Metro 2 Compliance
Metro 2 Compliance is an powerfully affective process of requesting e-OSCAR to verify whether items on your credit reports meet compliance standards. This solution forces e-OSCAR to work to your benefit, not the benefit of the Credit Reporting Agencies. There is a Difference between a traditional credit dispute and a Metro 2 Compliance based request via e-OSCAR. 

The Metro 2 Compliance request is a tactic of credit enhancement that requests that triggers e-OSCAR to electronically evaluate whether the all data was mandatorily perfect and complete Metro 2 Formatted Reporting Standards was properly reported within the compliance standards set forth by the FCRA. The FCRA requires that only data which is Factually Documented to be physically verified as fully true, correct, complete as reported, timely in reporting, of a known responsibility and ownership, or else wisely validated. 

With the Metro 2 Compliance Request, if the check for compliance is deficient or delayed or refused or else wisely questionable in any manner, it will contest the accusing with a lawfully leveraged challenge to demonstrate the certification of factual reporting (the process as well as the item itself of reporting) which includes the mandatorily perfect and complete Metro 2 Formatted Reporting Standards, the applicable requisites of the FCRA and the applicable requisites of the FDCPA, and or any other standard or regulation otherwise, be it mentioned or not.

Compliance of Reporting is a minimal standard of reporting not an optional one whereas the truth and validity of claims is a minimum standard of collection but not all items that meet collection standards meet the requisites of reporting. The fact is, you can have a collectable item not be legally reportable. 

Understanding Metro 2 Compliance
At Metro 2 is the standard format for which financial institutions must electronically send data about their loan customers electronically to the major credit reporting agencies (CRAs).  One of the goals/benefits that should be derived from using a standard format should enable banks to comply with the Fair Credit Reporting Act (FCRA) and the Equal Credit Opportunity Act (ECOA).  

The Consumer Data Industry Association (CDIA) provides the definitions that go along with Metro 2 language.  Recently, federal regulators have placed an increased emphasis on the completeness and accuracy of the data being transmitted to the major CRAs and data being published by the each of the CRAs.

A review of the CFPB’s Consumer Complaint Database noted over 50,000 complaints from January 1, 2016 through February 28, 2017 related to credit bureau reporting.  The accuracy of the data being reported to and by the major CRAs is critical to a consumer’s ability to receive credit in today’s marketplace.  Below are some tips to ensure your credit bureau reporting process is complete and accurate.

What is e-OSCAR    
e-OSCAR is a web-based, Metro2 compliant system that has been developed by Equifax, Experian, Innovis and TransUnion, this automated system that enables Data Furnishers (DFs), and Credit Reporting Agencies (CRAs) to create and respond to consumer credit history disputes. CRAs include Equifax, Experian, Innovis and TransUnion, their affiliates or Independent Credit Bureaus and Mortgage Reporting Companies. e-OSCAR also provides for DFs to send “out-of-cycle” credit history updates to CRAs. 

The system primarily supports Automated Credit Dispute Verification (ACDV) and Automated Universal Dataform (AUD) processing as well as a number of related processes that handle registration, subscriber code management and reporting. 

ACDVs initiated by a CRA on behalf of a consumer are routed to the appropriate Data Furnisher based on the CRA and subscriber code affiliations indicated by the DF. The ACDV is returned to the initiating CRA with updated information (if any) relating to the consumer’s credit history. If an account is modified or deleted, Carbon Copies are sent to each CRA with whom the DF has a reporting relationship.   

AUDs are initiated by the DF to request out-of-cycle credit history updates. The system is used to create the AUD and route it to the appropriate CRA(s) based on Subscriber Codes specified by the DF in the AUD record. The e-OSCAR AUD process is intended to provide the CRA with a correction to a consumer’s file for consideration outside of the regular activity reporting cycle process. e-OSCAR may not be used to add or create a record on a consumer’s file or as substitute for “in-cycle” reporting to the CRAs.

The 5 Points of Compliance    
The 5 points of compliance for you here, some are pretty self- explanatory, however, others merit a much deeper look.

