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Special Comment Codes
The Credit Bureau Special Comments can be user-entered, or in most cases, the system assigns a Special Comments code based on specific activity, as explained in the table below. The Special Comments codes allow you to better clarify the Credit Bureau account status that has been reported for that month.
Note: See CO in the table below for options that will affect whether or not an account is assigned Special Comment CO (account modified). |
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When hold codes 7 (legal hold), 9 (legal hold or in foreclosure), 94 (paid account—foreclosure started), 96 (paid account—was collection), or 99 (settled—paid in full—less than full balance) are on the loan, you should also enter a Special Comment code.
The system will not validate that your entry is the correct one for this account status. File maintenance to this field writes to loan history.
Note: Occasionally, customers will have two or more Special Comment codes to be reported to Credit Bureaus. However, only one Special Comment code is allowed per customer per reporting month. Consequently, a screen is available that allows you to prioritize which Special Comment code should take priority for Credit Reporting purposes. This screen is found under Loans > System Setup Screens > Special Comment Priorities. |
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Valid codes on the drop-down list are as follows:
Special Comment Code |
Description |
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Blank |
Removes any previously reported Special Comment codes.
•If there is a Hold Code 1 (foreclosure completed) and Special Comments equals BO, then Special Comments (BUSPCM) is cleared to blanks during the monthend credit reporting process. •If there is a Hold Code 7 or 9 on the account and Credit Bureau Account Status (BUCBRS) equals 11 (Account Current) and Special Comments equals BO, then BUSPCM is cleared to blanks. |
B |
Account payments managed by Credit Counseling Service. If you check the Consumer Credit Counseling box (MLCCC) on the Loans > Account Adjustment screen, the system automatically assigns the account Special Comments code "B" (Account payments managed by Credit Counseling Service). This excludes account that previously had Special Comments code equal to BO.
See Payoff Note below. |
C |
Paid by co-maker.
See Payoff Note below. |
H |
Loan assumed by another party (requires ECOA Code "T" (Association with account terminated).) |
I |
Election of remedy (Example: A car is repossessed, but the value of the car is less than the balance due. The credit grantor must consider the account paid and cannot collect the difference in the amounts.) |
M |
Account closed at credit grantor's request |
O |
Account transferred to another lender. The Special Comment Code can equal "O" or "AT" (see below) but neither are guaranteed to happen if your institution doesn't use the Special Comment Codes or they are overidden by another Special Comment Code. (This is designated on the Loans > System Setup Screens > Special Comment Priorities screen in CIM GOLD.)
At monthend, the Credit Reporting update function will populate the "O" if the account is released and it wasn't an inter-office move. If the Special Comment Code is designated as "O" by the system, the Scheduled Monthly Payment Amount (Base field 9), Current Balance (Base field 21), and Amount Past Due (Base field 22) will be reported as "0" and the Date Closed (Base field 26) will be the date the account was transferred to another lender.
Accounts closed due to transfer are reported for the first month after the transfer. For the months following that first reporting month after the transfer, the account is no longer reported.
Note: A report option designates how long to report closed accounts. Your GOLDPoint Systems account manager needs to set the last two fields in the Miscellaneous Parameters field on the Report Setup Screen with the number of months to continue reporting closed accounts, as shown below. If this option is blanks or the number of months is "00," then the account will default to reporting for 3 months (the month it closed plus two more).
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S |
Special handling (contact credit grantor for additional information)
If institution option OP24 SPHC (Add Special Handling Code) is enabled, the account has an Action Code 154 (partial charge-off date) in the current month as well as an Action Code 93 (repossession date), but does not have a Special Comment Code of BO, AI, AU, or AT, then this field will be updated to "S" (special handling).
