Understanding METRO2 Compliance
To begin understanding what METRO2 is, you must also understand what it is not.
METRO2 is not a credit repair method. That makes it sound far simpler than the reality, and it deserves some real explanation. If you have been the credit repair space for any amount of time then you are probably at least minimally familiar with the consumer protection laws like the Fair Credit Reporting Act, the Fair Credit Billing Act, Equal Opportunity Credit Act and the Fair Debt Collection Practices Act. You also must remember that these laws and standards were created by politicians that are not familiar with the credit reporting industry. You can probably look at different places in your own career and understand that someone who does not understand the ins and outs of any particular industry might not be the most qualified to create functional regulations for the inner workings of that industry.
For example, a politician without an education degree or any sort of education background has no idea about what a teacher who’s job is to educate a classroom full of your children goes through each day, and are not well placed to create regulation that affect a teacher’s job. Sadly, politicians do just that every day, in virtually every industry. That does not mean that the FCRA and those regulations are not good things that protect consumers, it simply means that in order to functionally implement such regulations, the Credit Bureaus had to create a standard of reporting for any creditor or Data Furnisher that wanted to place information onto a consumer’s credit report.
Add to this that each industry that reports to the credit bureaus has its own set of standards and regulations, as well as it’s own type of information that needs to go onto a credit report. A credit card company reports different information than a mortgage company, which reports different information than a auto lender, a student loan servicer, a collection company, a medical debt servicer, and so on. So, in order to effectively report the data from all the different types of industry accounts as well as stay within the bounds of the different consumer protection laws, the Credit Bureaus and Data Furnishers developed the METRO2 system software language.
With the creation of the METRO2 language and software, the credit bureaus were able to implement a universal language and standard of reporting that all companies must use in order to send data about their customers to the bureaus, who will then add that information to the consumer’s credit report. The METRO2 system is a fully FCRA-complaint system, so one of the benefits when the Credit Bureaus implemented the system is that it enabled banks to comply with the Fair Credit Reporting Act (FCRA) and the Equal Credit Opportunity Act (ECOA).
Interestingly, the METRO2 standards for reporting an account set by the Credit Bureaus is actually HIGHER than the standard set by the politicians in the consumer protection laws, meaning that it is possible for an account reporting on a credit report to meet the minimal standards of the FCRA or the FDCPA, but not actually meet the standard of reporting the bureaus have set for themselves and anyone that reports to them.
This is important for a few reasons: First, because it opens each account up to much wider scrutiny than disputes based on the consumer protection laws alone. Second, because this also means that an account does not have to have a visible error in order to be removed from a report for not complying with METRO2 reporting standards.
These standards are so strict that in the CRGG, the Bureau’s own credit reporting guide, they state that any deviation from these standards jeopardizes the integrity of the entire account. Recently, federal regulators have placed an increased emphasis on the completeness and accuracy of the data being transmitted to the major CRAs and data being published by the each of the CRAs.
Leveraging METRO2 Compliance as a Credit Repair Tactic
Challenging METRO2 Compliance is a powerfully effective process of using the bureau’s own e-OSCAR to verify whether items on a credit report meets METRO2 compliance standards. This tactic forces e-OSCAR system to work to your benefit, not the benefit of the Credit Reporting Agencies. There is a massive difference between a traditional credit repair dispute letter and a METRO2 Compliance based request via the bureau’s own e-OSCAR system.
Sending a METRO2 Compliance Challenge triggers e-OSCAR to electronically evaluate whether all data was mandatorily perfect and complete in regard to METRO2 Formatted Reporting Standards, and was properly reported within the compliance standards set forth by the FCRA. The FCRA requires that only data which is Factually Documented to be physically verified as fully true, correct, complete as reported, timely in reporting, of a known responsibility and ownership, or else wisely validated can be legally reported on a consumer’s credit report.
With the METRO2 Compliance Request, if the check for compliance is deficient or delayed or refused or questionable in any manner, it will contest the accusing with a lawfully leveraged challenge to demonstrate the certification of factual reporting (the process of reporting as well as the item itself of reporting) which includes the mandatorily perfect and complete METRO2 Formatted Reporting Standards, the applicable requisites of the FCRA, the applicable requisites of the FDCPA, and or any other standard or regulation that might possibly be applicable. Compliance of Reporting is a minimal standard of reporting, not an optional one whereas the truth and validity of claims is a minimum standard of collection but not all items that meet collection standards meet the requisites of reporting. The fact is you can have a legally collectable item that is able to be removed from the credit report as not legally reportable because it does not comply with METRO2 reporting standards.
What this means for you is that sending METRO2 Compliance Challenges is the best way to increase the effectiveness of the letters you are sending and get the best results possible for your clients. You are leveraging the bureau’s own systems to do your work for you and bringing the power of all of the Consumer Protection laws as well as the bureau’s own self stated reporting standards at the same time.