Do "Full Factual" reports actually exist?

[cashnocredit]

I've often wondered if the mythical "Full Factual" reports really exist. Sure the laws allow them for jumbo loans and high paid jobs but just because the law allows them doesn't mean the big three provide them. There's a can of worms involved in doing so. If used to make a credit decision on a large loan, they would have to make these special CRs available if you were declined. Further, FICO does not use info only in full factual reports so it can't be automated.

 

Here's the credit expert John Ulzheimer weighing in:

If your credit report is being accessed for a loan of $150,000 or more then none of the seven and ten-year rules are binding. That means the credit bureaus COULD maintain this negative stuff permanently but only for credit reports where you’ve applied for a higher dollar loan. They also have an exemption for credit reports sold for employment screening where the job is expected to pay $75,000 or more. Thankfully the credit bureaus choose to use the seven and ten year guidelines regardless. Whew

 

It's possible that the govt. can pull "full factuals," especially for things like a security clearance but we wouldn't ever know since Inqs for that purpose are not reported to us.

 

In any case, perhaps this will put a stake in the heart of "full factual" myth at least from the normal CRAs.

 

http://www.mint.com/blog/goals/credit-report-statute-of-limitations-05022011/

[hegemony]

they are not a myth. they cost more and many brokers and others don't know what they are which is why they are not used more.

 

CRAs keep a file with everything that has ever been reported to your consumer credit report; even items deleted and copies of any correspondence you've had with the CRAs.

[cashnocredit]

they are not a myth. they cost more and many brokers and others don't know what they are which is why they are not used more.

 

CRAs keep a file with everything that has ever been reported to your consumer credit report; even items deleted and copies of any correspondence you've had with the CRAs.

 

There is no doubt that CRAs keep everything that enters their maws and there are good reasons why they need to. That doesn't mean the information is sold. While they are clearly allowed to sell files with no reporting SOLs in exempted cases, John Ulzheimer goes out of his way to point out they (the standard credit CRAs) chose not to. Is he simply wrong? John is widely regarded as an expert on Scores and CRAs.

 

Now one can, on their own, or through hiring a specialized firm like Kroll, access old public records but that's not the same as getting them from the standard CRAs.

 

So Hedge, how 'bout some links?

[Scribe70]

I've often wondered if the mythical "Full Factual" reports really exist. Sure the laws allow them for jumbo loans and high paid jobs but just because the law allows them doesn't mean the big three provide them. There's a can of worms involved in doing so. If used to make a credit decision on a large loan, they would have to make these special CRs available if you were declined. Further, FICO does not use info only in full factual reports so it can't be automated.

 

Here's the credit expert John Ulzheimer weighing in:

If your credit report is being accessed for a loan of $150,000 or more then none of the seven and ten-year rules are binding. That means the credit bureaus COULD maintain this negative stuff permanently but only for credit reports where you've applied for a higher dollar loan. They also have an exemption for credit reports sold for employment screening where the job is expected to pay $75,000 or more. Thankfully the credit bureaus choose to use the seven and ten year guidelines regardless. Whew

 

It's possible that the govt. can pull "full factuals," especially for things like a security clearance but we wouldn't ever know since Inqs for that purpose are not reported to us.

 

In any case, perhaps this will put a stake in the heart of "full factual" myth at least from the normal CRAs.

 

http://www.mint.com/...tions-05022011/

 

Good info, but he is wrong about the tax liens, I got two federal tax liens that "self released" that were not renewed off my reports, it is tricky but it can be done.

 

 

 

[LKH]

they are not a myth. they cost more and many brokers and others don't know what they are which is why they are not used more.

 

CRAs keep a file with everything that has ever been reported to your consumer credit report; even items deleted and copies of any correspondence you've had with the CRAs.

 

There is no doubt that CRAs keep everything that enters their maws and there are good reasons why they need to. That doesn't mean the information is sold. While they are clearly allowed to sell files with no reporting SOLs in exempted cases, John Ulzheimer goes out of his way to point out they (the standard credit CRAs) chose not to. Is he simply wrong? John is widely regarded as an expert on Scores and CRAs.

