Is producer of merged credit reports considered CRA

[normajean]

I was reading the FTC report on Producers of merged credit reports dated October 28, 1998. It sounds to me these companies are considered a CRA and therefore they would have to investigate disputed items themselves. Is that correct? If that is the case then a person applying for for a mortgage loan that disputes their merged credit report should not have to ask for a rapid rescore if there were inaccuracies. If the Producer of merged credit reports investigated the disputed items they would have to provide a free copy of the corrected updated credit report. Am I way off here? Just wondered. Rapid rescores are very expensive. They charge per item to be rescored. Anybody have an answer? Maybe I am thinking too much.

Normajean

[DocDon]

I would have to think they are not CRA's since they do not actually receive and maintain information given to them by creditors - they simply compile information forwarded to them from the CRA's themselves.

Any time you throw a mortgage into the picture, expect to pay more - it seems their prices for everything are inflated.

[normajean]

So Doc, what does that FTC document mean?

This is what it says:

First American Real Estate Solutions, LLC("FARES") has agreed to settle Federal Trade Commission charges that First American CREDCO(CREDcO"), now a division of FARES, violated the FCRA by, among other things, failing to investigate information disputed by consumers in certain credit reports--known as instant merge reports--prepard by CREDCO,FARES is based in Florida. CREDCO is based in San Diego CA. It goes on to say when a consumer disputed information in a CR such as an instant merge report, the consumer reporting agency must investigate the disputed information and correct or delete the information if it is inaccurate. If after investigation, the CRA choosed not to chage the way it reports the information, it must include in future consumer reports a statement that the information is being disputed by the consumer and, if the consumer submits a stement describing the dispute include that statement in subsquent reports_________.

According to the FTCs complaint detailing the charges, CREDCO failed to comply with any of therse requirements in connection with its instant merge reports. The complaint states tha CREDCO typically did not investigate disputed info in its instant merge reports. Instead, CREDCO referred consumers with complaints to the national credit bureaus from which CREDCO received the disputed information . In addition, according to the FTCs complaint, on the rare occasions when CREDCo did investigate disputed information the company did not correct or delete from its files the information found to be inaccurate or obsolete. The complaint alleges further that, when such investigations did not resolve a consumers dispute and the consumer submitted a dispute statement, CREDCO neither included the consumers dispute statement in subsequent reports. Finally the complaint alleges that, when CREDCO learned through investigations that certain instant merge report information was inaccurate, it did not prevent the information form reappearing in future reports.

The proposed consent agreement to settle the charges, announced today would apply to all consumer reports that FARES creates, including its instant merge reports. the agreement would require FARES to investigate consumer report information that consumers dispute and either record the current status of the information or delete it.

There is more but i really need to learn how to cut and paste.

Normajean

[DocDon]

Here's what makes CREDCO different:

"The company was the first to provide merged credit data to the mortgage lending industry, and is the preferred provider to Fannie Mae and Freddie Mac. Today, First American CREDCO provides one of every three reports used by mortgage professionals. The company is also the leading provider of specialized credit reports to the automotive industry. Credit-granting organizations of all types and every size rely on products from First American CREDCO for credit decisions involving billions of dollars annually."

Unlike a service like Privacy Guard which simply gets its information from the CRA's, CREDCO is a CRA in that they furnish information that is directly used to establish credit worthiness.

[normajean]

Thanks Doc. So what is the best thing to do, Rapid Rescore or clean up credit and then reapply and take another hit?

the merged Credit report showed the following:

Correct Mortgage balance: $391,000. /Credit Report showing 463,301.

