Collector - August 2017 - 44

COMPLIANCE

Heads Up, Data Furnishers
More NCAP reforms are coming in September.
By Andrew Pavlik

T

Classification Code 02) until they are
at least 180 days past the date of first
delinquency with the original creditor
that led to the account being sold or
placed for collection.
* Delete accounts that are being paid by
insurance or were paid in full through
insurance. This does not include
accounts paid in full by the consumer.

he National Consumer Assistance
Plan (NCAP) has brought many
changes to data furnishers, and
there are more on the way.
For a refresher, NCAP is the result of an
agreement between the big three consumer
reporting agencies (Experian, Equifax and
TransUnion) and multiple state attorneys
general. The final result is a set of reforms
that are reshaping, in many ways, how data
is furnished to CRAs. Many of the NCAP
reforms have already been implemented,
but a new round of the reforms is set to take
effect in September 2017.
Below is a summary of provisions that
have already been implemented, followed by
an overview of some of the more important
changes coming next month.

All Data Furnishers
* New accounts opened after Sept. 15,
2017, must include the full name (first,
middle, last name and generation code/
suffix), address, full Social Security
Number and date of birth. If the full
Social Security number is not available,
full date of birth will be required.

ALREADY IMPLEMENTED:

PRACTICAL CONSIDERATIONS

Debt Collectors and Debt Buyers
* Report the original creditor name and
the valid Creditor Classification Code
according to the Metro 2 format. These
fields are required for each account or
item reported. Required June 15, 2016.
* Do not report debts that did not arise from
a contract or agreement to pay. These types
of accounts include, but are not limited to,
certain fines, tickets and other assessments.
For example, library fees or fines, parking
tickets, speeding tickets, and court fees or
fines. Required June 15, 2016.
* To avoid potential deletion of data by
the CRAs, you must report your full file
monthly, including accounts that are
open, that are paid in the last 90 days,
or that require deletion or corrections.
Required Sept. 1, 2016.

Now is the time to tackle these changes
in order to make the transition smooth.
Begin working with your operations
personnel to update your policies and
procedures and train your staff. Consult

REQUIRED BY SEPT. 15, 2017:

CRAs are the entities
steering the NACP's
implementation, so they
are in the best position
to provide clarification
to furnishers.
with other agencies that you may be in
contact with to see how they are dealing
with the new requirements. Educate
clients on NCAP and work with them as
you move forward. Most importantly,
carefully review any information
provided by the CRAs and contact the
CRAs as soon as you have questions.
The CRAs are the entities steering the
NCAP's implementation, so they are in
the best position to provide clarification
to furnishers.
Andrew Pavlik formerly served as ACA
International's senior compliance analyst.

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Debt Collectors and Debt Buyers
* Do not report medical debt collection
accounts (as defined by Creditor

44

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

President's Page
Industry News
Best Practices
FYI
Collection Tips
Window of Opportunity
A Rising Tide Lifts All Boats
Setting Things in Motion
Calendar
Honor Roll
ACA Members Contribute to Successful Collectors Challenge Month
School Tides
Finding Balance
D.C. Circuit Court Holds Oral Argument in Appeal Over Constitutionality of CFPB
Compliance
ACA SearchPoint
Last Word
Collector - August 2017 - Cover1
Collector - August 2017 - Cover2
Collector - August 2017 - 1
Collector - August 2017 - 2
Collector - August 2017 - President's Page
Collector - August 2017 - Industry News
Collector - August 2017 - 5
Collector - August 2017 - Best Practices
Collector - August 2017 - 7
Collector - August 2017 - FYI
Collector - August 2017 - 9
Collector - August 2017 - Collection Tips
Collector - August 2017 - 11
Collector - August 2017 - Window of Opportunity
Collector - August 2017 - 13
Collector - August 2017 - 14
Collector - August 2017 - 15
Collector - August 2017 - 16
Collector - August 2017 - 17
Collector - August 2017 - A Rising Tide Lifts All Boats
Collector - August 2017 - 19
Collector - August 2017 - 20
Collector - August 2017 - 21
Collector - August 2017 - 22
Collector - August 2017 - 23
Collector - August 2017 - 24
Collector - August 2017 - 25
Collector - August 2017 - Setting Things in Motion
Collector - August 2017 - 27
Collector - August 2017 - Calendar
Collector - August 2017 - Honor Roll
Collector - August 2017 - 30
Collector - August 2017 - 31
Collector - August 2017 - ACA Members Contribute to Successful Collectors Challenge Month
Collector - August 2017 - 33
Collector - August 2017 - 34
Collector - August 2017 - 35
Collector - August 2017 - School Tides
Collector - August 2017 - 37
Collector - August 2017 - Finding Balance
Collector - August 2017 - 39
Collector - August 2017 - 40
Collector - August 2017 - 41
Collector - August 2017 - D.C. Circuit Court Holds Oral Argument in Appeal Over Constitutionality of CFPB
Collector - August 2017 - 43
Collector - August 2017 - Compliance
Collector - August 2017 - 45
Collector - August 2017 - ACA SearchPoint
Collector - August 2017 - 47
Collector - August 2017 - Last Word
Collector - August 2017 - Cover3
Collector - August 2017 - Cover4
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