Accuracy of Data Reported to a Credit Bureau – NMP Skip to main content

Accuracy of Data Reported to a Credit Bureau

Jul 24, 2018

Question: We completed an examination by our regulator and just received the audit report. One item sticks out as an adverse finding and causes some concern. It deals with an FCRA violation. The regulator’s view is that we did not report accurate borrower information to a credit bureau and even questions the integrity of our reported data. So, our question is this: what constitutes accuracy? Also, what is involved in data integrity of borrower information?
 
Answer
The Fair Credit Reporting Act (FCRA) offers a description relating to “accuracy” in the context of reporting information to a Consumer Reporting Agency (CRA). Your financial institution should be providing certain pieces of information to the CRA about an account or other relationship with the consumer. The information should, at minimum:
 
1. Reflect the terms of and liability for the account or other relationship;
2. Reflect the consumer’s performance and other conduct with respect to the account or other relationship; and
3. Identify the appropriate consumer.
 
[12 CFR § 334.41(a)(FDIC); 16 CFR § 660.2(a)(FTC); 12 CFR § 222.41(a)(FRB); 12 CFR § 41.41(a)(OCC); 12 CFR § 717.41(a)(NCUA)]
 
In the context of information, “integrity” means that information the financial institution provides to a CRA about an account or other relationship with a consumer. The information being reported should, at minimum:
 
1. Be substantiated by the financial institution’s records at the time that the information is furnished;
2. Be furnished in a form and manner that is designed to minimize the likelihood that the information may be incorrectly reflected in a consumer report; and
3. Include the information in the financial institution’s possession about the account or other relationship that the appropriate federal financial institution regulator or the FTC, as applicable, has:
a. Determined that the absence of the information would likely be materially misleading in evaluating a consumer’s creditworthiness, credit standing, credit capacity, general reputation, personal characteristics, or mode of living; and
b. Listed in section I.(b)(2)(iii) of the “Interagency Guidelines Concerning the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies” (which section lists the credit limit for an account, if applicable and in the furnisher’s possession).
[12 CFR § 334.41(e)(FDIC); 16 CFR § 660.2(e)(FTC); 12 CFR § 222.41(e)(FRB); 12 CFR § 41.41(e)(OCC); 12 CFR § 717.41(e)(NCUA)]
Jonathan Foxx, Ph.D., MBA, is the Chairman and Managing Director of Lenders Compliance Group, the first and only full-service, mortgage risk management firm in the United States, specializing exclusively in outsourced mortgage compliance and offering a suite of services in residential mortgage banking for banks and non-banks. Information contained in this article is not intended to be and is not a source of legal advice. If you would like to contribute a question, please submit it to [email protected].


 
About the author
Published
Jul 24, 2018
Jobs Report Comes In Weak After Mortgage Rates Surge

Employers added just 29,000 jobs in September, sending Treasury yields lower and offering a potential counterweight to the recent rise in mortgage rates

Oct 02, 2026
Price Cuts Hit Four-Year High As Mortgage Rates Top 7%

More than one in five listings took a price cut in September, but pending sales still posted their sharpest annual decline since March 2025

Oct 01, 2026
Serious Mortgage Delinquencies Rise 19% After Five Months Of Improvement

ICE data shows 574,000 mortgages were at least 90 days past due in August, while early-stage delinquencies remained below year-ago levels

Sep 29, 2026
Smaller Down Payments Give Buyers More Room, But Rates Limit The Savings

The typical down payment fell 9% from a year ago, while shifting market conditions are giving originators different affordability conversations across the country

Sep 25, 2026
Mortgage Rates Break 7% Just As Builders Find A Way To Move Buyers

New-home sales rose 6.4% in August as builders cut prices, offered incentives, and sold more lower-priced homes. Now mortgage rates are moving against buyers again

Sep 25, 2026
Borrowers Want Digital Closings, But Some Originators Remain Hesitant

ServiceLink finds 45% of surveyed LOs cite borrower reluctance as a barrier, even though most recent buyers say digital options would influence their choice of mortgage provider

Sep 23, 2026