAs signs a contract in which they obligate themselves to use a "data format mutually agreed to by both parties" (to quote one of the forms I've seen), which IS the METRO2 format, and they obligate themselves to adhere to the standards. So if they make a corporate decision to do otherwise (FIRST USA BK REPORTING, DAMN THEM), they are in deliberate breach of contract. I think someone could take that and go somewhere with it. I may be doing so soon.

 

Also note that the standards require people to fill out all fields (except for those circumstances where the field is SUPPOSED to be blank), so creditors (FUSA DAMN THEM) do not have the right to decide not to report something which the format has a field for.

 

Also note that the standard requires creditors to contact the CRAs if they have any questions regarding how to properly fill out the format.

[SassyinAz]

well, I'll give you another yayyyyyyyyyy!

 

That's some post, reading-digesting and re-reading.

 

If I'm remembering correctly you disagreed in mommy's lengthy Exp thread about what was going on -- the date of status being changed as if the date reported, yes? This seems to be the common theme and the same problem with everyone's report -- Exp changed and didn't tell anyone, not even the infamous Fico-man was aware of what they were doing. So, wondering what you think the problem is there specifically.

 

Getting my head around this as it relates to Cap One and the disputing of dates specifically because as I understood it the dates are stored by the CRA's -- if I dispute a date in the payment history or a date that is unnamed or unknown it really isn't going to the furnisher, the data is stored by the CRA's -- that should be considered when deciding whether to dispute with the Furnisher directly in addition to the CRA's, depending on one's goals and desire for the TL.

 

And while I'm thinking and digesting what you've posted, I have it on good authority that the process outlined and detailed in the First USA must be stopped mega thread, is spot-on and indeed winnable -- move forward, we were right all along on the inaccuracy of charge-off/IIBK reporting.

 

Following on all of that, nodding to your breach of contract thoughts, however, the agreement is between the CRA's and the furnishers -- understanding you believe the furnishers are directly responsible in here based on the information formatting requirements of the computer programs themselves (CRA controlled). I think that would make a good argument towards their furnishing of information inaccurately as wilfull.

 

The CRA's have a bigger umbrella role if they have reason to know that the information is unreliable from the furnisher and they are ultimately the ones responsible for the accuracy in all reports they produce (ala the Cushman, Richardson, Stevenson cases) -- however it gets converted or whatever they do with it is not our problems as a consumer, I say -- that indeed is the bigger role of the CRA.

 

So, I think where I am going and what I'm pondering is, the information itself versus the technology of how it is converted and processed -- the latter not being our problem as consumers (we are protected based on what is spit out, not how it was chewed ) because the FCRA requirements that a reinvestigation be conducted by the CRA's and an investigation by the Furnishers hasn't changed. It has already been established that parrotting and matching information on computer screens isn't the requirement -- established BOTH for the CRA's and the furnishers (Johnson v MBNA built upon the Cushman case as a foundation).

 

Sassy

[radi8]

If I'm remembering correctly you disagreed in mommy's lengthy Exp thread about what was going on -- the date of status being changed as if the date reported, yes? This seems to be the common theme and the same problem with everyone's report -- Exp changed and didn't tell anyone, not even the infamous Fico-man was aware of what they were doing. So, wondering what you think the problem is there specifically

.

 

The question I have is as follows:

 

When the same account is reported to all three CRA's, and is verified by all three ( for example a 1999 charge-off that I only recently got rid of)

And E-Oscar sends the exact same verification data to all three CRAs, as is required-

but your FICO score drops on only one report (Experian).

Who is at fault?

 

E-Oscar, Metro-2 were both mandated by the CRA's, not the furnishers.

If they are error-prone or too confusing to use properly, the fault lies with?

Did paper UDF forms have these problems? No.

Since the requirement to use an error-prone system was mandated by the CRA's, they must bear the ultimate responsibility for it.

 

 

If the CRA's require monthly updating as part of their agreement, but a furnisher does not do so- and the CRA allows it by not enforcing their agreement- who is at fault?

[LKH]

OK. I've got one for you. A closed acct, paid as agreed, zero balance for 2 years, and has 2 30 day lates from 12/98 and 9/98.

 

I get a report directly from experian and it shows both dates of the lates.

 

I get a report from myfico and/or a creditors version and it shows late as 12/99 and "one other unknown date". Who's to blame? Experian. They are purposefully producing different copies of credit reports. I don't know why but I certainly have proof and Experian denies it to this day. Only a lawsuit will bring it out.

 

So when you say the creditors and not the cra's are to blame, I don't buy that for a second. Cra's, and especially Experian, are spiteful, vengeful, despicable, liars and cheaters.

 

My score before they decided to remove that late date - 721 - after 654.

[pryan67]

I only briefly scanned the post (VERY well written BTW), but I saw a few glaring items that I have an issue with:

 

 

Look at your CRs and (objectively) see how much is reporting correctly (and, be honest, MOST of the individual pieces of data on there are correct enough).

 

 

what is "correct enough", and where in the FCRA is that term? I believe that it MUST BE 100% correct...it is NOT that difficult....

 

f I give a task to 20 students, and 19 do it right, it was a fair and easy task and the 1 who got it wrong needs to pay more attention.  

 

If I give a task to 20 people and 1 does it right, it was an unfair and difficult task that was possible to accomplish, but I obviously didn't design it right or explain it well.  

