TABLE OF CONTENTS
PREFACE
CHAPTER 1
INTRODUCTION
Purpose of Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-3
Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4
Distinction between Commercial and Consumer Debt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-6
When to Report Debts to Credit Reporting Agencies (Reporting Cycle) . . . . . . . . . . . . . . . . . . . . . . . . . 1-6
Credit Extension . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-7
Account Servicing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-7
Debt Collection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-8
Write-Off and Close-Out . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-8
"Individual Service Agreements" and Memoranda of Understanding (MOUs) . . . . . . . . . . . . . . . . . . . . 1-9
Obtaining Credit Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-10
Credit Bureau Reporting Made Easy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-12
Special Rules/Laws Applicable for Reporting Debts
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-13
CHAPTER 2
REPORTING CONSUMER ACCOUNT INFORMATION
Reporting Consumer Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
Special Rules for Reporting Consumer Account Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
Legal Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2-2
60-Day Notice of Intent to Report to Credit Bureau . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3
Handling Disputed Information in Consumer Debtor Files . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5
Summary of Procedures Disputing Accuracy of a Credit Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-7
Procedures to be used When Debt Goes from "Current" to "Delinquent" Status . . . . . . . . . . . . . . . . . . . 2-8
Reporting Debts Being Collected by FMS' Debt Management Service (DMS) . . . . . . . . . . . . . . . . . . . . 2-9
General Instructions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-10
Use of the Metro 2 Format for Referring Information to Credit Reporting Agencies . . . . . . . . . . . . . . . 2-12
Reporting Consumer Account Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-13
Federal Agency Identifiers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-14
Important Debtor Identification Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-14
Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-17
CHAPTER 3
REPORTING COMMERCIAL ACCOUNT INFORMATION
Reporting Commercial Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
General Instructions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
Reporting Debts Being Collected by FMS' Debt Management Service (DMS) . . . . . . . . . . . . . . . . . . . . 3-3
Handling Disputed Information in Commercial Debtor Files . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4
Commercial Account Data Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4
Identification Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4
Debt Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3-5
TABLE OF CONTENTS
Current Activity Elements (Status Codes) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3-6
Agency Identification Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-10
Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-11
Automated Reporting Format for Commercial Debt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-12
Comments & Tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-14
Current Activity Status Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-15
Frequency of Payment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-16
Type of Debt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-16
APPENDICES
Appendix 1 - Section 3711(e) of Title 31, United States Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1
Appendix 2 - (Model) Memoranda of Understanding for Reporting of Consumer and Commercial Debts . . . . . A-5
Appendix 3 - Credit Reporting Agency Contacts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-23
Appendix 4 - Sample FMS Debt Management Cross-Servicing Implementation Agency Profile Form . . . . . . . A-25
Appendix 5 - Commonly Used Federal Agency Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-27
1-1
Chapter 1
Introduction
Purpose of Guidelines
These guidelines apply to ALL Federal Executive,
Legislative and Judicial agencies, including
Government corporations. The purpose of this document
is to provide guidance to Federal agencies for reporting
information on Federal debts (consumer and commercial)
to designated credit reporting agencies. The guidelines are
consistent with the Debt Collection Act of 1982 (DCA), as
amended by the Debt Collection Improvement Act of 1996
(DCIA), the revised Federal Claims Collection Standards
(31 CFR Parts 900-904) published November 22, 2000, the
revised Office of Management and Budget (OMB) Circular
No. A-129 published November 29, 2000, and the
Financial Management Service (FMS) publication
“Managing Federal Receivables” (revised May 2005).
Relevant portions of the DCA and the DCIA are codified at
31 U.S.C. § 3711(e) (see Appendix 1) and 3720(B).
This document supersedes the previous “Guide to Federal
Credit Bureau Reporting” which was published in 1991.
This guide will be periodically updated to include new
information as it develops.
Since 1991, numerous changes have occurred, most
notably:
(a) The DCIA, enacted in 1996, requires agencies to report
to credit reporting agencies, information on all delinquent
consumer debts owed to the Federal Government;
(b) The DCIA authorizes agencies to report accounts in
good standing to credit reporting agencies. Reporting
accounts in good standing ensures that all relevant Federal
debtor data is integrated into the credit reporting agency
databases and is available for consideration when credit
decisions are made and prevents overextension of credit;
Introduction
1-2
(c) The DCIA requires that lenders financing and/or
extending credit on behalf of the Federal Government be
required to provide information relating to the extension of
credit to consumer and commercial credit reporting
agencies. Submission of debtor information to designated
credit reporting agencies should be a routine and ongoing
part of Federal agencies and certified lenders account
servicing and debt collection procedures for both consumer
and commercial accounts;
(d) The revised Federal Claims Collection Standards,
published in November 2000 clarify and simplify Federal
debt collection procedures (and reflect changes under the
Debt Collection Improvement Act of 1996 and the General
Accounting Office Act of 1996); and
(e) The “Metro 2” format for reporting consumer debt,
developed by the credit reporting industry, is designed to
capture better data for debtor records within the credit
reporting agency databases. The Metro 2 format increases
the accuracy of debtor files which subsequently produces a
better credit report and provides additional features for the
report user. The format is the industry standard for
providers of information. See Chapter 2 for additional
information on the Metro 2 format.
The Financial Management Service (FMS) is available to
meet with Federal agencies to assist with the reporting
effort, including facilitation of the Memoranda of
Understanding (MOUs) between Federal agencies and the
designated credit reporting agencies receiving Federal
debtor data. “Model” consumer and commercial MOUs are
located at Appendix 2. The MOUs in Appendix 2 can
can be reproduced and used to enter into agreements
with the credit reporting agencies. Contacts for credit
reporting agencies and FMS are listed in Appendix 3.
Introduction
1-3
In addition to this document, the following materials
provide guidance on reporting to credit reporting agencies:
C
OMB Circular No. A-129 “Policies for
Federal Credit Programs and Non Tax
Receivables” (Revised);
C
“Federal Claims Collection Standards”
(Revised) (See 31 C.F.R.§ 901.4); and,
C
FMS Publication “Managing Federal
Receivables”(Revised May 2005).
Agencies should review Office of Management and Budget
(OMB) Circular No. A-129 for policies on the use of credit
reports for the purpose of screening and determining
creditworthiness of applicants for Federal financial
assistance or persons seeking to do business with the
Government.