 

Now one can, on their own, or through hiring a specialized firm like Kroll, access old public records but that's not the same as getting them from the standard CRAs.

 

So Hedge, how 'bout some links?

 

 

He is definitely wrong about at least some of things he stated. In the link provided, he says bk 13's report for 10 from date of discharge. Very, very wrong.

BK 13's do NOT report for 7 years from date of discharge. If that were the case, B K13's could report for 10, 11, 12, years or more depending on how long it takes to fulfill the terms of the BK. That is definitely not accurate.

 

 

From the CRA's:

 

 

 

https://help.equifax...4/noIntercept/1

 

How long do you keep my credit information?

The length of time information remains in your credit file is shown below:

 

Credit Accounts

 

Accounts paid as agreed remain on file for up to 10 years from the date of last activity

Accounts not paid as agreed remain on file for seven years from the date of last activity

Collection Accounts

 

Remain on file for seven years from the date of last activity

Public Records

 

Judgments remain on file for seven years from the date filed, whether satisfied (paid) or not

Paid tax liens remain on file for seven years from the date released (paid)

Unpaid tax liens remain on file indefinitely

Bankruptcy

- Chapters 7, 11, and non-discharged or dismissed chapters 12 and 13 remain on file for 10 years from the date filed

- Discharged chapters 12 and 13 remain on file for seven years from the date filed

New York State Residents Only (must be current resident)

 

Satisfied judgments remain five years from the date filed

Paid collections remain five years from the date of last activity

All other purge rules as noted above apply

California State Residents Only (must be current resident)

 

Paid or released tax liens remain on file seven years from the date released or 10 years from the date file

Unpaid or unreleased tax liens remain 10 years from the file date

All consumer-initiated inquiries for the purpose of obtaining a loan and/or benefit remain on the file for two years

All other purge rules as noted above apply

 

 

 

http://www.experian....o-10-years.html

 

Bankruptcy remains on your credit report for up to 10 years

Dear Experian,

 

How long does a bankruptcy stay on your report? It has been almost six years and I am still denied credit on that basis alone.

 

- LBE

 

Dear LBE,

 

Bankruptcy is sometimes represented as an easy way out of bad debt, but as you've discovered, that is not the case. While you may be free of your past credit obligations, you also will find it very difficult to obtain new credit, and possibly for a very long time.

 

A chapter 7 bankruptcy filing remains on your credit report for 10years. Chapter 13 bankruptcy remains for seven years. Under chapter 13 bankruptcy you repay at least a portion of the debt, so it is removed a little sooner.

 

When the economy was strong, the further in the past the bankruptcy filing occurred, the less impact it had on your ability to obtain credit. Depending on the type of credit, you might have qualified for new credit in a few months or a few years. But just getting credit wasn't the whole story.

 

While you might have been able to get a credit account, it usually came with high fees, interest rates, or both. Rarely was the credit you could get the kind of credit you would want.

 

In today's difficult economy, many lenders will not grant credit at all while the bankruptcy filing appears on your credit report. That means you might have to wait seven or even 10 years before you will be able to get credit.

 

Unfortunately, the number of people who will file bankruptcy a second time is fairly high. To lenders, that means there is a relatively high risk that a person who has filed bankruptcy in the recent past could file again in the near future, which means the lender would not get repaid.

 

In a strong economy, lenders are more willing to take that risk. But when the economy is struggling, as it is now, lenders might not be willing to take that risk at all.

[cashnocredit]

Getting back toe the "full facts" myth.

 

Here's another reason. The FACT act says this:

 

§ 609. Disclosures to consumers [15 U.S.C. § 1681g]

(a) Information on file; sources; report recipients. Every consumer reporting agency shall,

upon request, and subject to 610(a)(1) [§ 1681h], clearly and accurately disclose to

the consumer:

(1) All information in the consumer's file at the time of the request...

 

Note. So it appears that the CRAs would have to disclose items that are past reporting SOL in the consumer disclosures if they are disclosed under "full factual" exemptions.

 

Obviously boutique CRAs like LN could acquire old public records, merge them with other info, and disclose them for exempt permissable purposes but they also are obligated to disclose this extended info to consumers upon request.