 

It was not necessarily an unfair and difficult task...how tough is it to fill out a form? If the CRAs can't handle that, or the CSRs at the OC/CA, maybe they should get a less demanding job....not that I can THINK of a less demanding job than entering data into fields....this is similar to the argument that schools give all the time when teachers can't teach..."oh, we have to drag down the rest of the class"...I don't buy it...if they can't do the job, get someone who can...

 

 

But it is still the responsibility of the creditors to ensure that data reports correctly. And, difficult though it may be to get some things right, it is still them we have to blame when data is wrong. Because it IS possible to get it right.

 

 

It's also the responsibility of the CRAs to ensure that what's reporting is POSSIBLE...for instance, an account that's reporting IIB with a balance...impossible....one that's reporting a DOLA as 06/01, but an open date of 06/04 and a closed date of 06/03...

 

The verification process at the CRAs end is automated. The CRAs did NOT just randomly decide to verify for the hell of it. They got something back from the creditor that says that the record is verified.

 

 

we know for a fact that this isn't true 100% of the time...they DO "verify for the hell of it" often...and many people here have letters from the FOI stating that....

 

 

 

. "I had a CO with a balance that last reported two years ago. When I disputed and they verified, my score tanked! Who do I blame?"  

 

You blame yourself, really. The creditor was screwing up by not reporting it on a month-to-month basis. He is required to continue reporting until the account is closed with a zero balance, and he was not doing so

 

Where is that written in the FCRA?

[cannoda]

All the CRAs have to do to fix this problem is to contract on the accuracy of the information provided.

 

Remember, every one reporting a tradeline to a CRA has a contract with them - a contract drafted by the CRAs. All the CRA has to do is put some meaningful financial incentives or penalties in their contracts that are based on the number of reporting mistakes. They CRAs won't do this until they face financial incentives or penalties based on the accuracy of their databases.

[keb]

If I'm remembering correctly you disagreed in mommy's lengthy Exp thread about what was going on -- the date of status being changed as if the date reported, yes?  This seems to be the common theme and the same problem with everyone's report -- Exp changed and didn't tell anyone, not even the infamous Fico-man was aware of what they were doing.  So, wondering what you think the problem is there specifically.

 

I disputed 5 BK TLs recently. EX shows two with a DOS of 08/04. It shows the other three with a DOS of 05/02. Date reported for all 5 is 08/04. So they are not (universally) just slapping the reported date into the DOS. When I look at the two TLs with a DOS of 08/04, the 24-month history is 23 months of OK/no status, followed by a 24th month of PP. The others show a 24-month window that ends in 05/04, and maps to the 24 months ending in 05/04. That tells me that the FURNISHERS of the information were the ones who messed up.

 

The reason this might affect us more with EX than with others is twofold:

 

1) All CRAs get the same info, but they do not all USE the same info. They have differently philosophies as to what is and is not meaningful. So different CRAs ignore different things.

 

2) All CRAs "scrub" data to some degree or another to make it appear more "reasonable". EQ, for example, removes all balances, all past due balances, and all negative account history subsequent to a BK filing. The others do not. But FICO scoring cares about balances. My TU and EX FICOs both have negative comments regarding "balances on delinquent accounts", while EQ does not. Another example: the BK flag on the data format distinguishes between "BK filed" and "BK discharged". EX does not care - it lumps them together. FICO scoring cares, though. A non-discharged BK is worse than a discharged BK. So on EX, all BKs are scored as "discharged". On the others, filed but not discharged BKs are scored as if you are in a CCCS.

 

Getting my head around this as it relates to Cap One and the disputing of dates specifically because as I understood it the dates are stored by the CRA's -- if I dispute a date in the payment history or a date that is unnamed or unknown it really isn't going to the furnisher, the data is stored by the CRA's -- that should be considered when deciding whether to dispute with the Furnisher directly in addition to the CRA's, depending on one's goals and desire for the TL.

 

All of the dates that I see on a CR map in some way or another to the dates included in the last submission of data. I don't think the CRAs store "history" (e.g., multiple copies of submissions). That would be a staggering amount of data. The reason some dates start to go missing after awhile, for example, is because that information starts to get removed from the creditors computers and they can no longer report it.

 

And while I'm thinking and digesting what you've posted, I have it on good authority that the process outlined and detailed in the First USA must be stopped mega thread, is spot-on and indeed winnable -- move forward, we were right all along on the inaccuracy of charge-off/IIBK reporting.

 

I think the FUSA reporting practice is dead wrong just on the issue of completeness. I don't see how they think they can win. And I also think it rises to the level of malice. Let's cross our fingers.

 

Following on all of that, nodding to your breach of contract thoughts, however, the agreement is between the CRA's and the furnishers -- understanding you believe the furnishers are directly responsible in here based on the information formatting requirements of the computer programs themselves (CRA controlled).  I think that would make a good argument towards their furnishing of information inaccurately as wilfull.

 

Yes! My contention would be that, if the information is wrong on the CR, it is the FURNISHERS responsiblity to make sure that it is correct, even if it ends up being wrong because the CRA didn't interpret it correctly. If it is possible to get things to look right, no matter how difficult that may be, it is the furnisher's responsibility to make it right, or to delete. If this ends up being the CRAs fault in some way or another, I don't care. The furnishers can take that up with the CRA separately. But the FURNISHERS still have to make sure that it is right, or they have to remove it. And refusing to make the effort is willful.

