- • Data and data entry errors: Furnishers can input accurate consumer information incorrectly or make typographical mistakes (e.g., transposing two digits in an SSN,
misspelling names, transposing first and middle names).59 Consumers (when applying for a loan) can provide inaccurate data to furnishers. For both of these types of
inaccuracies, the credit bureau could pass along the inaccuracy to the consumer’s file.
Data errors can also lead to file matching problems by causing the bureau to put the trade line into a separate or “orphan” file distinct from the consumer’s original credit
file, and thus not include it in the consumer’s credit report. Alternatively, data inaccuracy could cause a consumer’s trade line to be mixed in with another consumer’s file (e.g., when the mistake causes the consumer’s header information to match or resemble the identity of another consumer).
• Bureau file matching inaccuracies: Inaccuracies can occur when a bureau assigns a trade line to a consumer’s file or when it determines the credit file that matches the consumer named in a creditor inquiry. A matching error can occur for a variety of reasons.
- o Matching errors may result from creditor inquiries and trade lines that contain a limited set of identifiers relating to the consumer. For example, a lender inquiry may omit information such as date of birth or SSN.
o Family members with similar identity information such as fathers and sons with common names (e.g., Jr., Sr.) can experience commingling of files, especially if
they reside at the same addresses and distinguishing information is not provided.
o Unrelated individuals with similar names and identity information get linked together because a name or SSN is incorrectly inputted.
has confidence that the new information belongs to the existing consumer. A common example occurs when a consumer changes names after getting married or divorced. 25
Until the bureau can link the individual pre- and post- name change, that individual’s
information might reside in two different files.
• Bureau process errors: An example of a process error would be if a credit bureau failed to prevent the reappearance in a consumer’s credit report of inaccurate data that was
removed as a result of a consumer dispute reinvestigation. Such errors can occur despite the bureau maintaining procedures to permanently remove or suppress identified
inaccuracies as required by the FCRA.
• Identity fraud/theft: Identity thieves can compromise a consumer’s credit history by creating new credit, utility, or health care accounts in the consumer’s name and then
letting them go unpaid. As these accounts go delinquent and are pushed to collections, the consumer victim’s credit rating can plummet. Fraudsters may also take over existing
consumer accounts, often disguising the account theft by changing the billing address of the applicant with the lending institution, or making purchases over the Internet.
Additionally, fraudsters can create synthetic identities using an innocent consumer’s SSN or other identifiers like last name and birthdate.
• Furnisher system or process inaccuracies: Inaccuracies can occur because of limitations in the processes furnishers and public records providers use in handling consumer transactions. Examples include:
- o Attributing ownership to an account on which an individual is only an
o Failing to post a payment;
o Assigning a payment to the wrong account;
o Failing to update records (e.g., tax liens or other judgments that are still listed as
open even though they have been paid or resolved);
o Failing to permanently change records when a consumer successfully disputes
an inaccuracy, with the result that faulty information is re-reported;
o Listing closed accounts as open;
o Reporting an incorrect credit limit; and
o Transferring loans from one owner or servicer to another owner or servicer with
different record-keeping systems can result in lost data or lost payment records
Section 6.2 Key Dimensions and Processes in the US Credit Reporting System.
http://files.consumerfinance.gov/f/2012 ... -paper.pdf