As industry and consumer needs evolve, the national CRAs continue to enhance the quality standards surrounding and supporting credit-reporting activities. In 2015, TransUnion, Equifax, and Experian announced the National Consumer Assistance Plan (NCAP), a set of initiatives designed to improve the accuracy of credit report information, as well as to provide consumers with a better experience interacting with the nationwide Credit Reporting Agencies
The three Credit Reporting Agencies (“CRAs”) have worked together to impart new minimum data quality standards for public record data that are collected and posted to consumer credit reports. The standards are applicable to all public record data on consumer credit databases (i.e. civil judgments, state and federal tax liens, and bankruptcies), and reports derived from those databases.
In a revision that could improve consumers’ credit scores, the credit agencies will exclude the tax liens and civil debts if reports on those obligations don’t include a consumers’ names and addresses, as well as Social Security numbers and or dates of birth, the CDIA said. Many liens and most judgments don’t include all of that data, in part because Social Security numbers are often redacted for security reasons.
These Public Record standards will apply to new and existing Public Record data on our respective credit reporting databases.
The industries preliminary understanding and analysis reveals the following:
• We anticipate no change to bankruptcy public record data.
• We anticipate significant change to civil judgment public record data as preliminary analysis shows approximately 96% of this data may not meet the enhanced PII requirements. It is very likely that civil judgment public record data will not be part of the CRAs’ core consumer credit database after the effective date.
• We anticipate significant change to tax lien public record data as preliminary analysis shows that as much as 50% of this data may not meet the enhanced PII requirements. Data changes and impacts associated with the enhanced collection frequency requirements are still being investigated and analyzed with the CRAs, the public record vendor and data sources.
Additionally, the records won’t be included without courthouse visits to obtain newly filed and updated public records at least every 90 days.
The CRAs successfully collaborated and developed Public Record data standards and service levels for the collection and timely updating of public records supplied by their shared public record vendor. Our focus was on: (i) minimum required consumer identifying information (name, address, social security number and/or date of birth) (“PII”) and (ii) minimum frequency of courthouse visits to obtain newly filed and updated public records (at least every 90 days).
The effective date of these public record changes is planned for July 1, 2017.
For more questions, contact your representative.
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