[hegemony]

 

So Hedge, how 'bout some links?

from the FCRA:

§ 1681c

The provisions of paragraphs (1) through (5) of subsection (a) of this section are not applicable in the case of any consumer credit report to be used in connection with—

(1) a credit transaction involving, or which may reasonably be expected to involve, a principal amount of $150,000 or more;

(2) the underwriting of life insurance involving, or which may reasonably be expected to involve, a face amount of $150,000 or more; or

(3) the employment of any individual at an annual salary which equals, or which may reasonably be expected to equal $75,000, or more.

 

You can search RMCR (Residential Mortgage Credit Report) to learn more about such credit products, which IIRC have been defined in law or regs since the late 1980s using the term RMCR.

 

Items older than the standard reporting period, it should be noted, are excluded from FICO calculations. Perhaps JU was referencing this aspect.

[cashnocredit]

 

So Hedge, how 'bout some links?

from the FCRA:

§ 1681c

The provisions of paragraphs (1) through (5) of subsection (a) of this section are not applicable in the case of any consumer credit report to be used in connection with—

(1) a credit transaction involving, or which may reasonably be expected to involve, a principal amount of $150,000 or more;

(2) the underwriting of life insurance involving, or which may reasonably be expected to involve, a face amount of $150,000 or more; or

(3) the employment of any individual at an annual salary which equals, or which may reasonably be expected to equal $75,000, or more.

 

You can search RMCR (Residential Mortgage Credit Report) to learn more about such credit products, which IIRC have been defined in law or regs since the late 1980s using the term RMCR.

 

Items older than the standard reporting period, it should be noted, are excluded from FICO calculations. Perhaps JU was referencing this aspect.

 

 

Hedge, there is no question CRAs are allowed to retain and disclose older information. But nothing requires that they do so. Further the FCRA requires that they disclose to consumers upon request all information and then some that they provide to credit grantors, exempt or not. Since old stuff doesn't show up in my CR they can't disclose it to an exempt credit grantor. That's the law as I read it.

[LKH]

So Hedge, how 'bout some links?

from the FCRA:

§ 1681c

The provisions of paragraphs (1) through (5) of subsection (a) of this section are not applicable in the case of any consumer credit report to be used in connection with

(1) a credit transaction involving, or which may reasonably be expected to involve, a principal amount of $150,000 or more;

(2) the underwriting of life insurance involving, or which may reasonably be expected to involve, a face amount of $150,000 or more; or

(3) the employment of any individual at an annual salary which equals, or which may reasonably be expected to equal $75,000, or more.

 

You can search RMCR (Residential Mortgage Credit Report) to learn more about such credit products, which IIRC have been defined in law or regs since the late 1980s using the term RMCR.

 

Items older than the standard reporting period, it should be noted, are excluded from FICO calculations. Perhaps JU was referencing this aspect.

 

 

Hedge, there is no question CRAs are allowed to retain and disclose older information. But nothing requires that they do so. Further the FCRA requires that they disclose to consumers upon request all information and then some that they provide to credit grantors, exempt or not. Since old stuff doesn't show up in my CR they can't disclose it to an exempt credit grantor. That's the law as I read it.

 

 

When they send you a REPORT, they are including everything in that REPORT. When they provide a full factual, they are providing everything in your FILE. A report and a file are 2 different things. A credit report is only part of what is contained in your FILE.

[Joe1099]

Is it possible to review your entire credit file....not just the report?

[ama]

So Hedge, how 'bout some links?

from the FCRA:

§ 1681c

The provisions of paragraphs (1) through (5) of subsection (a) of this section are not applicable in the case of any consumer credit report to be used in connection with—

(1) a credit transaction involving, or which may reasonably be expected to involve, a principal amount of $150,000 or more;

(2) the underwriting of life insurance involving, or which may reasonably be expected to involve, a face amount of $150,000 or more; or

(3) the employment of any individual at an annual salary which equals, or which may reasonably be expected to equal $75,000, or more.

 

You can search RMCR (Residential Mortgage Credit Report) to learn more about such credit products, which IIRC have been defined in law or regs since the late 1980s using the term RMCR.

