Collector - June 2017 - 35


disregard all together. For instance, we
learned that a Social Security number
isn't their primary matching criteria
even though it's really the only unique
identifier for a consumer. And if you
send them a redacted Social Security
number, you are sending them nothing at
all because they will completely disregard
it-they only want the full number.
They rely on different matching criteria
than we'd thought, like the consumer's
date of birth. A lot of our clients don't
automatically pass date of birth along to us.
But when we found out that the bureaus
use that information, we went back to our
clients to make sure if they had it they were
giving it to us because although it wasn't
really necessary for the collection process, it
was for the reporting process.
We also have a better understanding
of the dispute process so we're not doing
anything that creates an unnecessary red
flag in terms of a high dispute-to-deletion
ratio. For example, one of the bureaus will
delete any record of dispute under $250
just as a matter of practice, even if the
dispute is valid. They don't even pass it
to us-it's just deleted outright. When we

found that out, we had to decide what we
wanted to change on our side.


What do you think the bureaus
learned from your conversations?
I think they learned more about how
collection agencies treat disputes.
After the CFPB started focusing on credit
reporting accuracy, bureaus started
monitoring every agency's dispute-todeletion ratio to make sure it met what they
consider to be a healthy mark. But they
don't really communicate what that mark is,
and some of the bureaus police this process
more than others.
So when we met with them, we explained
why our ratio was above what they might
consider acceptable and ultimately made
them feel comfortable with our process.
We explained that we weren't just deleting
things because we got a dispute, we were
deleting them because we were looking at
everything in our file as opposed to what was
communicated in that one E-OSCAR ACDV,
which is all the bureaus really have to go on.
From their perspective, all they see is
that, for example, you have an Experian
dispute and you deleted the account

Starting July 1, Equifax, Experian and TransUnion will omit tax liens and some civil
debts from consumer credit reports. The Consumer Data Industry Association
will remove the information if it does not list a consumer's name, address, Social
Security number and/or date of birth.
The enhanced standards "will have an impact on consumer reporting databases-
particularly with civil judgment data where a vast majority of data may not meet PII
requirements," said Eric J. Ellman, interim president and CEO of CDIA.
The change is part of the credit reporting agencies National Consumer Assistance
Plan, which was announced in 2016.

from Experian. They don't know that we
look at it in our file and we see that we
had two written disputes and two verbal
disputes, plus the client's file indicates
there is problematic information. We make
a decision to delete based on everything
that exists in our files, but from their side
they just see the one-to-one to dispute. So
we were able to educate them on what our
process is to make sure they knew that our
actions were in keeping with the safeguards
they have in place to meet CFPB standards.
Also, when one of the bureaus made the
change about the date of first delinquency
threshold, we told them that they were
cutting out an entire market from being
able to credit report. And although they
were initially slow to move, once they
validated what we said they changed back
to their old practice.


Do you have any advice for other
agencies that may be experiencing
the same challenges you were?
I'd say they need to make sure they
know how the bureaus' rules fit in with
their treatment of accounts-specifically
their scripting. If collectors are telling
consumers that they've reported an account
to a certain bureau, the agency needs to
know if the bureau accepted their file so
collectors aren't making misstatements of
fact to consumers-telling them that an
account is presently pending with a credit
bureau when in fact it was deleted because
it met one of the bounce thresholds for that
bureau. You can't really just trust that since
you sent it to the bureau, it's there reflecting
on the right person's account.
If you're finding in your monthly audits
or otherwise that your information isn't
being received and matched the way you
anticipate, you should have a discussion with
the bureaus. It doesn't necessarily have to
be face-to-face like we did, but you should
talk about how they process information.
Because in the end, we all have the same
goal: accurate information.
Anne Rosso May is editor of Collector




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

President's Page
Industry News
Best Practices
Collection Tips
In Case of Emergency
Pulling Back the Curtain
ACA International's 2017 Convention and Exposition Preview
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
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