See Payoff Note below. |
V |
Adjustment pending |
AB |
Debt being paid through insurance. If the Insurance Payment transaction (tran code 2600-01) is run for at least two consecutive months, the system automatically assigns Special Comments code AB (Account being paid by insurance) to the account for Credit Reporting purposes. |
AC |
Paying under a partial payment agreement |
AH |
Purchased by another lender |
AI |
Recalled to active military duty. If you check the Guard/Reserve on Active Duty checkboxes on the Loans > Account Adjustment screen, the system automatically assigns the account Special Comment code "AI" (Recalled to active military duty). |
AJ |
Payroll deduction |
AL |
Student loan permanently assigned to government |
AM |
Account payments Assured by Wage Garnishment. If a Garnishment transaction (tran code 2600-30) is run on the account, the system marks this field with this code. After monthend is run, the Special Comments Code is cleared, unless another garnishment payment is made. Note: Garnishment transactions cannot be run for accounts with Hold Code 4 or 5 (bankruptcy).
See Payoff Note below. |
AN |
Account acquired by FDIC |
AO |
Voluntarily surrendered - then redeemed |
AP |
Credit line suspended |
AS |
Account closed due to refinance. This field is automatically populated with the AS code when GOLDTrak PC closes a loan during a renewal/refinance. |
AT |
Account closed due to transfer. If loan is service released (LNRLSD=Y) and Inter-Office Move to Account (M1IOTA) is not zero, then Special Comments equals AT. The Special Comment Code can equal "O" (see above) or "AT" but neither are guaranteed to happen if your institution doesn't use the Special Comment Codes or they are overidden by another Special Comment Code. (This is designated on the Loans > System Setup Screens > Special Comment Priorities screen in CIM GOLD.)
If "AT" is designated on the account by the system, the Scheduled Monthly Payment Amount (Base field 9), Current Balance (Base field 21), and Amount Past Due (Base field 22) will be reported as "0" and the Date Closed (Base field 26) will be the date the account was moved to another office.
IMPORTANT: The AT is only reported for an inter-office transfer account if it is not possible to report the account transfer using the L1 Segment of the Credit Report transmission, which is the preferred way to report an inter-office account transfer. The monthend credit reporting function does report the released account with "AT" (if it hasn't been opted out and it is highest in priority), but when we report an inter-office transfer, we use the new account for all the account information and the new account will not have the AT designation. The old account number will be reported in the Base Segment and the new account number will be reported in the L1 Segment. The Credit Bureaus use the account information with the L1 account number to start the new account reporting information, and the old account number from the Base Segment is used to close the old account in their tracking. Because the new account is used to report the credit line, the AT doesn't show up when using the L1 Segment.
Note: A report option designates how long to report closed accounts. Your GOLDPoint Systems account manager needs to set the last two fields in the Miscellaneous Parameters field on the Report Setup Screen with the number of months to continue reporting closed accounts, as shown below. If this option is blanks or the number of months is "00," then the account will default to reporting for 3 months (the month it closed plus two more).
|
AU |
Account paid in full for less than the full balance. If there is an amount in the Written Off Amount field (LNPWOA), the system reports the account with Special Comment code AU. |
AV |
First payment never received. When the end-of-month credit reporting function runs and the first payment on an account has not been made (the loan is 30+ days overdue and Installments Made (LNINNO) is equal to 0), the system assigns "AV" in the Special Comments field. |
AW |
Affected by natural or declared disaster.
If institution options K402 and K403 are set up for your institution, the system will automatically assign Special Comment Code "AW" on the account if a deferment using Deferment Reason Code 6 was run on the account. The Deferment transactions that allow Deferment Reason Codes are:
•Deferment Payment Transaction (tran code 2600-11) •Deferment By Code Transaction (tran code 2600-13) •No Rules Deferment (tran code 2600-17) •Deferment with Reason (tran code 2600-35) •Fee Reg Deferment (tran code 2600-50)
Note: Deferment Reason Code 6 must be set up on the Loans > System Setup Screens > Deferment Reason Codes screen. We suggest giving Deferment Reason Code 6 the name of "Declared Disaster."
You can also manually assign Special Comment Code "AW," as well as any Special Comment Code, to any account. At monthend, the system applies the Special Comment Code based on specific activity on the account. During the window after the system runs monthend and before the Credit Reporting transmission is sent (usually three or four days), you can manually update the Special Comment Code field to anything your institution wants to report.