 

Items older than the standard reporting period, it should be noted, are excluded from FICO calculations. Perhaps JU was referencing this aspect.

 

 

Hedge, there is no question CRAs are allowed to retain and disclose older information. But nothing requires that they do so. Further the FCRA requires that they disclose to consumers upon request all information and then some that they provide to credit grantors, exempt or not. Since old stuff doesn't show up in my CR they can't disclose it to an exempt credit grantor. That's the law as I read it.

 

 

When they send you a REPORT, they are including everything in that REPORT. When they provide a full factual, they are providing everything in your FILE. A report and a file are 2 different things. A credit report is only part of what is contained in your FILE.

 

 

LKH, an above quote from the credit laws referenced info in one's FILE, not info in a specific REPORT. So, if the law says FILE, would this supersede REPORT and mean they'd have to make everything available to us if we know to request the full FILE?

Edited August 29, 2011 by ama

[cashnocredit]

When they send you a REPORT, they are including everything in that REPORT. When they provide a full factual, they are providing everything in your FILE. A report and a file are 2 different things. A credit report is only part of what is contained in your FILE.

 

CRAs are allowed to do things they choose not to do. Providing out of reporting SOL credit info seems to be one of the things they choose not to do. Here's why: The FCRA requires CRAs to provide everything in your consumer file that it reports to ANY creditor and some stuff that it reports to NO creditor. I quoted the section. Why do you believe that the FCRA provision allowing them to report older info - which they are only allowed to do for high value credit but are not required to do - somehow exempts them from providing that same information to a consumer upon request under the rules of consumer discloser.

 

I do not think this from the FCRA:

All information in the consumer's file at the time of the request.

could be any clearer.

Edited August 29, 2011 by cashnocredit

[LKH]

When they send you a REPORT, they are including everything in that REPORT. When they provide a full factual, they are providing everything in your FILE. A report and a file are 2 different things. A credit report is only part of what is contained in your FILE.

 

CRAs are allowed to do things they choose not to do. Providing out of reporting SOL credit info seems to be one of the things they choose not to do. Here's why: The FCRA requires CRAs to provide everything in your consumer file that it reports to ANY creditor and some stuff that it reports to NO creditor. I quoted the section. Why do you believe that the FCRA provision allowing them to report older info - which they are only allowed to do for high value credit but are not required to do - somehow exempts them from providing that same information to a consumer upon request under the rules of consumer discloser.

 

You are putting words in my mouth. I never said it exempts them from anything. IF they provide a full factual to some entity, IMO, they would be required to provide the same to you if you requested such.

[cashnocredit]

Is it possible to review your entire credit file....not just the report?

 

You are actually allowed to visit them to see the file information. Don't know anyone who has.

[cashnocredit]

You are putting words in my mouth. I never said it exempts them from anything. IF they provide a full factual to some entity, IMO, they would be required to provide the same to you if you requested such.

 

Ok, I don't wish to do that. Let's narrow it down. If you request a credit report, which you may have to pay a nominal fee for, it is supposed to include all information in your file. So yes, I agree with the above statement. And, since they do not provide this when I buy a file direct from the CRA I can reasonably assume they do not provide this to someone else.

 

EtoA:

Unless they are violating the law. I don't believe they are. I think full fact's providers like Kroll get the info elsewhere and add it to the CRA's stuff.

Edited August 29, 2011 by cashnocredit

[LKH]

You are putting words in my mouth. I never said it exempts them from anything. IF they provide a full factual to some entity, IMO, they would be required to provide the same to you if you requested such.

 

Ok, I don't wish to do that. Let's narrow it down. If you request a credit report, which you may have to pay a nominal fee for, it is supposed to include all information in your file. So yes, I agree with the above statement. And, since they do not provide this when I buy a file direct from the CRA I can reasonably assume they do not provide this to someone else.

 

EtoA:

Unless they are violating the law. I don't believe they are. I think full fact's providers like Kroll get the info elsewhere and add it to the CRA's stuff.