Background
The Debt Collection Act of 1982 gave agencies the
authority to report delinquent nontax, non-tariff consumer
debts to credit reporting agencies provided that Federal
agencies follow detailed procedures.
The DCIA was enacted through the cooperation of major
Federal Government credit granting agencies, the OMB,
the Chief Financial Officers Council and the Department of
the Treasury. The DCIA significantly enhanced the Debt
Collection Act of 1982. The DCIA requires Federal
agencies to report to credit reporting agencies, information
on all delinquent Federal consumer debts. The DCIA also
authorizes the submission of information on consumer
debtors considered as “current.” Federal agencies have
been required, as a matter of policy, to report all (current
and delinquent) commercial debts since September 1983.
Introduction
1-4
This requirement was subsequently incorporated into OMB
Circular A-129 and the Federal Claims Collection
Standards. As detailed later in this document, agencies are
encouraged to report their entire debt portfolios (current
and delinquent debts).
Definitions
A “claim” or “debt” (used interchangeably) means any
amount of money, funds or property that has been
determined by an appropriate official of the Federal
Government to be owed to the United States by a person,
organization or entity other than another Federal agency.
Section 3701(b) of Title 31 of the United States Code
defines a “debt” or “claim” to include:
C
funds due to the United States on account of
loans made, insured or guaranteed by the
Government, (including any deficiency or
difference between the price obtained by the
Government in the sale of a property and the
amount due to the Government on a
mortgage on the property);
C
expenditures of non-appropriated funds;
C
overpayments;
C
any amount the U.S. is authorized by statute
to collect for the benefit of any person;
C
the unpaid share of any non-Federal partner
in a program involving a Federal payment
and matching or cost sharing payments by
the non-Federal partner;
Introduction
1-5
C
fines or penalties assessed by an agency; and

C
any other amounts of money or property due
to the Government other than delinquent
taxes and tariffs.
“Accounts receivable” are generated by all Federal
agencies. Examples of accounts receivable are: fines,
fees, penalties, forfeitures, royalties, audit disallowances,
claims, rents, damages, overpayments, and other amounts
owed to the Government.
“Credit reporting agency” (also known as “credit
bureau”)- Major consumer and commercial credit
reporting agencies that have signed agreements
Memoranda of Understanding (MOUs) with Government
agencies to receive and integrate credit information (data)
from voluntary subscribers (Federal agencies and private
sector entities) into their respective database. In turn, this
information is sold, oftentimes by smaller credit reporting
agencies, to purchasers of credit data (in the form of credit
reports and other products). The credit report, etc., is used
to determine creditworthiness, conduct credit scoring, assist
with collection efforts, or for other permissible purposes as
defined by the Fair Credit Reporting Act. (See Appendix 3
for designated credit reporting agencies.)
“Non-exclusive basis” - Federal agency debtor account
information is reported to each of the designated credit
reporting agencies receiving Federal debtor data.
(Agencies should attempt to resolve issues which prevent
reporting in this manner.)
Introduction
1-6
When to Report Debtor
Information
Credit
Extension
Debt
Collection
Write-Off/
Close Out
Account
Servicing
Submit accounts
to credit reporting
agencies during:
Distinction between Commercial and Consumer Debt
In accordance with the definitions contained in “Managing
Federal Receivables,” the term “commercial” signifies a
business activity and the term “consumer” signifies a
personal activity. The purpose of the activity, not the
type of entity involved, determines whether a debt is
classified as commercial or consumer.
For example, a loan to a farmer to obtain additional land or
equipment for farming would be considered a commercial
loan; whereas a loan to the same farmer to purchase a
personal residence would be a consumer loan.
When to Report Debts to Credit Reporting Agencies (Reporting Cycle)
There are four points in the credit management and debt
collection cycle when Federal agencies should make use of
credit reporting agencies. As part of its financial
management responsibility, an agency should report
information on its Federal debtors to credit reporting
agencies in the following circumstances:
Introduction
1-7
C
Credit Extension - Under the DCIA heads of
agencies must, as a condition for insuring or
guaranteeing any loan, financing, or other extension
of credit under any law to a person, require that the
lender provide information relating to the extension
of credit to consumer reporting agencies or
commercial reporting agencies, as appropriate.
Additionally, pursuant to 31 U.S.C. § 3720B,
Federal agencies may not grant a loan or loan
guarantee to a person or entity which owes
delinquent nontax debt to the Federal government.
See 31 C.F.R. § 285.13. Agencies are required by
OMB Circular No. A-129 to screen potential
applicants for Federal financial assistance for
creditworthiness. The applicants’ credit history
(credit report) also becomes a part of the official
loan origination files. In instances where a
delinquent Federal tax or nontax debt has been
reported and is reflected in the applicant’s credit
history, agencies should immediately suspend loan
processing (unless statutorily prohibited). In
instances where the loan, etc. has been approved,
the indebtedness should be reported to a credit
reporting agency after funds have been disbursed.
C
Account Servicing - Once a loan is awarded and
disbursed, or a financial obligation to repay an
administrative debt has been established, the
Federal agency (or in the case of a guaranteed loan,
the lender) becomes responsible for servicing or
controlling the account. Federal agencies may
provide to consumer reporting agencies or
commercial reporting agencies information from a
system of records that a person is responsible for a
claim which is current. If account servicing has
been contracted out or a lender is servicing the
account, agencies must require the servicer or
lender to make the initial referral of debtor account
information to credit reporting agencies and to
provide accurate and consistent account status
Introduction
1-8
updates.
C
Debt Collection - Reporting debts to credit
reporting agencies is an essential part of an
agency’s debt collection efforts. In accordance with
Federal law, agencies must report information on all
Federal delinquent consumer debtors to credit
reporting agencies. Regulations and policies
governing commercial debtors are covered in OMB
Circular No. A-129 (revised November 2000) and
the Federal Claims Collection Standards (revised
November 2000). With some exceptions, Federal
agencies must not extend credit assistance to
debtors owing unresolved delinquent debts to the
Government (see 31 U.S.C. § 3720B and 31 C.F.R.
§ 285.13). When debts have been transferred to
FMS or a designated debt collection center for
collection pursuant to the DCIA, FMS or the debt
collection center, as appropriate, will perform debt
collection activities (which include referral of
accounts to credit reporting agencies if requested by
the transferring agency).
Prior to reporting delinquent consumer debts to
credit reporting agencies, agencies must provide
consumer debtors certain rights of due process
which are detailed in Chapter 2, “Reporting
Consumer Account Information.”