[LKH]

Keb, it is also willful on the cra's part when we dispute as inaccurate, or not mine, or whatever the case may be, and they respond with verified, knowing damn well they never reinvestigated.

 

Or the "previously investigated" and they refuse to reinvestigate UNTIL they receive a PR and then they fake an investigation and remove the disputed item. That isn't the oc's fault.

 

My point is that all are liable, the cra's, ocs and ca's. When you say "If this ends up being the CRAs fault in some way or another, I don't care" I fail to understand why you wouldn't care? You should.

[Toothfairy]

4. "I had a CO with a balance that last reported two years ago. When I disputed and they verified, my score tanked! Who do I blame?"

 

You blame yourself, really. The creditor was screwing up by not reporting it on a month-to-month basis. He is required to continue reporting until the account is closed with a zero balance, and he was not doing so. You were benefitting from him being incompetent. When he verified, he did what he was supposed to, which was to show that your account is still currently CO with a balance. You need to be aware of the fact that you may pay that price (hopefully only temporarily) if you try to dispute off a valid bad account that hasn't been reporting for awhile. If they verify, your score will drop. It is supposed to drop. It was supposed to be that low all along.

 

.

 

My main question has to do with this scenario. I understand that if a balance is reporting that they are supposed to every month and when they finally do report your score drops, but....

 

What about a CO from 10/02 that has a "0" balance and has been reporting CO in 10/02 until it was disputed in 08/04 and suddenly not only is the Date of Status being reported in 08/04 (where previously it was 10/02), but now the Account history reads like this: Charge Off as of 10/02, 08/04. How could it have been charged off twice and who is to blame for this one? I really need to know since I have a very nasty letter sitting here waiting to be sent to EXP. The question is, should the OC be getting the letter instead, or should they both get a letter??

[LKH]

Toothfairy,

 

IMO, and it has always been my opinion, the cra's are vindictive to those of us that have disputed info on our reports. That said, I also believe the oc's/ca's are sloppy when it comes to reporting. I believe that both are responsible for inaccuracies in their own ways. I would send a letter to both the cra and the oc and maybe they'll fight it out amongst themselves, or at least figure out the problem.

[SassyinAz]

Good points, all of them, but I'm wanting to focus on this because I'm trying to understand and only so much can fit into my head at one time ;-)

 

If I'm remembering correctly you disagreed in mommy's lengthy Exp thread about what was going on -- the date of status being changed as if the date reported, yes? This seems to be the common theme and the same problem with everyone's report -- Exp changed and didn't tell anyone, not even the infamous Fico-man was aware of what they were doing. So, wondering what you think the problem is there specifically.

 

I disputed 5 BK TLs recently. EX shows two with a DOS of 08/04. It shows the other three with a DOS of 05/02. Date reported for all 5 is 08/04. So they are not (universally) just slapping the reported date into the DOS. When I look at the two TLs with a DOS of 08/04, the 24-month history is 23 months of OK/no status, followed by a 24th month of PP. The others show a 24-month window that ends in 05/04, and maps to the 24 months ending in 05/04. That tells me that the FURNISHERS of the information were the ones who messed up.

 

Where is that history coming from?

 

The information is converted in the Metro2 format and furnished to the CRA's, yes?

 

Anything then disputed occurs through E-Oscar, is the entire 24-month history re-furnished by the Furnisher if I were to dispute a late payment?

 

And, you know that Exp's own documentation says (recently updated but all that goes with it is not) that the date of status is the last time it was reported -- the exact same definition of the last reported field?

 

From this thread:

http://www.creditboards.com/phpBB2/viewtop...er=asc&start=30

 

Shows the date of status and status details as related (how it was done previously, count backwards from the scheduled to remain date)

http://www.experian.com/credit_report_basi...editreport1.pdf

 

The furnishers are required to provide the date of the first delinquency that led to the status being reported (collection/charge-off or anything similar) as an input field required by Exp's software when reporting the derogatory status. http://www.experian.com/products/pdf/insta...tant_update.pdf

 

And this, from this thread (this is what Exp changed but didn't tell anyone, not their reps and not FICO): http://www.creditboards.com/phpBB2/viewtop...er=asc&start=45

 

Here is how Experian DEFINES "date of status"

(and other terms)

 

http://www.experian.com/consumer/glossary.html

 

Date of Status

On the credit report, date the creditor last reported information about the account.

 

Last Reported

On the credit report, the date the creditor last reported information about the account.

 

Payment Status

Reflects the previous history of the account, including any delinquencies or derogatory conditions occurring during the previous seven years (i.e., Current account, delinquent 30, current was 60, redeemed repossession, charge-off – now paying, etc.)

 

Status

On the credit report, this indicates the current status or state of the account.

 

So, I guess the question is, how did you dispute those BK TL's??? And, once disputed, does the Furnisher have access to ALL information previously reported in order to make changes?

 

Monthly updates are now mandatory of the Furnishers, btw, per the E-Oscar system for dispute resolution as I understand it -- no updates = information won't be accepted by the CRA's = no reporting. Means to me, we should have been disputing information and requesting deletion of information that hadn't been updated (on it's face) for years now.