 

 

When you order your report, it is to include everything in it going back 7 years with a few exceptions for bk's and liens etc. In a full factual, they go back probably to day one of your existence in their system. If a creditor orders a report, by law, they should not be getting anything above a beyond what you get. You should be getting more info than they do as soft inq's are not provided creditors. If a creditor gets something in a report that you don't, I would think you would have a cause for a lawsuit.

[cashnocredit]

You are putting words in my mouth. I never said it exempts them from anything. IF they provide a full factual to some entity, IMO, they would be required to provide the same to you if you requested such.

 

Ok, I don't wish to do that. Let's narrow it down. If you request a credit report, which you may have to pay a nominal fee for, it is supposed to include all information in your file. So yes, I agree with the above statement. And, since they do not provide this when I buy a file direct from the CRA I can reasonably assume they do not provide this to someone else.

 

EtoA:

Unless they are violating the law. I don't believe they are. I think full fact's providers like Kroll get the info elsewhere and add it to the CRA's stuff.

 

 

When you order your report, it is to include everything in it going back 7 years with a few exceptions for bk's and liens etc. In a full factual, they go back probably to day one of your existence in their system. If a creditor orders a report, by law, they should not be getting anything above a beyond what you get. You should be getting more info than they do as soft inq's are not provided creditors. If a creditor gets something in a report that you don't, I would think you would have a cause for a lawsuit.

 

The limitation only applies to credit reports delivered to certain creditors. There is absolutely nothing in the FCRA that allows this limitation to consumers that get their credit diclosures directly from the CRA. Third parties are allows do filter whatever they want, but not the CRA.

[LKH]

You are putting words in my mouth. I never said it exempts them from anything. IF they provide a full factual to some entity, IMO, they would be required to provide the same to you if you requested such.

 

Ok, I don't wish to do that. Let's narrow it down. If you request a credit report, which you may have to pay a nominal fee for, it is supposed to include all information in your file. So yes, I agree with the above statement. And, since they do not provide this when I buy a file direct from the CRA I can reasonably assume they do not provide this to someone else.

 

EtoA:

Unless they are violating the law. I don't believe they are. I think full fact's providers like Kroll get the info elsewhere and add it to the CRA's stuff.

 

 

When you order your report, it is to include everything in it going back 7 years with a few exceptions for bk's and liens etc. In a full factual, they go back probably to day one of your existence in their system. If a creditor orders a report, by law, they should not be getting anything above a beyond what you get. You should be getting more info than they do as soft inq's are not provided creditors. If a creditor gets something in a report that you don't, I would think you would have a cause for a lawsuit.

 

The limitation only applies to credit reports delivered to certain creditors. There is absolutely nothing in the FCRA that allows this limitation to consumers that get their credit diclosures directly from the CRA. Third parties are allows do filter whatever they want, but not the CRA.

 

What limitation? If you know all of the answers why did you ask?

[hegemony]

Someone should page JU since he clearly was not saying FF reports do not exist. From the rest of the story it seems clear he is only talking about standard, garden variety consumer credit reports.

[cashnocredit]

Someone should page JU since he clearly was not saying FF reports do not exist. From the rest of the story it seems clear he is only talking about standard, garden variety consumer credit reports.

Right, he is talking about the standard CRAs, not the value added Krolls of the world. No one is saying Full Fact reports don't exist, just that they aren'r provided by the usual suspects. What JU is saying is this:

If your credit report is being accessed for a loan of $150,000 or more then none of the seven and ten-year rules are binding. That means the credit bureaus COULD maintain this negative stuff permanently but only for credit reports where you’ve applied for a higher dollar loan. They also have an exemption for credit reports sold for employment screening where the job is expected to pay $75,000 or more. Thankfully the credit bureaus choose to use the seven and ten year guidelines regardless. Whew.

He is talking about the standard CRAs, not Kroll Or LN. The extant question is whether the bg 3(or 4) CRAs provide them to creditors for loans > 150k or jobs > 75k/y. I don't see any way you can read JU's statement other than that they do not. And not because they are prohibited, but because they choose not to. By choosing not to provide that they also are not obligated to provide it to the consumer which the FCRA would have required.

[cashnocredit]

You are putting words in my mouth. I never said it exempts them from anything. IF they provide a full factual to some entity, IMO, they would be required to provide the same to you if you requested such.