C
Write-Off and Close-Out - An effective
receivables management program must include the
systematic write-off and close-out of uncollectible
debts pursuant to OMB Circular A-129.
Essentially, once the debt is written-off, the agency
must either classify the debt as currently not
collectible (CNC) or close-out the debt. If an
agency determines that continued collection efforts
after write-off are likely to yield higher returns in
the future, then the debt is not closed out but
Introduction
1-9
classified as CNC and reporting to credit reporting
agencies should continue. Once the agency
determines it is no longer cost effective or legally
possible to pursue collection, the debt should be
closed-out and all collection activity ceased. The
account’s status is forwarded to the credit reporting
agencies receiving Federal data. Agencies should
consult OMB Circular A-129 for details.
“Individual Service Agreements” and Memoranda of Understanding (MOUs)
In past years, many agencies signed “Individual Service
Agreements” with credit reporting agencies to accept, store
and integrate Federal data into credit reporting agency
databases. While FMS does not require termination of
these agreements, the Memoranda of Understanding
(MOUs) promote standardization of the reporting process
government wide and are consistent with current law.
Agencies are encouraged to enter into the MOUs at the
expiration of their current service agreements. The MOU
should be signed by the Federal agency Chief Financial
Officer or the designee and the appropriate credit reporting
agency official. Federal agencies should also have their
counsel review current agreements to determine whether
they are compliant with current law and policy.
The MOUs obligate Federal agencies to provide credit
information on their accounts to the particular credit
reporting agencies signing the MOU. In turn, the credit
reporting agencies agree to accept, load, store, and
incorporate this information into their data files and credit
information. This ensures that when a Federal agency or
private sector lender purchases a credit report on an
applicant or debtor, the Government’s information is
reflected in the report purchased.
Introduction
1-10
Obtaining Credit Reports
The smaller credit reporting agencies authorized by the
General Services Administration (GSA) on the Federal
Supply Schedule (FSS) to provide credit reports for Federal
agencies must purchase their information from the
designated credit reporting agencies listed at Appendix 3.
Federal agencies should use the FSS for the purchase of
credit reports and related information, unless circumstances
dictate otherwise. Purchasing credit reports through the
FSS is no different from purchasing other items through the
GSA’s FSS.
Agencies are required by OMB Circular No. A-129 to
purchase credit reports for screening loan applicants.
Where appropriate, Federal agencies should obtain
information (credit reports) on loan applicants from both
commercial and consumer credit reporting agencies prior to
extending credit or other Federal assistance. Credit reports
should also be purchased at other times throughout the
credit cycle:
C
to verify a debtor’s claim of financial inability to
pay a debt in a lump sum, as is required prior to
entering into an installment agreement;
C
to reassess a debtor’s financial position when
considering rescheduling a debt or otherwise
entering into a workout agreement;
C
to evaluate administrative offset and other debt
collection possibilities; and
C
to meet the requirement that an agency provide
credit data on a debtor when referring a debt for
litigation.
Introduction
1-11
The agency’s cost to purchase a credit report or other credit
information should be passed along to the borrower/debtor:
(a) through the application fee when used to determine
creditworthiness and eligibility during credit extension;
and, (b) as an administrative cost when used after the debt
becomes delinquent.
Introduction
1-12
Credit Bureau Reporting Made Easy
Action Required
Consumer
Reporting
Commercial
Reporting
1. Sign Memoranda of Understanding (MOU) with credit reporting
agencies (see “Model” Memoranda of Understanding at Appendix 2)
facilitated by the Financial Management Service, Debt Management
Services. See Appendix 3 for Treasury/FMS contact information.
YES
YES
2. Contact the consumer and/or commercial credit reporting agencies
receiving Federal debtor data to establish reporting relationship (contacts,
addresses, etc.). Agencies are reminded that data should be sent on a non-
exclusive basis (data should be sent to each of the credit reporting
agencies). See Appendix 3 for credit reporting agency contacts.
YES
YES
3. Agree with each credit reporting agency on the method in which data
will be sent. (tapes, disks, electronically, etc.)
YES
YES
4. Prepare data for submission to credit reporting agency.
NOTE: Reporting Cycles
Consumer - Report Monthly-(more frequent updates may be made as
required)
Commercial - Report Quarterly-(more frequent updates may be made as
required)
YES
YES
5. Complete “Transmittal of Account Information” sheet to accompany
tape, etc. (Attachment A to MOU)
YES
YES
6. Submit data to credit reporting agencies. The credit reporting agencies
will return all tapes to the respective agency after the data has been loaded
into the respective databases. Agencies are encouraged to work to
establish procedures to ensure that the information has been loaded and is
being properly reported by the credit reporting agencies.
YES
YES
7. Prepare quarterly report to Financial Management Service (Attachment
B to MOU).
YES
YES
Introduction
1-13


Special Rules/Laws
Consumer
Account
Data
Commercial
Account
Data
The Privacy Act of 1974, as amended - Promotes greater governmental
respect for the privacy of citizens.
YES
MAY
APPLY*
Debt Collection Act of 1982 (DCA) - Increases the efficiency of
government wide efforts to collect debts owed to the United States and to
provide additional procedures for the collection of those debts.
YES
YES
DCA due process requirements include: Requirement for 60-day notice to
debtor before submission of delinquent debtor data to credit reporting
agencies. See Chapter 2 - Reporting Consumer Accounts
YES
N/A
Debt Collection Improvement Act of 1996 (DCIA ) - Requires the
reporting of all nontax delinquent consumer debts to credit reporting
agencies.
YES
N/A
The DCIA authorizes the reporting of current consumer and commercial
debts.
YES
YES
OMB Circular No A-129, dated November 29, 2000 - Provides regulatory
guidance consistent with the DCA and the DCIA regarding the referral of
accounts to credit reporting agencies. Instructs agencies to report all
current and delinquent commercial debts.
YES
YES
The Department of the Treasury, Financial Management Service’s
“Managing Federal Receivables” - provides program guidance to Federal
agencies on reporting of information to credit reporting agencies.
YES
YES
Justice/Treasury “Federal Claims Collection Standards”- dated
November 22, 2000 - Regulations governing Federal debt collection
procedures (including the use of credit reporting agencies).
YES
YES
*Consult with Agency Counsel

2-1
Chapter 2
Reporting Consumer Account Information
Reporting Consumer Accounts
The purpose of this chapter is to provide general
instructions for reporting account information on
consumer debts to credit reporting agencies.