 

Sassy

[JerseyBaby]

Look at your CRs and (objectively) see how much is reporting correctly (and, be honest, MOST of the individual pieces of data on there are correct enough).

 

 

what is "correct enough", and where in the FCRA is that term? I believe that it MUST BE 100% correct...it is NOT that difficult....

 

Actually, the FCRA does not say information needs to be 100% accurate.

 

( Reasonable procedures. It is the purpose of this title to require that consumer reporting agencies adopt reasonable procedures for meeting the needs of commerce for consumer credit, personnel, insurance, and other information in a manner which is fair and equitable to the consumer, with regard to the confidentiality, accuracy, relevancy, and proper utilization of such information in accordance with the requirements of this title.

 

I'm still waiting for the "fair and equitable to the consumer" part to kick in. The CRAs

never seem to get that right.

[LKH]

This is the FCRA requirement for furnishers of info:

 

 

 

§ 623. Responsibilities of furnishers of information to consumer reporting agencies [15 U.S.C. § 1681s-2]

 

(a) Duty of furnishers of information to provide accurate information.

 

(1) Prohibition.

 

(A) Reporting information with actual knowledge of errors. A person shall not furnish any information relating to a consumer to any consumer reporting agency if the person knows or consciously avoids knowing that the information is inaccurate.

 

( Reporting information after notice and confirmation of errors. A person shall not furnish information relating to a consumer to any consumer reporting agency if

 

(i) the person has been notified by the consumer, at the address specified by the person for such notices, that specific information is inaccurate; and

 

(ii) the information is, in fact, inaccurate.

 

© No address requirement. A person who clearly and conspicuously specifies to the consumer an address for notices referred to in subparagraph ( shall not be subject to subparagraph (A); however, nothing in subparagraph ( shall require a person to specify such an address.

 

(2) Duty to correct and update information. A person who

 

(A) regularly and in the ordinary course of business furnishes information to one or more consumer reporting agencies about the person's transactions or experiences with any consumer; and

 

( has furnished to a consumer reporting agency information that the person determines is not complete or accurate, shall promptly notify the consumer reporting agency of that determination and provide to the agency any corrections to that information, or any additional information, that is necessary to make the information provided by the person to the agency complete and accurate, and shall not thereafter furnish to the agency any of the information that remains not complete or accurate.

 

(3) Duty to provide notice of dispute. If the completeness or accuracy of any information furnished by any person to any consumer reporting agency is disputed to such person by a consumer, the person may not furnish the information to any consumer reporting agency without notice that such information is disputed by the consumer.

 

(4) Duty to provide notice of closed accounts. A person who regularly and in the ordinary course of business furnishes information to a consumer reporting agency regarding a consumer who has a credit account with that person shall notify the agency of the voluntary closure of the account by the consumer, in information regularly furnished for the period in which the account is closed.

 

(5) Duty to provide notice of delinquency of accounts. A person who furnishes information to a consumer reporting agency regarding a delinquent account being placed for collection, charged to profit or loss, or subjected to any similar action shall, not later than 90 days after furnishing the information, notify the agency of the month and year of the commencement of the delinquency that immediately preceded the action.

( Duties of furnishers of information upon notice of dispute.

 

(1) In general. After receiving notice pursuant to section 611(a)(2) [§ 1681i] of a dispute with regard to the completeness or accuracy of any information provided by a person to a consumer reporting agency, the person shall

 

(A) conduct an investigation with respect to the disputed information;

 

( review all relevant information provided by the consumer reporting agency pursuant to section 611(a)(2) [§ 1681i];

 

© report the results of the investigation to the consumer reporting agency; and

 

(D) if the investigation finds that the information is incomplete or inaccurate, report those results to all other consumer reporting agencies to which the person furnished the information and that compile and maintain files on consumers on a nationwide basis.

 

(2) Deadline. A person shall complete all investigations, reviews, and reports required under paragraph (1) regarding information provided by the person to a consumer reporting agency, before the expiration of the period under section 611(a)(1) [§ 1681i] within which the consumer reporting agency is required to complete actions required by that section regarding that information.

© Limitation on liability. Sections 616 and 617 [§§ 1681n and 1681o] do not apply to any failure to comply with subsection (a), except as provided in section 621©(1)( [§ 1681s].

 

 

(d) Limitation on enforcement. Subsection (a) shall be enforced exclusively under section 621 [§ 1681s] by the Federal agencies and officials and the State officials identified in that section.

[keb]

what is "correct enough", and where in the FCRA is that term? I believe that it MUST BE 100% correct...it is NOT that difficult....

 

If the historical high balance on your account was $4980, and the report $4992, that's not 100% accurate, but really...

 

They get most fields right, even on bad TLs. Except for CAs, who are probably not given all of the data in the first place. (Which is not an excuse...)

 

..how tough is it to fill out a form?

 

That's true enough if it is just a question of mapping one piece of data onto another. But read the definition of "Billing Date" above, including the part about "freezing" it. No creditor has a date in their system that corresponds directly to that definition. They have to figure it out, and they have to figure it out correctly. And there are 1000s of creditors, with 100s of different accounting systems. So it's not easy. (Which is ALSO not an excuse...)

 

It's also the responsibility of the CRAs to ensure that what's reporting is POSSIBLE...for instance, an account that's reporting IIB with a balance...impossible....one that's reporting a DOLA as 06/01, but an open date of 06/04 and a closed date of 06/03...