 

Ok, I don't wish to do that. Let's narrow it down. If you request a credit report, which you may have to pay a nominal fee for, it is supposed to include all information in your file. So yes, I agree with the above statement. And, since they do not provide this when I buy a file direct from the CRA I can reasonably assume they do not provide this to someone else.

 

EtoA:

Unless they are violating the law. I don't believe they are. I think full fact's providers like Kroll get the info elsewhere and add it to the CRA's stuff.

 

 

When you order your report, it is to include everything in it going back 7 years with a few exceptions for bk's and liens etc. In a full factual, they go back probably to day one of your existence in their system. If a creditor orders a report, by law, they should not be getting anything above a beyond what you get. You should be getting more info than they do as soft inq's are not provided creditors. If a creditor gets something in a report that you don't, I would think you would have a cause for a lawsuit.

 

The limitation only applies to credit reports delivered to certain creditors. There is absolutely nothing in the FCRA that allows this limitation to consumers that get their credit diclosures directly from the CRA. Third parties are allows do filter whatever they want, but not the CRA.

 

What limitation? If you know all of the answers why did you ask?

The "limitation" is the assorted reporting SOLs for loans under $150k.

 

As for knowing all the answers, I posted the question because I didn't and I had run across JU's column. I have since re-read the FCRA and it clearly states consumer disclosures must be complete disclosures and does not selectively limit consumer disclosures. It makes me more convinced JU is correct about this.

[Lian]

The FCRA places no restrictions or requirements on what a commercial vendor of credit reports must include in any credit report they provide. When you order and receive a commercial credit report, there is no assurance that it is a complete representation of your credit file.

No one orders a complete credit file. Your complete credit file include tons and tons of information under various segments, field codes, and special comments, much of which is stored by the CRA in what is called Metro 2 format, and is unreadable to the average consumer. It is close to a binary code.

In recognition of this fact, congress provided section 609(a)(1)(A), which unequivoclly gives any consumer the right to "All information in the consumer's file at the time of the request" except for a few esoteric items, such as information related to their credit scoring of your file. Of course, the CRAs dont just send you "all information" in your credit file upon request, but take the reasonable approach that if you identify the specific information requested, and of course, submit the fee required under section 612(f), they have complied with section 609(a)(1). The CRAs have a statutory requirement to provide information that you clearly identify, and it is NOT discretionary on their part.

 

As to providing a "full factual" credit report, again, the FCRA places no requirements on the CRAs, other than section 609(a)(1), on what IS included. The so-called "full factual" credit reports are not a requirement on providing full content, but merely remove their normal prohibiton as to certain adverse items of information. Section 605( provides for an exemption from their normal bar against including those adverse items of information specified in section 605(a) in credit reports they issue after the relevant date of exclusion has expired. As has been stated, those exemptions are limited to ONLY those items set forth in section 605(, such as high principal loans and inquires relating to employment for income above the specified level. It does not relate to any information other than the adverse items of information specified in section 605(a), and is not a basis for requiring the CRA to include everything in your credit file. It just cannot omit those adverse item due to a normal section 605(a) prohibition.

[LKH]

You are putting words in my mouth. I never said it exempts them from anything. IF they provide a full factual to some entity, IMO, they would be required to provide the same to you if you requested such.

 

Ok, I don't wish to do that. Let's narrow it down. If you request a credit report, which you may have to pay a nominal fee for, it is supposed to include all information in your file. So yes, I agree with the above statement. And, since they do not provide this when I buy a file direct from the CRA I can reasonably assume they do not provide this to someone else.

 

EtoA:

Unless they are violating the law. I don't believe they are. I think full fact's providers like Kroll get the info elsewhere and add it to the CRA's stuff.

 

 

When you order your report, it is to include everything in it going back 7 years with a few exceptions for bk's and liens etc. In a full factual, they go back probably to day one of your existence in their system. If a creditor orders a report, by law, they should not be getting anything above a beyond what you get. You should be getting more info than they do as soft inq's are not provided creditors. If a creditor gets something in a report that you don't, I would think you would have a cause for a lawsuit.