Special Rules for Reporting Consumer Account Information
The reporting of information on individual consumers is
governed by certain laws, regulations and policy guidance,
including:
C
The Privacy Act of 1974 as amended - Promotes
greater governmental respect for the privacy of
citizens.
C
Debt Collection Act of 1982 (DCA) as amended by
the Debt Collection Improvement Act of 1996
(DCIA) - increases the efficiency of government
wide efforts to collect debts owed to the United
States and to provide additional procedures for the
collection of those debts.
C
DCIA - The DCIA requires the reporting of all non
tax delinquent consumer debts to credit reporting
agencies. The DCIA also authorizes the
reporting of current consumer and commercial
debts.
C
OMB Circular No. A-129 - Provides regulatory
guidance consistent with the DCA and the DCIA
regarding the referral of accounts to credit reporting
agencies.
Reporting Consumer Account Information
2-2
C
Justice/Treasury Federal Claims Collection Standards -
regulations governing Federal debt collection procedures
(including the use of credit reporting agencies).
C
The Department of the Treasury, Financial Management
Service’s Managing Federal Receivables - includes
guidance to Federal agencies on reporting information to
credit reporting agencies.
Legal Requirements
Federal agencies are legally required to follow certain procedures
when reporting delinquent consumer debts to credit reporting
agencies. Prior to reporting a delinquent consumer debt to a credit
reporting agency, a Federal agency must:
C
comply with the provisions of the Privacy Act of 1974.
See 31 U.S.C. § 3711(e)(1)(A). Agencies should consult
their counsel in order to comply with Privacy Act
requirements.
•
establish procedures to:
–
disclose promptly to consumer reporting agencies
substantial changes in the condition or amount of a
debt;
–
verify or correct promptly information about a debt
on request of a consumer reporting agency for
verification of information (see section entitled
“Handling Disputed Information in Consumer
Debtor Files”on page 2-5); and
–
get satisfactory assurances that consumer reporting
agencies are complying with Federal laws related to
providing consumer credit information. See 31
U.S.C. § 3711(e)(1)(E).
Reporting Consumer Account Information
2-3
C
take reasonable action to locate a person about
which the information will be reported for whom
the agency does not have a current address. See 31
U.S.C. § 3711(e)(3).
•
review the debt to be reported and decide that the
debt is valid and overdue. See 31 U.S.C. §
3711(e)(1)(B).
•
determine that the person about which the
information will be reported has not:
–
entered into a written repayment plan with
the Federal agency; or
–
filed for a review of the debt. See 31 U.S.C.
§ 3711(e)(1)(D).
•
send a notice to the person about which the
information will be reported at least 60 days prior to
reporting a debt to a credit reporting agency (see
“60-day Notice of Intent to Report to Credit
Bureau,” below) and notify the person that he or she
is entitled to a complete explanation of the debt, to
dispute information in the records about the debt,
and to an administrative repeal or review of the
debt. See 31 U.S.C. § 3711(e)(1)(C).
•
provide for a review of the debt upon request,
including an opportunity for reconsideration of the
initial decision. See 31 U.S.C. § 3711(e)(2).
60-Day Notice of Intent to Report to Credit Bureau
Pursuant to 31 U.S.C. § 3711(e), when reporting
information on delinquent consumer accounts, the debtor
must be notified 60 days in advance of such reporting to the
credit reporting agency. Agencies should provide this
notice in the initial billing notice or demand letter, but no
later than the second demand letter sent by the agency.
Reporting Consumer Account Information
2-4
The notice must include:
C
the agency’s intent to report the debt to a
credit reporting agency;
C
the specific information to be transmitted
(i.e., name, address, and taxpayer
identification number, information about the
debt);
C
the actions which may be taken by the
debtor to prevent the reporting (i.e.,
repayment in full or a repayment
agreement).
C
the rights the debtor has under 31 U.S.C. §
3711 to a complete explanation of the debt,
to dispute the debt, to review records about
the debt, and to seek an administrative
repeal or review of the agency’s
determination that the debt is due.
NOTE: Agencies must also comply with any
requirements contained in any contract, agreement,
law or regulation applicable to the debt.
Once all due process procedures have been observed, (i.e.,
the demand letter(s) have been sent, the debtor has been
given 60-days to respond to the notification of intent to
report to a credit reporting agency, and either the debtor
has not responded or any disputes have been resolved, an
agency must report the debt to the appropriate credit
reporting agencies. (See Appendix 3 - Credit Reporting
Agency Contacts).
Reporting Consumer Account Information
2-5
Handling Disputed Information in Consumer Debtor Files
Consistent with 31 U.S.C. § 3711(e), debtors shall have the
right to dispute inaccurate information contained in their
files and the right to review records pertaining to their
debts.
Reporting debts owed to the United States to consumer
reporting agencies is governed by the DCA and the DCIA
as codified at 31 U.S.C. § 3711(e). Obligations of
consumer reporting agencies and state and local
government agencies to investigate disputes under the Fair
Credit Reporting Act (FCRA) arise independently of
3711(e). Federal agencies should be aware that credit
reporting agencies may be required by the FCRA to delete
information if their investigation is not completed within
30 days.
It is critical for agencies to perform their investigations in a
manner that will allow completion within 30 days and
prevent deletion of the information. The standard
procedures for resolving disputes by credit reporting
agencies are depicted on the flow chart shown on page 2-7
titled “Summary of Procedures Disputing Accuracy of a
Credit Report”. The 30-day clock starts the day the credit
reporting agency receives a dispute from a debtor in
writing, by phone, or in person. Credit reporting agencies
then have five (5) days to provide the notice of dispute and
all relevant information to the Federal agency. Given that
most responses back to the credit reporting agencies from
Federal agencies will be by mail, a three to five day mail
time allowance is required. Once the mail times are
deducted this provides Federal agencies approximately 20-
22 days after receipt of the dispute to resolve and return it
to the credit reporting agency on the last day before
deletion.
While 31 U.S.C. § 3711(e) does not hold Federal agencies
to a specific timeframe, it does require Federal agencies to
verify or correct promptly information about the claim on
Reporting Consumer Account Information
2-6
request of a consumer reporting agency for verification of
information disclosed.

Credit reporting agencies are not required to remove
accurate data from their files unless it is outdated or cannot
be verified. (See chart on the next page which details the
consumer dispute process.)