 

I agree. And if you can point to a tradeline and say "it is impossible for that TL to be true because it is self-contradictory", I think they HAVE to remove it. But that isn't the case, for the most part. What is there is wrong, but it COULD be true.

 

BTW, if an account is in BK but not yet discharged, does it have a balance or not? And if so, is it meaningful? EQ thinks that it is not. EX, TU and Fair Isaac think that it is. You can say that it shouldn't be, but where does it say so?

 

we know for a fact that this isn't true 100% of the time...they DO "verify for the hell of it" often...and many people here have letters from the FOI stating that....

 

I'm not going to say the CRAs never do so. But I bet they do so FAR less than people here think. Just because you call up a CRS at a creditor, and they say they have no data and couldn't have verified, does not mean that they DIDN'T verify. That CSR has absolutely nothing to do with the part of the business that does verification. If any company tells you that, without first taking at least two days to research it, I'd say they're full of it.

 

The creditor was screwing up by not reporting it on a month-to-month basis. He is required to continue reporting until the account is closed with a zero balance, and he was not doing so

 

Where is that written in the FCRA?

 

The FCRA says nothing about this. I was referring to the industry data standards. They state that all accounts are to be reported until the account is closed with a zero balance, and that all accounts are to be reported once per report cycle (generally monthly). An unpaid chargeoff is not a zero balance account. The consumer still has a liability they have not honored. They may have initially been charged off six years ago, but they still owe the money TODAY and they are still not paying TODAY. So that's a current negative. People should be glad that most creditors are lazy.

 

So, for example, in the month in which it is paid, a paid chargeoff has the same negative effect as an unpaid chargeoff, since they were both negative as of last month. But over time, the paid chargeoff is supposed to get better, because it is supposed to age and the unpaid chargeoff is supposed to remain current. In practice, the paid chargeoff doesn't always age, and the unpaid chargeoff often ages due to lack of reporting, but those are both reporting errors, one detrimental to you and one beneficial to you.

 

That's just the logic of the data standards.

[SassyinAz]

 

Where is that written in the FCRA?

 

The FCRA says nothing about this. I was referring to the industry data standards. They state that all accounts are to be reported until the account is closed with a zero balance, and that all accounts are to be reported once per report cycle (generally monthly). An unpaid chargeoff is not a zero balance account. The consumer still has a liability they have not honored. They may have initially been charged off six years ago, but they still owe the money TODAY and they are still not paying TODAY. So that's a current negative. People should be glad that most creditors are lazy.

 

So, for example, in the month in which it is paid, a paid chargeoff has the same negative effect as an unpaid chargeoff, since they were both negative as of last month. But over time, the paid chargeoff is supposed to get better, because it is supposed to age and the unpaid chargeoff is supposed to remain current. In practice, the paid chargeoff doesn't always age, and the unpaid chargeoff often ages due to lack of reporting, but those are both reporting errors, one detrimental to you and one beneficial to you.

 

That's just the logic of the data standards.

 

Now we're getting somewhere!!!!!!!!

 

THIS is exactly the problem, keb, and why everyone's EX scores are tanking a dump with each dispute.

 

The FCRA doesn't address scoring, only the information.

 

I agree with your example an account charged-off six years ago is still a charge-off as of today.

 

The problem is, FICO uses the date of status as it was previously used by Exp, as the commencement of delinquency date that is attached to the status details.

 

Ex is now using it differently and didn't tell FICO -- making every TL read to FICO as if it were just charged off as of the status date.

 

From the link on the previous page, it does not appear to be an option that the Furnishers themselves can change -- it is a product of Exp's automation by using it the same as the last reported date -- which are 2 entirely different things to everyone in the world but Exp.

 

There are NO history fields in there that the Furnisher can change. If I dispute a date associated with the payment history, doesn't look to me as if there is anyway for the Furnisher to even respond to it specifically based on the options provided.

 

And, the only thing that matters for BK TL's with Exp is that it was included or discharged, only the filing date matters for the TL, makes no difference to Exp. The discharge would be reflected in the PR listing of the BK.

 

Sassy

[Toothfairy]

Toothfairy,

 

IMO, and it has always been my opinion, the cra's are vindictive to those of us that have disputed info on our reports. That said, I also believe the oc's/ca's are sloppy when it comes to reporting. I believe that both are responsible for inaccuracies in their own ways. I would send a letter to both the cra and the oc and maybe they'll fight it out amongst themselves, or at least figure out the problem.

 

So perhaps a CYA letter or modification to the OC and my nasty "I will sue you letter" to EXP? See if we can get them to figure it out?

[SassyinAz]

Toothfairy,

 

IMO, and it has always been my opinion, the cra's are vindictive to those of us that have disputed info on our reports. That said, I also believe the oc's/ca's are sloppy when it comes to reporting. I believe that both are responsible for inaccuracies in their own ways. I would send a letter to both the cra and the oc and maybe they'll fight it out amongst themselves, or at least figure out the problem.

 

So perhaps a CYA letter or modification to the OC and my nasty "I will sue you letter" to EXP? See if we can get them to figure it out?

Here is the bigger problem, fave tooth (extra chocO for you),

 

The FCRA says the information has to be accurate and complete; updated and verifiable, yes? nodding.

