The 5 Points of METRO2 Compliance form the framework that all Compliance Challenges are based, so they are worth reviewing. All the Points of Compliance are based on the bureau’s own reporting regulations and standards, so essentially, this is holding them accountable for their own rules.
Point 1. e-Oscar is a web-based, METRO2 compliant automated system: this is very important, because while the bureaus have utilized METRO2 reporting standards for quite some time, it was not until this phrase was officially added into their regulations in 2015 that challenging the METRO2 compliance of the reported accounts became a viable method for credit repair. What this means is that the bureaus themselves have explicitly stated that they are going to be METRO2 compliant as their own personal standard. Now that it has been said…it must be followed.
What is e-OSCAR
The e-OSCAR system is a web-based, METRO2 compliant system that has been developed by Equifax, Experian, Innovis and TransUnion. It is the 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 several 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.
Point 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 forced to be METRO2 compliant, but anyone they share information with. This is a huge deal because not only is the reporting bureau required to be METRO2 compliant, but the companies who send information to the CRA’s must be compliant as well, which requires several more steps to attempt to prove.
Point 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 LexisNexis, 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.
Point 4. The ACDV is returned to the initiating CRA with updated information (if any) relating to the consumer’s credit history: AFTER the DF has found what it has found, they then report back to the requesting DF or requesting CRA with their findings. If it was a third-party DF, they return it to the DF that requested it with the instructions to update their files to then turn around and forward the findings to the originating CRA.
Point 5. If an account is modified or deleted, carbon copies are sent to each CRA with whom the DF has a reporting relationship: METRO2 Compliance mandates that carbon copies (Carbon Copies!!) be sent out. Also, the regulation says that simply sending carbon copies to the other bureaus is not sufficient. They are required to send carbon copies to ALL the places they have reporting relationships with that they have shared that reporting with. 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 regard to this client. This fact alone makes it virtually impossible to comply with METRO2 reporting standards. Even providing that the DF has carbon copies, how would they construct hundreds of them for each individual that disputes or challenges an item on their credit profile?
Going a bit further, let’s 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 USPS Snail Mail. Even with a high-volume discount from USPS, this quickly becomes too heavy a cost. It is quite simply a million times easier and more affordable 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.