Appendix A to Part 660 - Interagency Guidelines Concerning the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies
16:1.0.1.6.76.0.39.5.56 : Appendix A
Appendix A to Part 660 - Interagency Guidelines Concerning the
Accuracy and Integrity of Information Furnished to Consumer
Reporting Agencies
The Commission encourages voluntary furnishing of information to
consumer reporting agencies. Section 660.3 of this part requires
each furnisher to establish and implement reasonable written
policies and procedures concerning the accuracy and integrity of
the information it furnishes to consumer reporting agencies. Under
§ 660.3(b), a furnisher must consider the guidelines set forth
below in developing its policies and procedures. In establishing
these policies and procedures, a furnisher may include any of its
existing policies and procedures that are relevant and appropriate.
Section 660.3(c) requires each furnisher to review its policies and
procedures periodically and update them as necessary to ensure
their continued effectiveness.
I. Nature, Scope, and Objectives of Policies and Procedures
(a) Nature and Scope. Section 660.3(a) of this part
requires that a furnisher's policies and procedures be appropriate
to the nature, size, complexity, and scope of the furnisher's
activities. In developing its policies and procedures, a furnisher
should consider, for example:
(1) The types of business activities in which the furnisher
engages;
(2) The nature and frequency of the information the furnisher
provides to consumer reporting agencies; and
(3) The technology used by the furnisher to furnish information
to consumer reporting agencies.
(b) Objectives. A furnisher's policies and procedures
should be reasonably designed to promote the following
objectives:
(1) To furnish information about accounts or other relationships
with a consumer that is accurate, such that the furnished
information:
(i) Identifies the appropriate consumer;
(ii) Reflects the terms of and liability for those accounts or
other relationships; and
(iii) Reflects the consumer's performance and other conduct with
respect to the account or other relationship;
(2) To furnish information about accounts or other relationships
with a consumer that has integrity, such that the furnished
information:
(i) Is substantiated by the furnisher's records at the time it
is furnished;
(ii) Is furnished in a form and manner that is designed to
minimize the likelihood that the information may be incorrectly
reflected in a consumer report; thus, the furnished information
should:
(A) Include appropriate identifying information about the
consumer to whom it pertains; and
(B) Be furnished in a standardized and clearly understandable
form and manner and with a date specifying the time period to which
the information pertains; and
(iii) Includes the credit limit, if applicable and in the
furnisher's possession;
(3) To conduct reasonable investigations of consumer disputes
and take appropriate actions based on the outcome of such
investigations; and
(4) To update the information it furnishes as necessary to
reflect the current status of the consumer's account or other
relationship, including, for example:
(i) Any transfer of an account (e.g., by sale or
assignment for collection) to a third party; and
(ii) Any cure of the consumer's failure to abide by the terms of
the account or other relationship.
II. Establishing and Implementing Policies and Procedures
In establishing and implementing its policies and procedures, a
furnisher should:
(a) Identify practices or activities of the furnisher that can
compromise the accuracy or integrity of information furnished to
consumer reporting agencies, such as by:
(1) Reviewing its existing practices and activities, including
the technological means and other methods it uses to furnish
information to consumer reporting agencies and the frequency and
timing of its furnishing of information;
(2) Reviewing its historical records relating to accuracy or
integrity or to disputes; reviewing other information relating to
the accuracy or integrity of information provided by the furnisher
to consumer reporting agencies; and considering the types of
errors, omissions, or other problems that may have affected the
accuracy or integrity of information it has furnished about
consumers to consumer reporting agencies;
(3) Considering any feedback received from consumer reporting
agencies, consumers, or other appropriate parties;
(4) Obtaining feedback from the furnisher's staff; and
(5) Considering the potential impact of the furnisher's policies
and procedures on consumers.
(b) Evaluate the effectiveness of existing policies and
procedures of the furnisher regarding the accuracy and integrity of
information furnished to consumer reporting agencies; consider
whether new, additional, or different policies and procedures are
necessary; and consider whether implementation of existing policies
and procedures should be modified to enhance the accuracy and
integrity of information about consumers furnished to consumer
reporting agencies.
(c) Evaluate the effectiveness of specific methods (including
technological means) the furnisher uses to provide information to
consumer reporting agencies; how those methods may affect the
accuracy and integrity of the information it provides to consumer
reporting agencies; and whether new, additional, or different
methods (including technological means) should be used to provide
information to consumer reporting agencies to enhance the accuracy
and integrity of that information.
III. Specific Components of Policies and Procedures
In developing its policies and procedures, a furnisher should
address the following, as appropriate:
(a) Establishing and implementing a system for furnishing
information about consumers to consumer reporting agencies that is
appropriate to the nature, size, complexity, and scope of the
furnisher's business operations.
(b) Using standard data reporting formats and standard
procedures for compiling and furnishing data, where feasible, such
as the electronic transmission of information about consumers to
consumer reporting agencies.
(c) Maintaining records for a reasonable period of time, not
less than any applicable recordkeeping requirement, in order to
substantiate the accuracy of any information about consumers it
furnishes that is subject to a direct dispute.
(d) Establishing and implementing appropriate internal controls
regarding the accuracy and integrity of information about consumers
furnished to consumer reporting agencies, such as by implementing
standard procedures and verifying random samples of information
provided to consumer reporting agencies.
(e) Training staff that participates in activities related to
the furnishing of information about consumers to consumer reporting
agencies to implement the policies and procedures.
(f) Providing for appropriate and effective oversight of
relevant service providers whose activities may affect the accuracy
or integrity of information about consumers furnished to consumer
reporting agencies to ensure compliance with the policies and
procedures.
(g) Furnishing information about consumers to consumer reporting
agencies following mergers, portfolio acquisitions or sales, or
other acquisitions or transfers of accounts or other obligations in
a manner that prevents re-aging of information, duplicative
reporting, or other problems that may similarly affect the accuracy
or integrity of the information furnished.
(h) Deleting, updating, and correcting information in the
furnisher's records, as appropriate, to avoid furnishing inaccurate
information.
(i) Conducting reasonable investigations of disputes.
(j) Designing technological and other means of communication
with consumer reporting agencies to prevent duplicative reporting
of accounts, erroneous association of information with the wrong
consumer(s), and other occurrences that may compromise the accuracy
or integrity of information provided to consumer reporting
agencies.
(k) Providing consumer reporting agencies with sufficient
identifying information in the furnisher's possession about each
consumer about whom information is furnished to enable the consumer
reporting agency properly to identify the consumer.
(l) Conducting a periodic evaluation of its own practices,
consumer reporting agency practices of which the furnisher is
aware, investigations of disputed information, corrections of
inaccurate information, means of communication, and other factors
that may affect the accuracy or integrity of information furnished
to consumer reporting agencies.
(m) Complying with applicable requirements under the Fair Credit
Reporting Act and its implementing regulations.