Exhibit 8 of the 2023 Credit Reporting Resource Guide (CRRG) provides details on Compliance Condition Codes (CCC) used for legal compliance in consumer credit reporting. These codes are applied to indicate specific conditions such as accounts closed at a consumer’s request or disputes raised under federal laws like the Fair Credit Billing Act (FCBA), the Fair Debt Collection Practices Act (FDCPA), and the Fair Credit Reporting Act (FCRA).
These codes should not be used in response to consumer disputes initiated by credit bureaus unless required under FDCPA obligations. Each CCC remains in place until another code replaces it or it is explicitly removed using the XR code.
Types of Compliance Condition Codes and Their Uses
One code, XA, indicates that an account has been closed at the consumer’s request. When reporting this code, the Date Closed field should reflect when the account was closed to further purchases.
The XB code applies when a consumer disputes account information directly with the data furnisher under FCRA. This code should remain only while the investigation is in progress and should no longer be reported once the dispute is resolved.
If a consumer continues to disagree with the results of an FCRA dispute investigation, the XC code should be used. This code signifies that the investigation is complete, but the consumer maintains their disagreement.
For cases where a consumer both requests to close an account and disputes the account under FCRA, the XD code should be used. If the dispute investigation is completed but the consumer still disagrees, the code should be updated to XE to reflect both the closure and the continued dispute.
The XF code is used when a consumer disputes an account under the Fair Credit Billing Act (FCBA), and the investigation is still in progress. If the investigation has been completed but the consumer disagrees with the results, the XG code should be applied.
For general disputes that have been investigated and completed, the XH code is used to indicate the resolution of any disputes under FCRA, FDCPA, or FCBA.
If a consumer both requests to close an account and disputes the account under FCBA, the XJ code should be reported. This reflects both actions happening at the same time.
The XR code is used to remove a previously reported Compliance Condition Code. This code should not be used as a default value. If no compliance code applies to an account, the field should simply be left blank rather than incorrectly assigning a code.
Reporting Guidelines for CCCs
Compliance Condition Codes should be reported every month as long as the condition applies. However, they can also be reported only once, and the system will retain them until another code is applied or the XR code is used to remove them.
If a dispute is resolved, the original dispute codes such as XB or XF must be removed or replaced with the appropriate resolution code like XH or XC. If dispute codes remain active after resolution, it can create compliance issues and mislead credit reporting agencies.
Example of How CCCs Are Reported Over Time
For a case where a consumer requests to close their account, the XA code is initially reported. If the consumer later disputes information about the account under FCRA while it is closed, the code changes to XD to reflect both actions. Once the dispute investigation is completed, the code should either return to XA if the closure remains relevant or be replaced with XH if the dispute itself was resolved.
If a consumer disputes information without closing the account, the XB code would be used while the dispute is being reviewed. If they still disagree after the investigation is completed, the code would change to XC.
For accounts closed and disputed under FCBA, the process is similar, but the codes XF and XJ are used instead.
If at any point a previously reported CCC no longer applies, the XR code should be submitted to remove it.
Key Takeaways
1. CCCs indicate special conditions related to consumer credit accounts, including disputes and account closures.
2. These codes should be actively maintained and updated based on the status of disputes or consumer requests.
3. The XR code should be used only to remove a previously reported CCC, and if no compliance condition applies, the field should be left blank.
4. Keeping dispute codes active after resolution can create compliance risks, so they must be updated properly.
For more details, refer to Exhibit 8 of the 2023 CRRG.