 

This is your post from the previous page:

 

4.  "I had a CO with a balance that last reported two years ago.  When I disputed and they verified, my score tanked!  Who do I blame?"

 

You blame yourself, really.  The creditor was screwing up by not reporting it on a month-to-month basis.  He is required to continue reporting until the account is closed with a zero balance, and he was not doing so.  You were benefitting from him being incompetent.  When he verified, he did what he was supposed to, which was to show that your account is still currently CO with a balance.  You need to be aware of the fact that you may pay that price (hopefully only temporarily) if you try to dispute off a valid bad account that hasn't been reporting for awhile.  If they verify, your score will drop.  It is supposed to drop.  It was supposed to be that low all along.

 

.

 

My main question has to do with this scenario. I understand that if a balance is reporting that they are supposed to every month and when they finally do report your score drops, but....

 

What about a CO from 10/02 that has a "0" balance and has been reporting CO in 10/02 until it was disputed in 08/04 and suddenly not only is the Date of Status being reported in 08/04 (where previously it was 10/02), but now the Account history reads like this: Charge Off as of 10/02, 08/04. How could it have been charged off twice and who is to blame for this one? I really need to know since I have a very nasty letter sitting here waiting to be sent to EXP. The question is, should the OC be getting the letter instead, or should they both get a letter??

It is reporting that the TL was charged-off as of 10/02 and as of 08/04, it remains a charge-off -- it doesn't say it was charged off twice, you're only reading it that way because of how it previously reported.

 

Is that information inaccurate? No, it's not.

 

Is that information misleading? No, it's not.

 

The FCRA doesn't address scoring, it only addresses the information, so really, it isn't a FCRA violation.

 

They have changed how they report information (technically accurate and escpaing FCRA liability) while they KNOW what FICO is doing with the information it gets from them (punishing and lowering consumer's scores with each dispute).

 

FICO isn't regulated, it can use the information provided to spit out whatever number it wants.

 

Do you see how clever this plot is, Exp is reading along laughing at their masterful manipulation of the system (FICO too).

 

The only thing I think we could hang on Exp is in the purpose of the FCRA itself:

 

b) Reasonable procedures. It is the purpose of this title to require that consumer reporting agencies adopt reasonable procedures for meeting the needs of commerce for consumer credit, personnel, insurance, and other information in a manner which is fair and equitable to the consumer, with regard to the confidentiality, accuracy, relevancy, and proper utilization of such information in accordance with the requirements of this title.

 

Maybe there's a way to make "proper utilization of such information" applicable to FICO???? or that TU and EQ don't use the information in the same way to penalize consumers for disputing??? or that EX previously didn't use the information in the same way and the change has resulted in it not being fairly utilized???

 

I have looked at my Exp 100 times today, keb, and while I'm flying with ya on the updating of the status date (as accurate), I'm just not seeing where the furnisher can do a damn thing about it except NOT respond and have all information deleted.

 

Sassy

[SassyinAz]

Everything in italics is quoted from the Metro 2 format instruction manual:

 

Once information is reported accurately, it is important that data furnishers not ask for a subsequent change the history payment record unless the payment history is inaccurate.

 

. Consumer credit history information will be reported in a factual, precise and objective manner.

 

. Only inaccurately reported accounts should be deleted. Paid derogatory accounts, such as collections or charge offs, should be reported as paid; they should not be deleted.

 

. Requests by consumers for reverification of challenged information must be processed promptly.

 

. Unless an error is discovered, the consumer will be advised that the factual credit history will continue to be reported.

 

Asking for exceptions to the standards jeopardizes the integrity of the data (bolding and italics is theirs).

 

The Metro 2 format was designed to allow reporting of the most accurate and complete information on consumers’ credit history. It is imperative that all accounts are reported on a monthly basis and that they are reported with a final account status code when they are ultimately paid or closed.

 

For data furnishers or processors who report data by cycles, all accounts should be reported at the close of each cycle.

 

All fields should be reported in order to comply with the FCRA, which specifies the reporting of complete and accurate information.

 

Hellooooooooooo Cap One and your lack of reporting the credit limit.

 

If all 3 are requiring the use of the same format, the only thing making a difference in scoring (besides inaccuracies) is those TL’s that aren’t reported to all 3, yes?

 

Always retain a back-up copy of the data you provide. This copy could be used to replace media that was damaged or unreadable.

 

There’s a good reason to request verification from the furnisher directly.

 

Do not report derogatory accounts beyond the allowable retention periods specified by federal and state laws.

 

Interesting keb, the section you quoted earlier about the freezing is relating to re-reporting of paid accounts specifically -- not a word about the FCRA requirements for re-reporting and certification of the information. Hmmmmm, big fat hmmmmmmm

 

I’m guessing you are a programmer by your previous post, you write programs that extract the information from creditor’s files and translate it into a metro 2 format or something similar?

 

Date closed

 

For all portfolio types, contains the date the account was closed or paid. For line of credit, open or revolving accounts, there may be a balance due.

 

Account status codes

 

Enter the account status code which best describes whether the account is current or past due as of the billing date.

 

I like DA “deletes entire account” I think we should request it specifically

 

Note: In order to maintain the integrity of credit information, it is important that data furnishers not ask for a subsequent deletion of account history unless an actual error was reported. Paid derogatory accounts, such as collections, should be reported as paid; they should not be deleted.