Therefore, Federal agencies should have procedures in
place to promptly address such disputes. In order to avoid
having information deleted at the expiration of the 30 days,
agencies are strongly encouraged to review and make a
decision on disputes and report back to the credit reporting
agency within fourteen (14) days if possible and no longer
than twenty one (21) days maximum.
Reporting Consumer Account Information
2-7
SUMMARY OF PROCEDURES DISPUTING ACCURACY OF A CREDIT REPORT*
Debtor requests and receives copy of credit report
Debtor is satisfied with report
contents -- process complete
Debtor is not satisfied and disputes
in writing, by phone, or in person
Credit Reporting Agency provides notice of dispute
to Federal Agencies within five business days along
with “all relevant information” that the Debtor provided
Federal Agency considers “all relevant information”
submitted by the Debtor
Federal Agency determines its information to be
accurate
Federal Agency notifies credit reporting agency
Information is maintained on file by
Credit Reporting Agency
Federal Agency determines its information to be
inaccurate or incomplete or can’t be verified
Federal Agency notifies all Credit Reporting
Agencies to which it reports
Credit Reporting Agencies must “promptly”
delete (or update info) as appropriate based
on Federal Agency reinvestigation
Within five days of completion of reinvestigation, Credit Reporting Agency
notifies the debtor in writing of the results. Notice must include:
¾
Statement that reinvestigation is completed and a revised credit report
¾
Notice that the Debtor can add a 100-word statement to report
¾
If requested, procedures used to reinvestigate, and names, addresses, and phone numbers for Federal Agencies
OR
OR
M
U
S T
T
A
K
E
N
O
LO
N
G
E R
T
H
A
N
30 D
A
Y
S
*BASED ON “THE CREDIT REPORTING DISPUTE RESOLUTION PROCESS” WITH PERMISSION OF THE CONSUMER
DATA INDUSTRY ASSOCIATION (CDIA)
Reporting Consumer Account Information
2-8
Procedures to be Used When Consumer Debt Goes from “Current” to “Delinquent” Status
As described earlier in this chapter, Federal agencies must
comply with certain due process procedures before
reporting a delinquent consumer debt to a credit reporting
agency. A minimum of 60 days is required to comply with
due process procedures, which include providing the debtor
with notice and an opportunity to dispute the information to
be reported. See “Legal Requirements” and “60-Day
Notice of Intent to Report to Credit Bureau.”
This section describes the procedures to be followed when
the status of a consumer debt changes from “current” to
“delinquent.” Federal agency procedures applicable to the
due process period (60 days or while appeals and reviews
are pending) are as follows:
C
send the 60-day notice described in the above
section entitled “60-Day Notice of Intent to
Report to Credit Bureau;”
C
if the agency has been reporting the debt as
“current/not delinquent,”remove the debtor’s
account from data (tapes, etc.) sent to the credit
reporting agencies. In other words, do not report
the account;
C
if the debtor asks for a review of the files or
disputes the debt, do not report the debt until any
reviews or appeals are completed;
C
if the debtor submits a payment(s) or enters into a
repayment agreement within the 60-day period
the account should be updated accordingly;
C
after passage of the 60-days (or after all reviews
or appeals are completed), report the delinquent
account(s) to the credit reporting agencies.
Reporting Consumer Account Information
2-9
Presumably, this would be the third month of delinquency,
since consumer accounts are reported on a monthly basis.
During subsequent reporting periods, the agency should
update the debtor’s account status. NOTE: Generally,
Federal agencies are not required to send debtors multiple
notices of intent to report to a consumer reporting agency.
Agencies should consult their counsel to determine when
multiple notices are required.
Reporting Debts Being Collected by FMS’ Debt Management Services (DMS)
With some exceptions, the DCIA requires that Federal
agencies transfer to Treasury, or a Treasury-designated
debt collection center, all debts which are greater than 180
days delinquent (see 31 U.S.C. § 3711(g)). When a debt is
transferred to the Financial Management Service’s Debt
Management Services (DMS) -- the area within Treasury
responsible for collecting delinquent debt--the agency to
which the debt is owed (known as the “creditor agency”)
must certify that it has completed all due process required
by the DCIA and Treasury regulations for reporting debts
to credit reporting agencies. (See 31 U.S.C. § 3711(e) and
31 C.F.R. § 285.12 for due process and certification
requirements.)
Federal agencies have the option of transferring delinquent
debts prior to the expiration of 180 days, provided they
have completed all due process requirements, and they
certify the debts as required by 31 C.F.R. § 285.12.
Federal agencies have two options for credit bureau
reporting once they have referred cases to DMS for debt
collection, a process known as “cross-servicing:” (1) they
may continue to report the cases to credit reporting
agencies, and DMS will not do so; or (2) they may cease
reporting, and DMS will report to credit reporting agencies
on the Federal agencies’ behalf. Federal agencies are asked
to select the option they prefer when completing the “DMS
Cross-servicing Agency Profile” form (see Appendix 4).
Reporting Consumer Account Information
2-10
Further information on FMS cross-servicing can be found
in the FMS publication “Cross-Servicing Implementation
Guide” at: http://www.fms.treas.gov/debt/crosserv.html.
As a part of its regular debt collection procedures, DMS
will report debts it is collecting to the appropriate
designated credit reporting agencies. If a credit reporting
agency notifies DMS that a debtor has disputed the validity
or accuracy of a debt, DMS will notify the creditor agency
of the dispute. If the creditor agency does not recertify the
debt within the specified time, DMS will return the entire
debt file to the agency and cease all further collection
efforts, including referral to credit reporting agencies. See
Appendix 3 for DMS contact information.
General Instructions
The following applies for all consumer accounts:
C
Prior to reporting delinquent consumer debts, the
head of the agency must comply with legal
requirements described earlier in the “Legal
Requirements Section:”
C
An agency must report account information on
delinquent nontax, non-tariff, consumer debts at
least monthly. Agencies may update account
information more frequently to maintain the integrity
and accuracy of the information reported. Agencies
should report complete information on each debt, not
just the updated items.
There is no minimum dollar threshold on the
amounts for debts which agencies can report.
Reporting Consumer Account Information
2-11
C
In accordance with the DCIA, agencies are now
authorized to report current (i.e., not delinquent)
consumer accounts to credit reporting agencies.
