FACTA 312 may seem to be tightening the rope around the neck of the Collections Industry, but investing in accurate credit bureau reporting saves time and money by decreasing your overall financial exposure and getting your debtors to come to you!

While the complexity of data reporting is more manageable for the collections industry than for lenders and other data furnishers, that doesn’t mean Debt Buyers and Collection Agencies are off the hook.  With the implementation of Section 312 of the Fair and Accurate Credit Transactions Act, Collections Industry data furnishers are required to be just as vigilant as banks and other lenders when it comes to the accuracy and integrity of the consumer information reported to the credit bureaus. 

FACTA 312 is clear.  Regardless of industry, if you report consumer account information you need to have a compliance program in place.  Are you prepared?

Reporting collections information presents special challenges. 

For the collections industry, reporting accurately after you have taken possession of accounts may not be enough.  Evaluating a seller’s credit bureau reporting standards as part of your due diligence before you purchase or begin servicing a portfolio is the key to decreasing your risk of disputes.

Not reporting yet but interested in reaping the benefits?

While using the threat of reporting a delinquency on a debtor’s credit bureau to coerce payment is never allowed, it is perfectly legal to report delinquent accounts in the normal course of business.  Investing in accurate credit bureau reporting saves time and money by getting your debtors to come to you!

What CBSC can do for Collections Industry data furnishers - FACTA 312 Compliance Consulting Services

 

CASE STUDIES

Accurate Credit Reporting - What’s it Really Worth to Debt Buyers and Collection Agencies?

#1  Disputes policy and processing is many times overlooked as part of FCRA and FACTA 312 compliance.  One national Collections Agency was recently fined a $1.1 Million civil penalty by the FTC for “incomplete or ignored investigation of disputes.”  Ignoring the disputes led to attempts to collect invalid debts, as well as report them to the credit bureaus.

#2  Bear Sterns and EMC were fined $28 Million for mortgage servicing violations, among which were issues of inaccurate credit bureau reporting.  As part of the settlement, both Bear Sterns and EMC were required to ”establish and maintain a comprehensive data integrity program to ensure the accuracy and completeness of data and other information they obtain about consumers’ loan accounts, before servicing those accounts.”