Correct Mortgage hgh Credit: $478,000. / CR showing 649,000.Correct Mortagage Payments: 1,700.00 / CR showing 1,927.00

Current Auto Amount $ 24,000.00/ CR showing 26,000

Correct High Auto Credit $28,778.00 /CR showing $52,000.00

Correct revolving Balance $1,700. / Cr showing $3,751.00

High Revolving Balance is $7,500.00

Correct secured Debt is $391,390.00 / Cr is shoing $489,500.00

Correct Unsecured Debt is $1,700 / CR is showing $3,700

Correct total debt owed is $393,000.00 / Cr is showing $493,206.00

Corrct total High credit of debt owed: $510.034.00 / Cr showing $708,000.

the ultimate result is to get one more score over 700. The three scores now are showing 690, 695, and 740

The delima is they are showin a equity line listed twice. They do not show a car paid off. Is it better to have a debt ratio better or to have an overall total debt low, showing a car paid in full.

Is a rescore a good idea, and on which items? They charge per item rescored.

Any advice??

Thanks doc

Normajean

[DocDon]

Normajean,

I don't know enough about rapid rescoring and don't want to give you misinformation. I would suggest you post questions about rapid rescoring for mortgages in mortgage section for the pros to answer.

As far as the other items - I would contact the creditors and advise them the information being reported is incorrect. I don't think risking having items deleted for non-response to a dispute would be in your best interest - that will definately tank your score (losing all the history).

Your DTI is often calculated to show your "potential for default", so if it's borderline, closing some accounts may be in your future. A loan officer will better be able to give you an answer to that.

You also want to show low utilization of revolving accounts (credit cards), while the available credit is factored into your DTI, showing a history of on-time payments and proper utilization (not indicating you are living off your cards by maxing them out constantly), may make up for some shortfalls.

[Diamond in the Rough]

So, I'm trying to understand. In your first response to normajean, Doc, you state that providers of trimerge reports are not a CRA, but in your second response, I think it to mean that CREDCO is a CRA, and that we can in fact dispute information with them. If so, Ive' got a bone to pick with them. Norma, could you possibly point me to the link where you found this article so that I can use it the next time CREDCO referrs me to dispute with the Big 3. Thank you.

[DocDon]

Kinda. I succeeding in confusing everyone is what happened.

"Furnishers of merged credit reports" can include companies like Privacy Guard, which simply forward information from the CRA's. Creditors don't use PG to determine your credit-worthiness. If they did, PG would too be considered a CRA.

CREDCO is used by creditors, and your ability to obtain credit is directly related to information supplied by CAMCO, so they are a CRA.

[normajean]

Doc, now I am really confused. The Trimerged is for a prequal credit report which affects my ability to get credit. It was put out by Certified Credit Reporting and provided for Home Buyers Network.

Thanks Doc

normajean

[DocDon]

If the credit report was pulled to establish your credit worthiness, they are a CRA by the definition of that FTC statement.

PG is simply a way to get all three of your reports, and to monitor them. If you get a declination based upon information received from PG, they are now a CRA....

[normajean]

Ok so I'm taking it slow. Still a little confused. Please be so kind as to understand I am completely lost!!! 8) 8) 8) So they do have to respond to a dispute. I am unclear how the PG entered into this whole thing.

Here is the link to the document: www.ftc.gov/opa/1998/10/credco.htm

I have been trying to figure out how to scan the document that the FTC put out and post it but alas, I will have to wait for my children to do that for me. Good Grief. So try the link.

Normajean

[DocDon]

No problem.

The first line of your post said "Producers of merged credit reports". There are many companies that produce merged credit reports that have nothing to do with supplying that information to creditors.... such as Privacy Guard - who simply sell merged reports to consumers.

I didn't understand that the article was written about CREDCO which supplies merged credit reports to potential CREDITORS.

CREDCO, being a CRA, must respond to disputes.

[normajean]

Ok so bottom line is Home buyers network is considered Cra. So I will dispute with them. (If this is wrong, be gentle!!!! )

I posted my question in the mortgage section. Thanks Doc.

Normajean

[DocDon]

Whomever supplied the credit report is the CRA.

[normajean]

Alrighty then! Thanks.

Normajean