Consumer information is reported on a monthly
basis. Agencies should report current account data
so that debtor files contain all indebtedness to the
U.S. Government. This information assists debtors
who are current when being considered for credit
and assists the government when determining the
debtor’s creditworthiness and ability to repay other
obligations (avoids overextension).
C
Agencies should report debtor account information
to credit reporting agencies on a non-exclusive basis
(i.e., submit account information to each consumer
credit reporting agency receiving Federal data)
unless circumstances dictate otherwise.
In order to avoid potential reporting errors,
agencies should not re-use or re-issue account
numbers after an account has been closed.

C
Agencies should report each debt separately and not
group together debts owed by a single borrower,
regardless of the amount of activity with that
borrower.
C
Agencies should report capitalized interest or other
capitalized expenses as part of the debt giving rise to
the interest or expense. For example, if $1,000 in
interest is capitalized on a $50,000 debt, the amount
to be reported as a single account would be $51,000.
Reporting Consumer Account Information
2-12
C
In the case of participation loans (loans consisting of
both direct and guaranteed portions or more than one
lender), an agency would report only the direct
participation amount. The guaranteed amount would
become reportable by the agency after the agency
acquires the guaranteed portion in satisfaction of a
default claim.
C
An agency should furnish the account information
electronically, on-line, on magnetic tape, manually,
or in any other form agreed to by both parties.
Use of the Metro 2 Format for Referring Information to Credit Reporting Agencies
In 1997, the credit reporting industry initiated the use of
the “Metro 2" format which became the industry
standard for reporting debtor information. The “Metro
2" format was developed by Consumer Data Industry
Association (CDIA) to replace the Metro format which was
developed in the late 1970's. The Metro 2 format facilitates
complete and greater accuracy of reporting of data and
provides the following features:
C
format is designed to be easier to use and
understand;
C
allows reporting on debtors that “cannot be located;”
C
allows reporting of deferred payments and
“associate” borrowers/debtors information;
C
Identification numbers can be changed to
accommodate transfer or sale of debt (asset sales);
and,
C
the format accommodates a 4-digit “year” field to
accommodate reporting in the year 2000 and beyond.
Reporting Consumer Account Information
2-13
Reporting Consumer Account Information
The credit reporting agencies receiving Federal debtor
data will assist agencies to implement Metro 2 format
reporting. (See Appendix 3 for credit reporting agency
contacts.)
Electronic copies of the Metro 2 reporting format are
available from Consumer Data Industry Association (DCIA)
via the Internet in the following steps:
a)
INTERNET address:
http://www.cdiaonline.org;

b)
from the home page, click on the “Data
Provider/Metro2/ACDV/AUD” icon;
c)
click underneath Metro 2 for Credit
Reporting on “Instructions to Access the
Metro 2 Format;” The Metro 2 format is
posted on the Consumer Data Industry
Association (CDIA) website in Adobe
Acrobat Reader format, also known as “pdf.”
Adobe Acrobat Reader will be necessary to
open and read the document.
d)
call telephone numbers listed to obtain
UserID and passcode.
e)
click on “download” where indicated;
f)
complete and submit user/subscriber
information;
g)
a prompt that the submittal was successful
should be displayed; select the option to
download the format in either “windows”
or “MAC.”
h)
type in “METRO 2" (uppercase) at the user
Reporting Consumer Account Information
2-14
i.d. prompt; and finally,
i)
type in “accuracy” at the password prompt.
The speed at which the file will download depends on the
type of modem used with your computer. The file will be
downloaded as a “zipped” file which must then be
“unzipped” to be opened.
Federal Agency Identifiers
A list of agency identifiers (Appendix 5) has been
developed for use with the Metro 2 format.
Important Debtor Identification Elements
When preparing information for submission to the credit
reporting agencies, the following information is essential to
maintaining the accuracy of debtor records:
C
Account Number: This should be the unique
alphanumeric or numeric code which identifies each
individual loan, loan guarantee, or debt.
Codes which are based primarily on Social Security
Numbers are acceptable only if the agency can
distinguish between different loans which may have
been made, or other types of credit which may have
been extended to an individual or entity and if such
use of Social Security Numbers is otherwise
authorized by law. Agencies have the option of
adding an additional character to the code to make
such distinctions.
Reporting Consumer Account Information
2-15
C
Taxpayer Identification Number (TIN): This is the
number used by the Internal Revenue Service to
identify individuals and businesses (e.g., Social
Security Numbers and Employer Identification
Numbers). Agencies are required by 31 U.S.C. §
7701(c) to obtain the TIN of all persons or entities
with whom it does business. All agencies and
lenders extending credit shall require the applicant
or borrower to supply a TIN as a prerequisite of
obtaining credit or assistance. NOTE: Delinquent
debts should be reported even if agencies are unable
to locate a TIN.
When transmitting files to the credit reporting
agencies, the TIN can be omitted only if the Federal
agency has exhausted all remedies in efforts to
obtain it, and if the credit bureau reporting agency
agrees to accept the account without it.
C
Name: This should identify the individual(s) or
entity legally liable to repay the debt. Agencies
should require the debtor to notify them of any
changes made to legal liability for the debt and
should maintain, in their files, the names (and
addresses) of the debtor of record and all other
legally liable parties.
C
Address: This should be the address of principal
residence of the legally liable individual(s) which
corresponds to the debtor(s) of record, including
city, state and zip code. A street address rather than a
route number or post office box should be reported.
C
Type of Debt: Report the category that best describes
this account.
C
Date of First Disbursement/Date Debt Established:
For a loan or line of credit, this is the date when
credit was extended by the initial disbursement of
funds or the closing on a loan, whichever is earlier.
Reporting Consumer Account Information
2-16
For other types of debts, the date to be reported is the
date on which the event which created the debt
occurred or the date the charge was assessed. For
example, if the debt arose as the result of an
installment sale, then the date of such sale goes in
this field. Similarly, the date a fine or fee is assessed
would be the date the debt was established. The date
the debtor was notified of the debt should not be
used unless that is the date the debt was established
(e.g. certain administrative debt).
C
Amount: Report the full amount of the original debt
and any capitalized interest, principal only.
C
Terms: This is the length of time for which credit has
been extended, from the date of the first
disbursement of funds until the date of the last
originally scheduled repayment by the debtor.
Report this time period in years for real estate loans.
C
Association: Report the individual’s or entity’s
relationship to the account, e.g., individual, joint, co-
maker, etc. If reporting a relationship other than
individual, information must be provided on each
legally liable party involved with a debt. If the
financing information is the same for all parties, a
separate section on the same file must be completed.
