Collector - June 2017 - 34

BUSINESSOPERATIONS

Seeing Eye to Eye
Are you giving consumer reporting
agencies the data they want? Here's
what one ACA member learned when
his company sat down with them to
discuss the information exchange.
By Anne Rosso May

I

f you report
accounts to any
of the three major
consumer reporting
agencies, you probably
feel that you have a
clear understanding
of what data they
want. That's what the compliance team
at The CMI Group thought, too, until a
routine audit revealed some surprising
inconsistencies.
Here, Christopher Meier, general counsel
and chief compliance officer for The CMI
Group, reveals what his company has learned
about the consumer reporting process in the
last year after holding face-to-face meetings
with Experian, Equifax and TransUnion
representatives to discuss consumer data.

Q

It sounds like you've had some
interesting conversations with the
consumer reporting agencies recently.
Can you tell me how everything started?
After we report a file to the consumer
reporting agencies, our compliance
officer will go in and check to make sure our
tradeline shows up with each of the bureaus
and that it matches our records. Last year
we found that with one of the bureaus in
particular, things weren't matching up.
When we called them to ask why, it turned
out they had made a procedural change on
their end: if the date of first delinquency
wasn't outside 90 days, they didn't report the
tradeline. They had just stopped accepting
updates on all accounts that didn't meet that
criteria, and didn't tell us because they had
decided that we weren't a large enough data
furnisher. That's a little comical because we

A

34

furnish a lot of records-that's primarily how
we do our collections.

Q
A

What did you do next? Did the
conversation end there?
No. Once we found that out, we
started wondering, "OK, if you're not
accepting updates or new placements on
accounts that aren't meeting your date of
first delinquency criteria, what else aren't
you accepting?" And when we started
asking questions, we found out that they
had all kinds of policies on how they handle
disputes and updates that didn't exactly
mirror what the other bureaus were doing.
So we sent all three bureaus detailed
questionnaires to find out what they were
doing with each element in our file-how
they match the data to a consumer record,
how they handle updates and how they
handle disputes. We came up with the
questions based on our specific risk areas,
and we also relied in part on the CFPB's
documentation of what it considers risk
areas in consumer reporting.
Accuracy is easily one of the biggest issues
in credit bureau reporting, so we wanted to
make sure we understood how the bureaus
were using the files that we were giving

them. As it turned out, we got different
answers from all of them.
After those initial email conversations,
we invited each of them to individual, onsite roundtable meetings to make sure they
understood what we're doing and how we're
using the information.

Q
A

Were they surprised by the
invitation?
They did seem surprised that not only
did we want to meet with them, but
that we wanted to meet on our campus. The
reason for that was so they could see us, get
to know us and understand that we take
compliance seriously too.
We had several pre-meeting conversations
and email exchanges to make sure we all had
a firm understanding of what the discussion
would be about beforehand. We didn't want
to go into the meetings and wind up with a
bunch of questions to take home.

Q
A

What was the most interesting
thing you learned from these
conversations?
In some instances, we were
surprised to hear what data they
put a premium on and what they would

ACAINTERNATIONAL.ORG


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Table of Contents for the Digital Edition of Collector - June 2017

President's Page
Industry News
Best Practices
FYI
Collection Tips
In Case of Emergency
Pulling Back the Curtain
ACA International's 2017 Convention and Exposition Preview
Calendar
Honor Roll
Seeing Eye to Eye
The Business Battle
Blueprint for Success
Federal Court Nixes CFPB Enforcement Action That Claimed a Payment Processor Ignored Fraud
Compliance
ACA SearchPoint
Last Word
Collector - June 2017 - Cover1
Collector - June 2017 - Cover2
Collector - June 2017 - 1
Collector - June 2017 - 2
Collector - June 2017 - President's Page
Collector - June 2017 - Industry News
Collector - June 2017 - 5
Collector - June 2017 - 6
Collector - June 2017 - 7
Collector - June 2017 - Best Practices
Collector - June 2017 - 9
Collector - June 2017 - FYI
Collector - June 2017 - 11
Collector - June 2017 - Collection Tips
Collector - June 2017 - 13
Collector - June 2017 - In Case of Emergency
Collector - June 2017 - 15
Collector - June 2017 - 16
Collector - June 2017 - 17
Collector - June 2017 - 18
Collector - June 2017 - 19
Collector - June 2017 - Pulling Back the Curtain
Collector - June 2017 - 21
Collector - June 2017 - 22
Collector - June 2017 - 23
Collector - June 2017 - 24
Collector - June 2017 - 25
Collector - June 2017 - ACA International's 2017 Convention and Exposition Preview
Collector - June 2017 - 27
Collector - June 2017 - 28
Collector - June 2017 - 29
Collector - June 2017 - 30
Collector - June 2017 - 31
Collector - June 2017 - Calendar
Collector - June 2017 - Honor Roll
Collector - June 2017 - Seeing Eye to Eye
Collector - June 2017 - 35
Collector - June 2017 - The Business Battle
Collector - June 2017 - 37
Collector - June 2017 - 38
Collector - June 2017 - 39
Collector - June 2017 - Blueprint for Success
Collector - June 2017 - 41
Collector - June 2017 - Federal Court Nixes CFPB Enforcement Action That Claimed a Payment Processor Ignored Fraud
Collector - June 2017 - 43
Collector - June 2017 - Compliance
Collector - June 2017 - 45
Collector - June 2017 - ACA SearchPoint
Collector - June 2017 - 47
Collector - June 2017 - Last Word
Collector - June 2017 - Cover3
Collector - June 2017 - Cover4
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