I've been thrown into a situation and I'm not sure where to start with it.

Are institutions required to report any certain type of loan?
For example, we've recently gone through an acquisition and the bank we purchased, they did not report on Consumer Lot Loans. Is there any kind of requirement that would make them do that or cause us to have to begin reporting on those?

Not really, but if you report one loan in a certain category as an institution, you have to report them all.

What if they reported lot loans up until a certain time and then stopped across the board.

Example: Lot Loans were reported until 5/31/2019. Effective June 1, 2019, they elected to stop reporting any new lot loan across the board.

Would we still fall into a situation where we had to go back and report all of those loans since 5/31/19?

If you do start reporting them, would you not be reporting their history anyway in your credit bureau data submission?

We don't want to report those loans.
But it appears as though at one point, those loan types were reported but in 2019, the bank made the decision to stop reporting those loan types going forward.

Loans originated before May 31, 2019 were reported.
Loans originated on or after June 1, 2019 were not reported.

Therefore, do we have to go back and report those after June 1?

Do you report all of your lot loans now that you make or did you not make any and all you have is this purchased portfolio? If you are reporting your lot loans, why do you not want to report the purchased loans. I guess I am not understanding the issue. . .

We report all of them that originate now.

BUT, the bank we purchased stopped reporting those types of new loans between 2019 and the day we purchased them 10/23/2023. It was a change they decided to make to reduce their reporting to a small pool of loan types.



We have a customer that is saying the bank we purchased should have reported his lot loan. It originated in 2019 and paid off in 2021. He's wanting us to go back and report that history - even though it is now paid off. If it was that bank's practice at the time to not report, then I wouldn't think we would be responsible for going back and reporting this loan.
If it were open and active now, then yes, we would be reporting it because we report all consumer loans.

You are correct. You are actually under no obligation to the borrower to report any loan to a credit bureau. Regulatory wise, you have to make sure that you fairly report, if you are reporting. Unfair/inconsistent reporting among a class of loans could be considered a fair lending issue on the servicing side of the loan or violate the data integrity regulations (Appendix E to Part 1022).