 

The limitation only applies to credit reports delivered to certain creditors. There is absolutely nothing in the FCRA that allows this limitation to consumers that get their credit diclosures directly from the CRA. Third parties are allows do filter whatever they want, but not the CRA.

 

What limitation? If you know all of the answers why did you ask?

The "limitation" is the assorted reporting SOLs for loans under $150k.

 

As for knowing all the answers, I posted the question because I didn't and I had run across JU's column. I have since re-read the FCRA and it clearly states consumer disclosures must be complete disclosures and does not selectively limit consumer disclosures. It makes me more convinced JU is correct about this.

 

 

If you are happy with what you believe, that's all that matters. Keep in mind however, that JU made several statements that were inaccurate, at best.

[cashnocredit]

The FCRA places no restrictions or requirements on what a commercial vendor of credit reports must include in any credit report they provide. When you order and receive a commercial credit report, there is no assurance that it is a complete representation of your credit file.

No one orders a complete credit file. Your complete credit file include tons and tons of information under various segments, field codes, and special comments, much of which is stored by the CRA in what is called Metro 2 format, and is unreadable to the average consumer. It is close to a binary code.

In recognition of this fact, congress provided section 609(a)(1)(A), which unequivoclly gives any consumer the right to "All information in the consumer's file at the time of the request" except for a few esoteric items, such as information related to their credit scoring of your file. Of course, the CRAs dont just send you "all information" in your credit file upon request, but take the reasonable approach that if you identify the specific information requested, and of course, submit the fee required under section 612(f), they have complied with section 609(a)(1). The CRAs have a statutory requirement to provide information that you clearly identify, and it is NOT discretionary on their part.

 

As to providing a "full factual" credit report, again, the FCRA places no requirements on the CRAs, other than section 609(a)(1), on what IS included. The so-called "full factual" credit reports are not a requirement on providing full content, but merely remove their normal prohibiton as to certain adverse items of information. Section 605( provides for an exemption from their normal bar against including those adverse items of information specified in section 605(a) in credit reports they issue after the relevant date of exclusion has expired. As has been stated, those exemptions are limited to ONLY those items set forth in section 605(, such as high principal loans and inquires relating to employment for income above the specified level. It does not relate to any information other than the adverse items of information specified in section 605(a), and is not a basis for requiring the CRA to include everything in your credit file. It just cannot omit those adverse item due to a normal section 605(a) prohibition.

Clearly the raw database files are close to useless and congress' intent was for the CRAs to put the information in an organized, human readable form and that providing this satisfies 609. Also, you note that "full factual" is a poor label as it only adds adverse information listed in 605(a) and, for instance, does not permit CRAs to report the full range of credit inquiries recorded in the file.

 

However, if the consumer identifies specific information that would not normally be provided and pays the fee, then the CRA is required to provide that information as well. For instance identifying a withdrawn lien which is in the database but would not show up on either a "full facts" or standard credit pull.

 

It seems to me that any negative information that is provided on a 605(b ) pull to credit grantors should be also provided on a standard 609 consumer disclosure unless CRAs take a rather myopic view as to what the meaning of section 609's ("all") is.

 

That said, a paid, written request for a credit report specifically requesting inclusion of all information that would be included under the section 605(b ) exemption should do the job if that data is available on a 605(b ) pull.

 

Again, JU states the CRAs do not provide 605(b ) exempted data to creditors though he also states they certainly have the right to do so if they meat the exmption requirements.

[cashnocredit]

If you are happy with what you believe, that's all that matters. Keep in mind however, that JU made several statements that were inaccurate, at best.

 

No, it's not. What matters is what the facts are as to what CRA's really do. It's a very relevant question as to whether they provide out of SOL adverse info on a full facts pull or not. So far we have JU's clear statement that they don't. Sure he may be wrong about this but it seems consistent with section 609 of the FCRA and the only contrary evidence presented so far consists of agregators that combine the normal CRA info with other info they dig up elsewhere.

 

While I currently believe the JU is correct I will only be happy when I know for certain. I would be just as happy to be wrong as right. It's only my current belief based on what I've seen so far and is subject to change.