A Message Regarding NCAP
In 2015, Equifax, Experian, and TransUnion announced the National Consumer Assistance Plan (NCAP), a set of initiatives designed to improve the accuracy of credit report information, as well as to provide consumers with a better experience interacting with the nationwide Credit Reporting Agencies (CRAs).
In June 2016, the CRAs announced enhanced public record data standards for the collection and timely updating of public record data reported on consumer credit reports. The enhanced standards require:
- minimum consumer identifying information (name, address, social security number and/or date of birth) (PII)
- minimum collection frequency for public records (at least every 90 days)
Based on information provided by our public record vendor about the data available from courts and recorders offices, we expect bankruptcy public record data will continue to meet the enhanced collection and reporting standards. However, civil judgments and approximately half of tax lien data are not expected to meet the enhanced standards.
During the week of July 10, 2017, the CRAs will remove from their databases previously collected public record data that does not meet the enhanced PII standards. This includes the removal of all judgment public records and the portion of tax liens not meeting the enhanced standard. Public record data will also be monitored for adherence to the enhanced PII and collection frequency standards after July 1, 2017.
Despite the anticipated loss of significant volume of public record data from credit files, impact analysis conducted by the CRAs, as well as leading scoring model companies using CRA data, show a modest risk scoring impact and minimal loss in predictive performance as a result of these changes.
Attached are White Papers and Correspondence from the repositories regarding the studies conducted supporting their position:
- FICO NCAP PR Impact
- Vantage Score 3.0 NCAP PR Impact
- Equifax NCAP PR Impact Analysis
- TransUnion NCAP PR Impact Analysis
Beginning the week of July 10, 2017 Command will be providing a Public Record Report that will provide Liens and Judgments to our client base. Please contact your Account or Client Service Representative with any questions and to be set up for the Public Record Report.
James B Hegstetter