If the financing information is not the same, then a
separate file must be completed for each liable party.
Reporting Consumer Account Information
2-17
SUMMARY

Federal agencies seeking to establish a reporting relationship with credit reporting agencies
should do the following:
1.
Execute an MOU with each consumer credit reporting agency accepting Federal
data on consumer debts (See Sample MOU at Appendix 2).
2.
Contact each of the consumer credit reporting agencies receiving Federal debtor
data to establish a reporting relationship (contacts, addresses, etc.). Federal
agencies are reminded that data is to be sent on a non-exclusive basis (all data is to
be sent to each of the consumer credit reporting agencies). See Appendix 3 for
credit reporting agency contacts.
3.
Agree to method and media in which data will be sent (magnetic tape, disks,
electronic, etc.).
4.
Prepare data for submission to credit reporting agencies. See Chapter 2 for
information on the “Metro 2" format for reporting consumer debt.
5.
Complete “Transmittal of Account Information” sheet to accompany tape, etc.
6.
Submit data to credit reporting agencies. The credit reporting agencies will return
all tapes to the respective agency after the data has been loaded into their database.
Agencies are encouraged to work with the credit reporting agencies to develop a
method to determine whether debtor data has been loaded into their database and is
being properly reported.
7.
As required by the DCIA, codified at 31 U.S.C. § 3711(e), Federal agency data
furnishers must notify consumer debtors of the agency’s intent to report a
delinquent debt; supply accurate account information; correct inaccurate
information; and research and respond to consumer disputes in a timely manner.

3-1
Chapter 3
Reporting Commercial Account Information
Reporting Commercial Accounts
The purpose of this chapter is to provide general
instructions for reporting information on commercial
debts to designated credit reporting agencies and detailed
information on the categories of information to be reported.
See OMB Circular No. A-129 for additional information.
General Instructions
The following applies to all commercial accounts:
Pursuant to OMB Circular No. A-129, and the Federal
Claims Collection Standards (FCCS), Federal agencies
shall report account information on all delinquent nontax,
non- tariff, commercial debts. Agencies shall also report
current nontax commercial debts. This information assists
debtors who are current when being considered for credit
and assists the government when determining the debtor’s
creditworthiness and ability to repay other obligations
(avoids overextension). There is no minimum dollar
threshold on the amounts for debts which agencies can
report.
C
Account information should be reported on a non-
exclusive basis; i.e., debtor information should be
submitted to each designated commercial credit
reporting agency receiving Federal data, unless
circumstances dictate otherwise. (See Appendix 3
for credit reporting agency contacts.)
C
Federal agencies will report commercial account
information on a quarterly basis. More frequent
updates may be provided as necessary to maintain
the integrity and accuracy of the information being
reported. Agencies should report complete
information on each debt, not just the updated
items.
Reporting Commercial Account Information
3-2
C
An agency should report each debt separately and
not group debts owed by a single borrower,
regardless of the amount of activity with that
borrower.
C
An agency should report capitalized interest or
other capitalized expenses as part of the debt giving
rise to the interest or expense. (For example, if
$1,000 in interest is capitalized on a $50,000 debt,
the amount to be reported as a single account would
be $51,000.)
C
In case of participation loans (loans consisting of
both guaranteed and direct portions or involving
more than one lender) an agency would report only
the direct participation amount. The guaranteed
amount would become reportable if the agency
acquires the guaranteed portion in satisfaction of a
default claim.
An agency should furnish the account information
electronically, on magnetic tape, disks, manually, or in any
other media agreed to by both parties. Magnetic tape
information should be prepared in the format provided at
the end of this chapter. An agency should report all of the
information listed in this section (beginning on Page 3-4)
for each account. Agencies currently unable to do so
must, at a minimum, provide the information below
that is indicated with an asterisk (*). This information is
essential for the adequate identification of an account.
Provisions should be made, however, for providing all
items of information as soon as possible.
Reporting Commercial Account Information
3-3
Requests by the credit reporting agencies for additional
categories of information not included in this document
should not be honored unless authorized by law, and agreed
to by the agency, and the Debt Management Services of the
Financial Management Service (FMS) has been informed
of the request. See Appendix 3 for the Debt Management
Services contact information.
Reporting Debts Being Collected by FMS’ Debt Management Service (DMS)
With some exceptions, the DCIA requires that Federal
agencies transfer to Treasury, or a Treasury-designated
debt collection center, all debts which are greater than 180
days delinquent (see 31 U.S.C. § 3711(g)).
Federal agencies have the option of transferring delinquent
debts prior to the expiration of 180 days, provided they
have completed all due process requirements, and they
certify the debts as required by 31 C.F.R. § 285.12.
Agencies have two options for credit bureau reporting once
they have referred cases to the Financial Management
Service’s Debt Management Services (DMS) for debt
collection, a process known as “cross-servicing:” (1) they
may continue to report the cases to credit reporting
agencies, and DMS will not do so; or (2) they may cease
reporting, and DMS will report to credit reporting agencies
on the Federal agencies’ behalf. Federal agencies are asked
to select the option they prefer when completing the “DMS
Cross-Servicing Agency Profile” form (see Appendix 4).
Further information on DMS cross-servicing can be found
in the DMS publication “Cross-Servicing Implementation
Guide” at: http://www.fms.treas.gov/debt/crosserv.html.
As a part of its regular debt collection procedures, DMS
will report debts it is collecting to the appropriate
designated credit reporting agencies. If a credit reporting
agency notifies DMS that a debtor has disputed the validity
or accuracy of a debt, DMS will notify the creditor agency
of the dispute. If the creditor agency does not recertify the
Reporting Commercial Account Information
3-4
debt within the specified time, DMS will return the entire
debt file to the agency and cease all further collection
efforts, including referral to credit reporting agencies. See
Appendix 3 for DMS contact information.
Handling Disputed Information in Commercial Debtor Files
While it is not required by law, Federal agencies should
handle disputed information from their commercial debtors
in the same manner as consumer disputes (see Chapter 2).
Disputed information should be investigated and resolved
in a prompt and timely manner. The credit reporting
agency contacts listed on Appendix 3 are available to
assist with dispute resolution.
Commercial Account Data Elements
(*) Designates required field
Identification
Elements
*(1)
Account Number: Each debt must have a unique
account number. This should be the discrete
alphabetic, numeric or alpha-numeric code which
identifies each individual debt.
