OCC 2000-3
Subject: Consumer Credit Reporting Practices
Description: FFIEC Advisory Letter
Date:  February 16, 2000	

TO:	Chief Executive Officers of All National Banks, 
	Department and Division Heads, and All Examining 
	Personnel


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) 874-5170.




_________________________
David D. Gibbons
Deputy Comptroller for Credit Risk


Attachment - FFIEC Letter to Chief Executive Officers