 

I lied about the BK Coding, this metro2 crap conflicts with Exp’s program for updating :shock:

 

How do account statuses, payment ratings and special comments interact?

 

Answer: The account status (field 17A) is used to report the current condition of the accounts, such as current or 30 days past the due date. The payment rating (field 17B), which is required for certain account statuses, is used to report whether the account is current, past due, in collections or charged off within the activity period being reported. The special comment (field 19) is used to provide additional information about the account. These codes are used together to provide a complete picture of the account.

 

Examples:

 

. An account is reported with account status code 80 (90 days past the due date) and special comment code M (account closed at credit grantor’s request). Since both codes are reported, credit grantors know the current condition of the account, and that the account is closed to further charges, at the credit grantor’s request.

 

. An account is reported with account status code 13 (paid), payment rating 3 (90 days past the due date) and special comment code AU (account paid in full for less than the full balance). The combination of codes provides complete information for credit grantors: the account is paid, the consumer was 90 days past the due date during the final month and the account was settled for less than the full balance.

 

Oyyyyyyyyyyy!

 

What account status code should be reported with the BK consumer information indicators?

 

Answer: For accounts where all associated borrowers are reported with a BK consumer information indicator, report the account status code that represents the status of the account just prior to the notification of the BK

 

Hellooooooooooooo First USA

 

Tired of typing and I just got to the correction/consumer dispute sections -- figures they are at the end.

 

OHHHHHHHHHH, one more because this is good!

 

The FCRA guarantees consumers the right to dispute information that has been previously reported to CRA’s (see sections 611 and 623)

 

Note the bolding here, it is theirs:

 

The consumer may initiate his or her dispute at a CRA, one of the affiliates of that repository, or a reseller of consumer reports. Regardless of the source at which the dispute originates, the data furnisher must respond

 

See FTC interpretation letters of July 1999 "]http://www.ftc.gov/os/1999/9908/fareslette...erfinal.htm

 

Clicking on that now.

 

The law also describes these duties of data furnishers specific to the consumer dispute process:

 

. Conduct an investigation with respect to the disputed information.

 

. Review all relevant information provided by the CRA (Sassy note -- yeah right, what, the 2-digi code????)

 

. Report the results of the investigation to the CRA.

 

. If the investigation finds that the information is incomplete or inaccurate, report those results to all other CRA’s to which the data provider furnished the information.

 

Notice, no mention in here of the requirement to advise the CRA’s of the dispute (though there are codes for it under the FCRA and FCBA), another hmmmmmmm indeed

 

The law also mandates a deadline for the completion of the investigation, review, and reporting of the investigation results. The process shall be completed within a 30-calendar day period that begins when the consumer contacts the CRA

 

The above directly contradicts everything previous to it.

 

Appears to me the furnishers do what the CRA’s tell them to do which isn’t always the same as what the FCRA says either must do.

 

Interesting indeed.

 

Sassy

[SassyinAz]

The Fares FTC letter isn't available online, that figures.

 

Sassy

[keb]

Sassy -

 

In industry parlance I'm a "Computer Engineer Level 5". I've done a lot of work that is comparable to this stuff. I haven't worked with Metro2 or E-OSCAR, or I'd feel more confident. I'm just blundering along like the rest of us, trying to evaluate the described data format and the written standards in the light of my own experience.

 

-----

 

After reading all of the threads you cross-linked to, I'm again coming around to the thought that EX may well be screwing this up.

 

I looked at my CR, and of the 5 TLs I had disputed (two of which ended up with a status date of 08/04, and the other three of which had status dates unchanged), the EX REPORTING DATE is the same as the DATE OF STATUS. Even for the accounts that CHANGED but did not have the DOS change. E.g., they updated on 08/04, but show a last reported date of 05/02(??!!?). So there's something screwy about how EX is doing this.

 

Perhaps this happens when a dispute is initiated with EX itself? That seems to be a constant in the threads, and my disputes originated with EQ.

 

It doesn't detract from the fact that, in the case of the two OCs who moved my BK to 08/04, it got moved on all 3 CRs, and IMHO the OCs are the ones who screwed it up.

 

-----

 

As for BK reporting...

 

I can't for the life of me figure out how they think they're getting this done.

 

There is a single field in the record called the "consumer information identifier". Its field description says:

 

"Contains a value that indicates a special condition of the account that applies to the primary consumer.

 

This special condition may be that a bankruptcy was filed, discharged, dismissed or withdrawn; a debt was reaffirmed; or the consumer cannot be located or is now located.

 

The indicator should be reported one time and will be deleted only when the appropriate removal code (Q, S or U) is reported."

 

What it does NOT say is how a BK is placed in historical context. It would work fine if everyone reported everything correctly as it happens, but how does this tell a furnisher how to fix an incorrect BK listing?

 

I might note that the BK may be fixed the first time it is reported, and that it moves because the furnisher keeps re-reporting this flag (which you note they are not supposed to do). But even that doesn't answer all of my issues with it.

 

And the problem with THAT is that the date which the BK is tied to matters for scoring purposes. So the date matters, but there is nothing that specifies how the date is set, or what it should be.

 

I talked to several CSRs at Fair Isaac and asked each of them whether a BK should be reported as of the date of filing or the date of discharge. They all said that this was an optional choice of the date furnisher! When it matters to scoring? How can that be optional?

