DCL-08-08, Electronic - Online Solution for Complete and Accurate Reporting

DEAR COLLEAGUE LETTER

DCL-08-08

DATE: March 6, 2008

TO: ALL STATE AND TRIBAL IV-D DIRECTORS

RE: Electronic - Online Solution for Complete and Accurate Reporting

Dear Colleague:

The purpose of this DCL is to notify States of a web-based automated system, created by national credit reporting agencies, called e-OSCAR. e-OSCAR enables data furnishers (e.g., IV-D agencies) and consumer reporting agencies (CRAs) to electronically respond to consumer credit history disputes within the timeframes mandated in section 611(a)(1)(A) of the Fair Credit Reporting Act (FCRA). The FCRA requires CRAs and IV-D agencies to investigate disputes and respond back to a consumer within 30 calendar days from the date a dispute is submitted.

Prior to e-OSCAR, CRAs and data furnishers responded to consumer disputes by mail, telephone, and/or fax. Given the stringent FCRA timeframes to resolve disputes, in 2004 CRAs started requiring furnishers to use e-OSCAR. The four largest CRAs - Experian, Equifax, Innovis, and TransUnion use e-OSCAR. Even though CRAs mandated data furnishers to use e-OSCAR to resolve disputes, three CRAs (Equifax, Innovis, and TransUnion) use e-OSCAR but also continue to resolve disputes by mail, telephone, and/or fax. Presently, Experian is the only CRA using e-OSCAR exclusively. However, the three other CRAs have confirmed that they, too, will eventually only use e-OSCAR.

The impact to those States that are not currently using e-OSCAR may be significant. For example, any obligor who disputes his/her arrearage or claims a mistake of identity with Experian, will result in this CRA updating the debt to current or deleting the arrearage completely from the credit report. As mentioned previously, Experian will resolve disputes using only the e-OSCAR interface. If a Child Support Enforcement agency has not signed up for e-OSCAR, this CRA has no other recourse but to update the credit report based on the obligor’s claim. As the three remaining CRAs transition to the usage of e-OSCAR only, the impact may become even more considerable to States. The overall impact may be the reduction in collections, in addition to noncompliance of credit reporting and FCRA requirements.

States can determine who within the Child Support Enforcement agency should access e-OSCAR and how the system is administered for the State. There can be one or more users within one office or multiple users in multiple offices; this will depend on each State’s preference and/or workload. Also, the e-OSCAR website provides an online help desk that can aide IV-D agencies implement the system within each State.

The initial registration for e-OSCAR is free. However, there is a $21 quarterly fee to use the system; this fee includes a minimum number of transactions per quarter. Once the minimum number of transactions has been reached, a $0.30 charge for each additional transaction sent or received will be added to the quarterly fee. Offices will receive an invoice at the beginning of each new quarter for their previous three months' usage.

Presently, 14 States are realizing the benefits of using e-OSCAR. These benefits include: compliance with FCRA, updating consumer disputes more quickly, updating all participating CRAs at one time of dispute resolution, and notifying CRAs of correct arrearages.

To use e-OSCAR one must register at www.e-OSCAR.org. There are five steps:

Step 1: Obtain a Subscriber Code
Step 2: Select Company Code and Create an Administrator User ID/Password
Step 3: Select Business Type
Step 4: Print Summation Page (within 7 days you will receive a telephone call or an e-mail notification)
Step 5: Complete e-OSCAR training (Once your Registration is approved, you must complete an e-OSCAR online training tutorial. The tutorial will automatically launch when you log-in for the first time. After you complete the training you will be granted system access.)

Please contact your Regional Program Manager if you have any questions.

Sincerely,

Margot Bean
Commissioner
Office of Child Support Enforcement

cc: ACF/OCSE Regional Program Managers