Even though you’re familiar with Metro 2^® files, do you find accurate furnishing overwhelming? In this article, I’ll explain where to proactively focus so that you can maintain accurate Metro 2^® records and avoid causing harm to your consumers.

In addition to protecting consumers, accurate furnishing helps you avoid unwanted regulatory scrutiny from increased consumer complaints and credit reporting disputes. Regulation V requires that furnishers establish and implement reasonable written documentation regarding the accuracy and integrity of consumer information furnished to Consumer Reporting Companies (CRCs). In fact, the CFPB’s Spring 2022 Supervisory Highlights cites this violation: “In reviews of credit card furnishers, examiners found furnishers’ policies and procedures had failed to specify how particular data fields, such as the date of first delinquency, should be populated when furnishing information about credit card accounts.”

As a credit data furnisher, it’s your responsibility to ensure accurate furnishing to CRCs, including that generated by your third-party processors. You need a clear understanding of how well your systems of record map to your Metro 2^® files and the ability to generate the right documentation to support them.

These key activities will help you maintain accuracy and control of your Metro 2® files

As a senior executive in consumer reporting operations, I have clients focus on three foundational data furnishing accuracy and control activities. First, we conduct a deep review of the Metro 2^® furnishing file that is submitted to the CRCs. Then we develop a detailed data mapping and conversion document to examine the system of record code that produces the file. Finally, we examine the organization’s upstream operational processes to identify trigger events and data that affect the file.

Examining Metro 2® files for accuracy: Four areas

Proactively focus on improving furnishing accuracy in these areas: your system of record’s limitations for compliant reporting, internal logic in your system of record that inadvertently causes inaccuracies, inconsistencies among correlated fields and missing or inaccurate values in the fields.

To avoid inaccuracies and potential regulatory red flags, review the activities below. Remember that these reviews also apply to data generated by your third-party processors.

1. Examine your system for limitations that may hinder data compliance, including:

• Inability to generate certain Metro 2^® file segments

• Limited capture / storage of information (e.g., 6 months versus 7 years)

• Reporting of delinquent accounts for greater than 7 years beyond the Date of First Delinquency

• Consolidation of data elements into one field requiring manual parsing (Surname, First Name, Middle Name)

• Missing logic required to report Metro 2^® fields (e.g., reporting spaces instead of the appropriate Generation Code)

• Not flagging required Metro 2^® fields as mandatory (e.g., Social Security Number)

2. Review logic that could result in inaccurate reporting, including:

• Inaccurately counting days past due for account status assignment

• Lacking logic to report “Last Good Payment” date after a payment reversal due to NSF

• Mass overwriting of dates (e.g., Date of Account Information)

• Missing best practice controls (e.g., if account is current and in bankruptcy, Date of First Delinquency should not be blank)

• Reporting the most recent Actual Payment Amount value rather than totaling all payments receiving during the reporting period

3. Address inconsistencies among correlated fields, including:

• Failure to update all relevant downstream data elements when manually overriding Metro 2^® fields (e.g., Account Status)

• Inaccurate or incomplete reporting when an account is closed (e.g., Date Closed is not populated, Current Balance is greater than $0)

• Inconsistent date progression (e.g., Date of Account Information is a date later than the timestamp of the file)

• Inappropriate representation of Metro 2^® fields related to Account Status (e.g., Payment Rating is not populated when required, Payment History profile does not reflect the prior month’s Account Status)

4. Resolve missing and inaccurate field values, including:

• Invalid assignment of Portfolio Type and/or Account Type values

• Inaccurate values furnished for Special Comment Code, ECOA, Consumer Information Indicator and Compliance Condition Code fields

Ensure data accuracy now and for the future

Now that you understand how to avoid issues that can harm your consumers, drive credit disputes and draw regulatory scrutiny, take immediate steps to understand exactly how your data is mapping to Metro 2^®. If you are struggling with capacity or expertise, or are new to credit data furnishing, find a trusted expert like Bridgeforce to help you implement both a proven technology data mapping solution as well as the knowledgeable operational support needed to execute it.

- By Michelle Macartney