1. e-Oscar is a web-based, Metro2 compliant automated system: this is very important, because Metro2 has been around for quite some time, however it never really had any “teeth” to it until this phrase was added. This phrase simply stated, that the bureaus are going to be Metro2 compliant. Now that it has been said…it must be followed. This was added officially in 2015.

2. Credit Reporting Agencies (CRA’s) include Equifax, Experian, Innovis and TransUnion, their affiliates or Independent Credit Bureaus and Mortgage Reporting Companies: e-Oscar also provides for Data Furnishers (DF’s) to send “out of cycle” credit history updates to CRA’s: What this means is that not only are the major CRA’s held to be Metro2 compliant, but anyone they share information with…anyone. This is a huge deal for not only is the reporting to be Metro2 compliant, but also the companies who send information the the CRA’s are to be compliant as well. Many more steps to prove compliance must be completed…and as you will see, this is going to prove to be IMPOSSIBLE!

3. Automated Credit Dispute Verification (ACDV) initiated by a CRA on behalf of a consumer are routed to the appropriate DF based on the CRA and subscriber code affiliations indicated by the DF. Simply put, the CRA are required to forward all disputes to the DF who had reported the item to the CRA for verification. This also means that if a third-party reported this information, such as NexisLexis, they then have to forward the dispute to their source, i.e. SageStream. You can begin to see the mass amount of work required to get this done, and if you cannot, let me explain. See the major CRA’s have computers to do such things, others require individuals to complete this task. This creates a large demand for resources, and quite frankly becomes overwhelming for them to complete when a simple deletion request is 100X easier, less expensive and much faster to complete.

4. The ACDV is returned to the initiating CRA with updated information (if any) relating to the consumer’s credit history: So, what happens is AFTER the DF has found what it has found, they then report it back to the requesting DF or requesting CRA with their findings. More steps for them to go through. If it was a third party DF, they return it to the DF that requested it to then update their files to then turn around and forward the findings to the originating CRA. WOW…here comes the part where it is virtually impossible to be 100% Metro2 compliant. Ready?

5. If an account is modified or deleted, carbon copies are sent to each CRA with whom the DF has a reporting relationship: This is going to be a long paragraph, or several…I will begin with what I consider the obvious.

CARBON COPIES? Are you kidding me? Metro2 Compliance mandates that carbon copies be sent out. Who the heck uses carbon copies of anything anymore? Car dealerships, sometimes I assume, but I cannot think of another place that would utilize carbon copies. OK, so let us say that they do have carbon copies, all they have to do is send them out to the major CRA’s right? NOPE!

They are required to send carbon copies to ALL places they have reporting relationships with that they have shared that reporting. This DOES NOT mean just for that one bureau, or for just the main 3 bureaus, but ANY data furnisher they do business with in regards to this client. This fact alone makes it virtually impossible to comply with Metro2 by itself, providing that the DF has carbon copies, even then…how would they construct hundreds of them for each and every individual that disputes or challenges an item on their credit profile?

Let us take this a bit further… Let us assume for the moment that they do have hundreds of carbon copies ready to be made… what would it cost them to mail them to each and every place they have a reporting relationship with? They cannot fax a carbon copy, they cannot email a carbon copy, they must send it via snail mail! USPS! Even with a high-volume discount from USPS, this quickly becomes something that drains and strains their resources. It is quite simply a million times easier for them to just admit defeat for the few that know about Metro2 and request to delete the item then to go through this process to prove compliance for Metro2.

Now, the last thing I want to say is this, and this is quite possibly the greatest aspect to it all. If the consumer were to sue the DF and or the CRA for non- compliance reporting of items on their credit report, they would win 100% of the time providing the consumer had proof that they challenged, and that the challenge was received. Because in a court of law, how is a DF or a CRA going to prove this to the court system? They cannot! The DF and the CRA’s know this and quite simply are not going to send their high-priced attorney into a courtroom knowing they will lose the case. They simply delete the item when they realize that the individual sending in the challenges knows what they are doing.