13 CONSUMER FINANCIAL PROTECTION BUREAU
raise particular concerns about the accuracy and interpretation of collections tradelines, the vast
majority of which are furnished by debt collection agencies and debt buyers.
16,17,18
In its 2012 white paper on the U.S. credit reporting system, the CFPB reported (based on
interviews with the three largest NCRAs) that debts in collections accounted for 13
percent of tradelines in credit reports.
19
These tradelines however, accounted for nearly
40 percent of consumer disputes about inaccurate information handled by the NCRAs
through e-OSCAR, the online dispute system used by data furnishers and the NCRAs to
create and respond to consumer credit history disputes.
20
16
The Federal Trade Commission (FTC) found that 5 percent of consumer records had errors that could negatively
impact a consumer’s ability to get favorable loan terms. The study observed that one in four consumers (24
percent) identified what they believed to be an error on at least one of their three credit reports from an NCRA.
Among 1,001 consumers who reviewed their credit reports, collections tradelines accounted for 502 of 1,210
alleged inaccuracies identified by consumers regarding non-header information on their credit reports. Collections
tradelines accounted for 267 of 662 errors that were modified following consumer disputes regarding non-header
information.
17
Federal Trade Commission, Report to Congress under Section 319 of the Fair and Accurate Credit Transactions
Act of 2003 at 5, December 2012., available at
http://www.ftc.gov/sites/default/files/documents/reports/section-319-fair-and-accurate-credit-transactions-act-
2003-fifth-interim-federal-trade-commission/130211factareport.pdf.
18
The May 2011 study on credit reporting accuracy by the Policy and Economic Research Council (PERC) also found
similar results with small differences. For example, one in five credit reports (19 percent) were alleged by
consumers to have one or more potential inaccuracies on their records. In the PERC study, 1,970 potential
inaccuracies (potentially material and not material) were identified in the 3,876 reports examined. See Michael
Turner, Robin Varghese & Patrick D. Walker, PERC Results and Solutions, U.S. Consumer Credit Reports:
Measuring Accuracy and Dispute Impacts (2011) available at http://www.perc.net/wp-
content/uploads/2013/09/DQreport.pdf.
19
The percentage of all credit report tradelines we estimated to represent accounts in collection in our 2012 white
paper is larger than the 9.1 percent of tradelines we identify as collections tradelines in the Bureau’s CCP. The
2012 figure represents the average of responses to a question submitted to all three NCRAs regarding the
percentage of tradelines that represent accounts in collections; responses from the three NCRAs differed. In
addition, our question did not narrowly define an account in collection as narrowly as we do here (where we define
a collections tradeline as an account reported carrying a specific designation as defined in NCRA furnisher
guidelines). The 2012 figure may include accounts that are severely delinquent and may have experienced a
charge-off, but have not been furnished as collections tradelines.
20
Consumer Financial Protection Bureau, Key Dimensions and Processes in the U.S. Credit Reporting System: A
review of how the nation’s largest credit bureaus manage consumer data at 29 (September 2012) available at
http://files.consumerfinance.gov/f/201212_cfpb_credit-reporting-white-paper.pdf.