Remember: Occasionally, customers will qualify for two or more Special Comment Codes to be reported to Credit Bureaus. However, only one Special Comment Code is allowed per customer per reporting month. Consequently, a screen is available that allows you to prioritize which Special Comment Code should take priority for Credit Reporting purposes. This screen is found under Loans > System Setup Screens > Special Comment Priorities.
The system will update the deferment start and end dates and report them in the K4 Segment of the Credit Report and transmission. See the K4 Segment description for more information. |
AX |
Account paid from collateral. If the Sale of Security transaction (tran code 2510-03) is run and the account closes (is paid off) due to the transaction, the system automatically assigns Special Comments code AX (Account paid by security) to the account.
See Payoff Note below. |
AZ |
Redeemed repossession |
BA |
Transferred to recovery. This can only accompany accounts with the Account Status of 71-97. Accounts that received the BA Special Comment Code have both Hold Codes 2 (charge-off) and 91 (collection account) and an Account Status of 71-97. |
BL |
Credit card stolen |
BN |
Paid by company that originally sold the merchandise
See Payoff Note below. |
BO |
Foreclosure proceedings started. If there is a hold code 7 (legal hold) or 9 (legal hold or in foreclosure) on the account and Credit Bureau Account Status (BUCBRS) does not equal 11 (account current) and BUSPCM equals blanks, then during the monthend processing, the Special Comments code is set to BO. |
BP |
Paid through insurance. If the Death Claim Payment transaction (tran code 2600-06) is run and the account closes (is paid off) due to the transaction, the system automatically assigns Special Comments code BP (Account paid by insurance) to the account.
See Payoff Note below. |
BS |
Prepaid lease |
BT |
Principal deferred/Interest payment only |
CN |
Loan modified under a federal government plan |
Loan modified — not under a federal government plan. The system automatically assigns Special Comment code "CO" to accounts where loan modification took place during the month. Institution options are available that designate when the system applies the "CO" code. The system can assign the CO code to an account if the P/I Constant, Interest Rate, Term, or any combination of the three are changed. Your GOLDPoint Systems account manager can set up these options for you (see box below).
Additionally, if a first payment has not been made (Installments Made (LNINNO) equals 0) and the original principal/interest payment (LNOPIC) is different from the current principal/interest payment (LNPICN), the system will not assign Special Comments code CO. Sometimes loans have an odd first payment, which should not qualify as principal/interest change.
If the current or next P/I amount match the Original P/I Constant, this code will not be used.
See GOLDPoint Systems Only below for institution options that affect CO Special Comment Codes. |
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CP |
Account in forbearance.
If the loan is in deferment, you can assign the account this Special Comment Code. The system will automatically assign Special Comment Code "CP" if a Hardship Deferment was run on the account from the Loans > Transactions > EZPay screen or from tran code 2600-20 (Hardship Deferment) in CIM GOLDTeller. The CP Special Comment Code is not applied until the Credit Reporting monthend runs.
If the deferment was due to a declared disaster, you should use Special Comment Code "AW" instead of "CP."
See also:
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These options are available in Institution Options (commonly referred to as "Oops Options") to set up the institutions’ preferences for Special Comment codes in regards to loan modifications. You should set up the COTM, CORT, COPI, and/or COPT options before setting up the COND option, as explained in the following table. Also, the CMAN option is used in conjunction with the other options.
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In compliance with credit reporting regulations (FACT-ACT), certain Special Comment codes and Account Status can be generated on a selected customer loan account depending on the Payoff Description selected when paying off a loan (Loans > Payoff screen).
In order for this feature to be effective, your institution must create eight payoff description codes on the Loans > System Setup Screens > Payoff Transaction Descriptions screen.
The table below displays the Code and Description for each payoff description code that must be created as well as the Special Comment Code or Account Status that is generated at monthend when the corresponding Payoff Description is used.
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The Special Comments codes are found on both the Credit Report (FPSRP184) and in the Base Segment of the transmission sent to credit repositories.