OCC Bulletin 2000-3| February 16, 2000
Consumer Credit Reporting Practices: FFIEC Advisory Letter
Chief Executive Officers of All National Banks, Department and Division Heads, and All Examining Personnel
The guidance attached to this bulletin continues to apply to federal savings associations.
On January 18, 2000, the Federal Financial Institutions Examination Council (FFIEC) issued an advisory letter to the Chief Executive Officers of financial institutions about consumer credit reporting practices. The advisory alerts institutions that certain large credit card issuers are no longer reporting customer credit lines and/or high credit balances to the credit bureaus. Additionally, some lenders are not reporting any credit information, including payment histories, on subprime borrowers.
The advisory alerts institutions that their ability to make prudent consumer credit underwriting and account management decisions may be adversely affected by incomplete credit bureau files. It advises that institutions should have processes in place to effectively identify and compensate for missing data in credit bureau reports and models. Those that do not could inadvertently expose themselves to increased credit risk.
National banks should assess the effect of incomplete credit bureau information on their credit decision and risk management processes, and develop and implement strategies to mitigate the effect of missing information. Additionally, national banks that do not report fully to the credit bureaus should consider the still unresolved legal and reputation risks of not reporting.
For further information contact the Credit Risk Division, (202) 649-6670.
David D. Gibbons
Deputy Comptroller for Credit Risk