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FCRA regarding $75,000 plus salary and $150,000 plus purchas


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I was curious after reading the FCRA concerning the exception for persons earning a salary over $75,000 and purchases amounting over $150,000. Does this mean that the seven year reporting rule does not apply here...that CRAs may report older information in these instances to future employers and banks when credit is checked? If not, what does it mean?

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B) Exempted cases. The provisions of paragraphs (1) through (5) of subsection (a) of

this section are not applicable in the case of any consumer credit report to be used in

connection with

(1) a credit transaction involving, or which may reasonably be expected to involve, a

principal amount of $150,000 or more;

(2) the underwriting of life insurance involving, or which may reasonably be

expected to involve, a face amount of $150,000 or more; or

(3) the employment of any individual at an annual salary which equals, or which may

reasonably be expected to equal $75,000, or more.

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Do the CRA's know how much we make? They certainly don't list it. I thought they had to tell us everything they have on file about us? I don't see how they would know, unless creditors are telling them the "income" amounts we put on our loan applications.

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That is a good question. I am self-employed, so my income isn't listed anywhere except my tax return. Even then, that is pretty off because it includes all of my expenses.

I have also seen where income and job type is inputed into your FICO score. A "white collar" is given more points than a "blue collar" worker.

Heck, I'm the janitor and ceo of my little company, lol. Wonder where they rank me?

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Yes it does mean that jobs paying over $75,000 and loans where the principal opening balance was over $150,000 can stay on your report forever.

This is why you will always hear me tell people that if you must be late on making payments, do it on a credit card, or car loan, but NEVER NEVER NEVER on a mortgage payment.

Now to be completely fair, the section being discussed simply states limits, not requirements. If a CRA wants to drop something after 7 years that they can legally keep in the file forever, they can if they want. It puts that discretion in the hands of the CRAs.

Thankfully, I believe all the CRAs generally stick to the 7/10 year limit. With the millions of chunks of data they have, a simple retention policy is easier to manage. By sticking to the 7/10 limits it also staves off issues regarding furnishers not being around anymore (bank mergers for example) or records with the furnishers not existing.

For the record, the retention requirements for banks on loan documents is "life of the loan +20 years." The bank actually has to keep the original or a tamper-proof facsimile of mortgage docs for that long. (I was a records manager for the First National Bank of Chicago for several years).

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