Credit Bureau Reporting

Credit bureau reporting is a valuable enforcement tool that notifies credit bureaus of a child support debt. This can be a great incentive for NCPs to satisfy their child support debt, especially when they are trying to make a major purchase (i.e., house, car or boat). Child Support Services (CSS) currently reports to three (3) major credit bureau agencies:  Equifax,  Transunion, and Experian.

Most of the Customers Assistance Response Efforts (CARE) scripts direct the CARE Customer Service Representative (CSR) to forward a follow-up or an FYI to the district office when customers contact CSS regarding their reported status to the credit reporting agencies. District office staffs are encouraged to contact the Center for Coordinated Programs (CCP). To maintain continuity in the credit bureau referral process, all requests for manual updates to credit bureaus are to be sent to the Credit Bureau team by emailing cs.creditbureau@okdhs.org.

The credit bureau analyzer runs around the 15th of each month looking for payments logged on OSIS since the last analyzer run. The OSIS system automatically updates credit bureau information every 30-35 days.

Customers can also dispute their credit report directly to the credit reporting agencies by visiting the credit bureau website(s). The Program Coordinator monitors these customer disputes using the E-OSCAR service. Reviewing the disputed referrals and makes any adjustments necessary to ensure our customers are treated fairly by the CSS credit bureau reporting process.

Things to know about the Credit Bureau Analyzer

• CSS does not report on cases that have less than a $15,000 balance.
• Runs around the 15th of each month looking for payments logged on OSIS since the last referral cycle.
• Checks prior two months plus 15 days for initial referral – checks prior one month plus 15 days for ongoing referral – this allows for unexpected complications in getting payment in on time (income assignment periodic payment schedule, mailing time, etc.)
• Interest balances are not referred to the credit reporting agencies.
• Rewards paying customers by setting a 92% threshold on monthly child support due.  If NCP pays at least 92% of the monthly due, analyzer refers as “current account”.

The Credit Bureau analyzer will refer cases that meet the following criteria:

• Case status is 02, 06, 08, or 10;
• Case is posting monthly amount due, either current support, judgment payment or both;
• Service type on the CSCU screen is “F” (full service); and
• Case is in-state or incoming interstate (outgoing interstate do not refer).

Analyzer Exception Edits

• NCP incomplete name in OSIS (missing first or last name will reject FGN);
• NCP under 18 years of age;
• NCP invalid SSN (valid does not always mean verified);
• No NCP type 01 address for the NCP, either current or last known;
• Non-discharged bankruptcy filed by NCP prior to 10-17-05; and
• Resolved duplicate FGNs are rejected with description “case is a resolved duplicate” (If the true FGN has been referred to credit bureau the resolved duplicate will report to credit bureau as “PAID OR CLOSED ACCOUNT/ZERO BALANCE”).

Cases analyzed but not referred are written to the CMOD report (CS021R01 Credit Bureau Exception Report) and can be viewed by child support specialist as needed.

Initial Referral

If the case otherwise meets criteria for referral, the analyzer runs through two (2) additional edits before referring the case for the first time:

1. The case must have at least two prior completed months of financial history.
2. Is the monthly child support due paid in full or at least to the 92% threshold?  If YES and there is an arrearage:
   1. Is the arrearage greater than or equal to $15,000?
      If YES, the case is referred as CURRENT ACCOUNT. If NO the analyzer reads the NCP is meeting their obligation and the case is not referred to the credit bureaus.  The case is written to the exception report for staff review.
   2.  If the monthly child support due IS NOT being paid at the minimum level of the 92% good paying customer threshold, the case is referred with a status of ACCOUNT ASSIGNED TO COLLECTIONS even if arrears are under $15,000.

Cases that meet the criteria for an initial referral auto-generates a “Notice of Credit Bureau Referral” to the NCP. If there is no response from the NCP, the initial referral is made during the next referral cycle.  An automated case log entry is made. The document sent to the NCP is listed on the DOCL and NL screen and can be viewed by child support staff.

Ongoing Referral

Once a case has been referred to the credit bureau reporting agencies, it will continue to be referred, until current support and any arrearage debt is no longer owed. The referral status will change as the collection status changes. The CBRI screen lists the collection status of the referral to credit bureaus.

An automated case log entry is generated when the reported collection status changes.

Closure Referral

• Cases that have been referred and then change to an outgoing interstate case will be updated to “ACCOUNT TRANSFERRED TO ANOTHER OFFICE”;
• Some states continue to refer even after they send the case to Oklahoma as incoming interstate.  To avoid double reporting Oklahoma can manually close the referral. These referrals will also be closed as “ACCOUNT TRANSFERRED TO ANOTHER OFFICE”;
• Cases that have been referred and changed to status 04 (closed) in OSIS will automatically update to a closed status in the next referral cycle;
• Cases that have been referred in error will be closed with status “DELETE ENTIRE ACCOUNT”.  This is a Center for Coordinated Program function which can be emailed to cs.creditbureau@okdhs.org requesting manual updates; and
• Cases that fall outside of these reasons can be closed manually as necessary.

When a credit bureau referral is closed for any reason, an automatic case log entry is generated.

Legal Authorities:

• Federal: 42 USC § 666(a)(7) and 15 USC § 1681b and 1681f
• State: 56 O.S. § 240.7
• OAC 340:25-5-265 Release of arrearage information to consumer reporting agencies – credit bureaus; and
• OAC 340:25-5-200.1 Administrative review process.