Collector - July 2017 - 17

APPENDIX E
Regulation V requires furnishers to
consider, and incorporate as appropriate,
the guidelines set forth in Appendix E.
Notably, regulators have taken action
against furnishers that have failed to
appropriately consider and incorporate the
guidance contained in Appendix E, making
it essential that furnishers understand these
guidelines.
Appendix E provides both general and
specific guidance for furnishers to consider
when creating their accuracy and integrity
policies and procedures. As previously
noted, a company's accuracy and integrity
policy must be appropriate to the nature,
size, complexity and scope of the furnisher's
activities. The guidelines in Appendix E
provide examples of items a furnisher should
consider when developing policies and

procedures that are appropriate to its nature
and scope, including the types of business
activities in which the furnisher engages
(e.g., first-party or third-party debts), the
nature and frequency of the information it
furnishes to the CRAs (e.g., monthly, weekly,
variable), and the technology used to furnish
information to CRAs (e.g., Metro 2 Format or
other formats).
The guidelines in Appendix E also list four
distinct objectives that a furnisher's policies
and procedures should promote:
* Furnishing accurate information about
the consumer and its accounts.
* Furnishing consumer information that
has integrity.
* Conducting reasonable investigations.
* Updating information as necessary
to reflect the current state of the
consumer's account.

Furnishers should review their furnishing
methods and reflect on how these objectives
are currently being realized or how they
can be incorporated into future furnishing
processes.
The guidelines also direct furnishers to
identify practices that may compromise the
accuracy and integrity of the information
furnished and suggest that reviewing
feedback from consumers, CRAs and
employees can provide insight into the
functionality of any current accuracy and
integrity policies.
In addition to general guidelines,
Appendix E also provides 13 specific
components that furnishers must address, as
applicable, in their policies and procedures.
The 13 components cover a broad range
of issues in a furnisher's business, such as
internal business functions and controls,

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17

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

Upfront
Industry News
Best Practices
FYI
Collection Tips
What’s in Your Policy?
State Licensing Laws: What’s New and Trending
The Question of Rule 68
Calendar
Honor Roll
Healthcare Data at Risk
ACA Members Meet in D.C. to Advocate on Behalf of Industry
Fixing What’s Broken
Credit Listening Considerations
U.S. Supreme Court Hands Collection Industry a Win in ACA-Supported Case
Compliance
ACA SearchPoint
Last Word
Collector - July 2017 - Cover1
Collector - July 2017 - Cover2
Collector - July 2017 - 1
Collector - July 2017 - 2
Collector - July 2017 - Upfront
Collector - July 2017 - Industry News
Collector - July 2017 - 5
Collector - July 2017 - 6
Collector - July 2017 - 7
Collector - July 2017 - Best Practices
Collector - July 2017 - 9
Collector - July 2017 - FYI
Collector - July 2017 - 11
Collector - July 2017 - Collection Tips
Collector - July 2017 - 13
Collector - July 2017 - What’s in Your Policy?
Collector - July 2017 - 15
Collector - July 2017 - 16
Collector - July 2017 - 17
Collector - July 2017 - 18
Collector - July 2017 - 19
Collector - July 2017 - State Licensing Laws: What’s New and Trending
Collector - July 2017 - 21
Collector - July 2017 - 22
Collector - July 2017 - 23
Collector - July 2017 - The Question of Rule 68
Collector - July 2017 - 25
Collector - July 2017 - 26
Collector - July 2017 - 27
Collector - July 2017 - Calendar
Collector - July 2017 - Honor Roll
Collector - July 2017 - Healthcare Data at Risk
Collector - July 2017 - 31
Collector - July 2017 - ACA Members Meet in D.C. to Advocate on Behalf of Industry
Collector - July 2017 - 33
Collector - July 2017 - 34
Collector - July 2017 - 35
Collector - July 2017 - Fixing What’s Broken
Collector - July 2017 - 37
Collector - July 2017 - 38
Collector - July 2017 - 39
Collector - July 2017 - Credit Listening Considerations
Collector - July 2017 - 41
Collector - July 2017 - U.S. Supreme Court Hands Collection Industry a Win in ACA-Supported Case
Collector - July 2017 - 43
Collector - July 2017 - Compliance
Collector - July 2017 - 45
Collector - July 2017 - ACA SearchPoint
Collector - July 2017 - 47
Collector - July 2017 - Last Word
Collector - July 2017 - Cover3
Collector - July 2017 - Cover4
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