 

 

 

You possibly also noticed that, when an account is assigned a status code, the list of status codes does not include bankruptcy.

 

I had a LOT of trouble (given the list of possibilities) trying to figure out WHAT status a furnisher would have to put onto a BK account until I read the part you quoted about reporting the status "that represents the status of the account just prior to notification of the bankruptcy". And given that this instruction is buried down in the FAQ section, I'm not too surprised to find people slapping stuff like "120 days late" and "charge off" onto a BK. They're asking themselves "well, I THINK it should say paid or paying as agreed, but that makes no sense, I'll just slap this other code on here".

 

But if it is true that the BK status is the status immediately prior to filing, then there is no way for a BK account to ever get one of the closed/zero statuses that allow people to stop reporting, which makes no sense. On the other hand, it makes no sense to keep reporting it, either.

 

I don't think the CRAs thought BK through very well at all, which doesn't much surprise me (since we're all scum, after all, grrrrr). And is why every OC/CA makes up there own idiosyncratic rules.

[Blonde Italian Princess]

Yay!

 

Madonna mia! Yay indeed! And double yays!

 

Thank you for posting this very informative post.

 

I just wanted to take a moment to say how deeply impressed I am by the level of knowledge I have seen so far here at CB. I am brand new here, so I guess I am still in that "Oh my!" stage, but I have already learned so much.

 

Good research! Back to my coffee....

[pryan67]

what is "correct enough", and where in the FCRA is that term? I believe that it MUST BE 100% correct...it is NOT that difficult....

 

If the historical high balance on your account was $4980, and the report $4992, that's not 100% accurate, but really...

 

They get most fields right, even on bad TLs. Except for CAs, who are probably not given all of the data in the first place. (Which is not an excuse...)

 

well then, I could say "I paid MOST of my bills, so why are you reporting negative items?" Same thing...it's all or none in my opinion

 

 

 

..how tough is it to fill out a form?

 

That's true enough if it is just a question of mapping one piece of data onto another. But read the definition of "Billing Date" above, including the part about "freezing" it. No creditor has a date in their system that corresponds directly to that definition. They have to figure it out, and they have to figure it out correctly. And there are 1000s of creditors, with 100s of different accounting systems. So it's not easy. (Which is ALSO not an excuse...)

 

 

If they can't figure it out, then they shouldn't be reporting at all

 

 

It's also the responsibility of the CRAs to ensure that what's reporting is POSSIBLE...for instance, an account that's reporting IIB with a balance...impossible....one that's reporting a DOLA as 06/01, but an open date of 06/04 and a closed date of 06/03...

 

I agree. And if you can point to a tradeline and say "it is impossible for that TL to be true because it is self-contradictory", I think they HAVE to remove it. But that isn't the case, for the most part. What is there is wrong, but it COULD be true.

 

 

I disagree...MANY TLs are impossible...especially the DOS issues

 

BTW, if an account is in BK but not yet discharged, does it have a balance or not? And if so, is it meaningful? EQ thinks that it is not. EX, TU and Fair Isaac think that it is. You can say that it shouldn't be, but where does it say so?

 

 

I would say it does NOT have a balance during the period between filing and discharge...since it's uncollectable by law...however, should it NOT be discharged, then the balance DOES exist

 

 

we know for a fact that this isn't true 100% of the time...they DO "verify for the hell of it" often...and many people here have letters from the FOI stating that....

 

I'm not going to say the CRAs never do so. But I bet they do so FAR less than people here think. Just because you call up a CRS at a creditor, and they say they have no data and couldn't have verified, does not mean that they DIDN'T verify. That CSR has absolutely nothing to do with the part of the business that does verification. If any company tells you that, without first taking at least two days to research it, I'd say they're full of it.

 

 

 

I know of many times when they "verify" a TL within one day...totally impossible to do properly...also, how many times have they "verified" information using an incorrect address, account number. case number, etc?

 

 

The creditor was screwing up by not reporting it on a month-to-month basis. He is required to continue reporting until the account is closed with a zero balance, and he was not doing so

 

Where is that written in the FCRA?

 

The FCRA says nothing about this. I was referring to the industry data standards. They state that all accounts are to be reported until the account is closed with a zero balance, and that all accounts are to be reported once per report cycle (generally monthly). An unpaid chargeoff is not a zero balance account. The consumer still has a liability they have not honored. They may have initially been charged off six years ago, but they still owe the money TODAY and they are still not paying TODAY. So that's a current negative. People should be glad that most creditors are lazy.

 

Data standards aren't the law....and therefore don't really matter....I don't know how I think a CO should be reported, but if the lender took it as a loss, then they're commiting fraud as far as I'm concerned...if they wrote it off, then they shouldn't be allowed to collect, and reporting is collection activity IMO

 

So, for example, in the month in which it is paid, a paid chargeoff has the same negative effect as an unpaid chargeoff, since they were both negative as of last month. But over time, the paid chargeoff is supposed to get better, because it is supposed to age and the unpaid chargeoff is supposed to remain current. In practice, the paid chargeoff doesn't always age, and the unpaid chargeoff often ages due to lack of reporting, but those are both reporting errors, one detrimental to you and one beneficial to you.

 

That's just the logic of the data standards.