Codes which are based primarily on Social Security
Numbers or Employer Identification Numbers are
acceptable only if the agency can distinguish
between different debts which may have been made
or other types of credit which may have been
extended to a single entity and if otherwise
authorized by law. An additional character added to
the code could be used to make such distinctions.
In order to avoid potential reporting errors, account
numbers should not be re-used or re-issued once an
account has been closed.
Reporting Commercial Account Information
3-5
*(2)
Taxpayer Identification Number (TIN): This is the
number used to identify individuals and businesses
by the Internal Revenue Service (e.g., Social
Security Numbers and Employer Identification
Numbers). In accordance with the DCIA and OMB
Circular No. A-129, agencies are required to obtain
the TIN of all persons or entities with whom it does
business. See 31 U.S.C. § 7701(c). When
transmitting files to a credit reporting agency, the
TIN can be omitted only if the agency has
exhausted all means to obtain it. NOTE:
Delinquent debts should be reported even if
agencies are unable to locate and provide a TIN. In
instances where the TIN is not available, this field
of the reporting format submitted to the credit
reporting agency should be zero filled.
*(3)
Name: This should identify the individual(s) or
entity who is primarily legally liable to repay the
debt. Agencies should require the debtor to notify
them of any changes to legal liability. Agencies
should maintain the name(s) and address(es) of the
debtor(s) of record, guarantors, and any other
legally liable parties.
*(4)
Address: This should be the address of the principal
residence or place of business of the legally liable
individual(s) or entity which corresponds to the
reported name, including city, state and zip code. A
street address should be provided; route numbers
and/ or post office boxes should be avoided
whenever possible.
Debt Elements
*(5)
Type of Debt: Report the type of debt (e.g., loan,
overpayment, fee, fine, penalty, claim, forfeiture,
rent, royalty, damages, audit disallowance, sale of
goods or services, advances for services or goods no
longer required, miscellaneous, or other).
Reporting Commercial Account Information
3-6
*(6)
Date Debt Initiated: In the case of a loan or line of
credit, this is the date when the Government made
the legal commitment to extend credit. If this date
is unavailable, report the date of the initial
disbursement of funds or the date of the loan
closing, whichever is earlier. For other types of
debt, the date to be provided is the date the debt was
created or assessed. For example, use the date of
sale if the debt arose as the result of an installment
sale, or date of assessment in the case of a fine or
fee. The date that the debtor was notified of the
debt should not be used unless this is the date the
debt was established (e.g., certain administrative
debt).
* (7) Amount of Debt: Report the full amount of the
original debt, principal only. (Report dollars only)
(8) Maturity Date: Report the date by which the debt is
due to be repaid in full.
(9)
Frequency: Report how often payment is made
(e.g., monthly, quarterly, semi-annually, annually,
or irregularly.)
(10)
Security: Report a loan as “Secured” (or “S”) if
collateral had to be pledged as part of the original
loan agreement and the value of the collateral is
known to be equal to or greater than the full loan
amount. In any other circumstance, this category
should be left blank.
Current Activity
Elements (Status Codes)
(11)
Status: Report the current status of the debt as
identified below:
(a)
current -- payments are up-to-date, and the
account is in good standing.
Reporting Commercial Account Information
3-7
(b)
delinquent -- indicates that at least one
repayment of the loan or debt is overdue.
This classification should be used when
there is no other status which better
describes the account.
(c)
in default -- indicates 90 or more days past
due.
(d)
in collection -- account has been assigned to
an attorney, collection agency, an agency’s
internal collection department.
(e)
contested -- terms or amounts are in dispute;
however, case has not gone into formal
proceedings.
(f)
in litigation – court proceedings are
pending.
(g)
foreclosure started -- proceedings which will
lead to foreclosure have been undertaken.
The term “foreclosure” is usually used for
mortgaged property.
(h)
foreclosed -- foreclosure has been
completed.
(i)
repossessed collateral -- collateral has been
repossessed, either voluntarily or
involuntarily.
(j)
written off /currently not collectible --
amount of loan or debt has been written off,
however the Agency has determined to
continue to pursue further collection efforts.
Reporting Commercial Account Information
3-8
(k)
settled -- (compromised) account legally
paid for less than full balance and the debtor
has no further legal obligation.
(l)
paid in full -- account repaid in accordance
with agreement, no outstanding balance due.
(m)
paid in full/was in collection -- account has
now been paid, although it had gone to
collection.
(n)
paid in full/written off -- account has now
been paid, although the account had been
previously written off.
(o)
paid in full/was repossession -- account has
now been paid, although repossession had
occurred.
(p)
cannot be located -- entity has gone out of
business or cannot be found at any address.
(q)
written off/closed-out or discharged -
collection action has terminated and no
further collection efforts are warranted.
Account was reported to IRS on Form
1099C.
(r)
other (specify).
Since these classifications are not intended to be
mutually exclusive, more than one may apply in
some situations; however, the classification
reported should be the one which most
accurately reflects the current collection activity
of an account.
Reporting Commercial Account Information
3-9
Some status classifications must be considered to
override others. The following are such
classifications, in order of priority; (a) debtor
cannot be located; (b) account has been foreclosed;
and, (c) in litigation. Information on bankruptcies
will be obtained by credit reporting agencies from
public records and included on the appropriate
credit report. “In bankruptcy” is not to be reported
by agencies as an account’s status. “In collection”
should be reported instead.
(12)
Amount of Debt Outstanding: The amount to be
reported is the total amount currently owed on the
debt, including all interest and late fees.
(13)
Past Due Amount: The amount to be reported is the
amount which is overdue, including financing
interest and all late charges.
(14)
Date of Most Recent Payment: Report the most
recent date on which payment was received. If no
payment has been received, leave blank.
(15)
Date of Violation: This is the date on which the
most recent violation of the agreement occurred, if
applicable. If the violation is a delinquency, report
the date the debt became delinquent. If a grace
period is given for payment (e.g., 30 days after the
due date before additional charges are levied), the
debt becomes delinquent if the period ends without
payment. However, the date of delinquency is the
original due date, not the date which designates the
end of the grace period.
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3-10
Agency Identification
Elements
(16)
Contact Person: Report the name and telephone
number for the individual designated as contact for
the lending agency or division responsible for
handling the debt.
*(17) Federal Creditor Agency: Report the department,