Most Popular Compliance Content
Reporting the date of first delinquency to credit
04/20/2025
My compliance question is regarding Credit/Metro 2 data reporting. We recently made a change in the platform which collects all data to be furnished to the Consumer Reporting Agencies (CRAs) in regards to our entire consumer lending portfolio. Prior to the change that we made (after consulting with developers from the company who provides the platform), when a consumer loan became past due 30days, the date of first delinquency would report as the 30th day past the original due date. Example - payment due 03/20/2025 not paid, the date of first delinquency (DOFD) would be reported as 04/19/2025. After making a change in our platform as to how we count days past due, using the same example as above, if a payment is due 03/20/2025, and although the 30th day would be 04/19/2025, our platform is now reporting the DOFD as 04/30/2025 (the last day of the month). All of our consumer loans and lines of credit have been impacted this way. The third party company [redacted] who develops and maintains our platform insists that we are still compliant with the FCRA in that the DOFD is reporting as the last day of any given month when a loan is 30-59 days past due. We don't feel this is correct, but [redacted] can/will not provide us with any kind of evidence in writing that states we are in compliance with FCRA based on what they are telling us. When a loan becomes 30 days past due mid-month - is it in compliance to report the DOFD as the last day of said month? If so, where can we source information to substantiate this? I have looked throughout the Credit Reporting Resource Guide and cannot find anything supporting this.
Image quality analysis (IQA)
04/13/2025
What is image quality analysis (IQA)?
When to get Compliance involved
04/06/2025
Should we bring in compliance to assist when new or modified products or services are launched? If you do, should we have them come in early on or wait until the end or near the very end to "clean up" mistakes that were made?
Benefits of automated document purging in ECM system
04/06/2025
What are the benefits of automatically purging documents from an ECM system?
Is Disclaimer of Oral Agreements for required?
03/30/2025
Does a Disclaimer of Oral Agreements requirement apply to consumer revolving line of credit loans? I know if the loan amount is over $50K you must give this notice; however, my vendor's loan origination system is not prompting this document. I believe it doesn't apply for a consumer open end credit loan.