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Special Comment codes

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Special Comment codes

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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.

 

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Note: See CO in the table below for options that will affect whether or not an account is assigned Special Comment CO (account modified).

 

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.

 

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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.

 

Valid codes on the drop-down list are as follows:

 

Special Comment Code

Description

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. If loan is service released (LNRLSD=Y), then Special Comments equals O.

S

Special handling (contact credit grantor for additional information)

 

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.

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 disaster

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

CO

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.

 

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GOLDPoint Systems Only: These options are available in 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.

 

Option

Description

OPCO CMAN

If this option is on, the "CO" Special Comment code is only applied to the account during monthend Credit Reporting when a manual change is made to one of the following fields:

 

Interest Rate

P/I Constant

Term

Due Date

 

If changes are made to those fields by the system due to transactions (e.g., loan payment moves the due date), the account will not be assigned Special Comment code "CO."

 

In order to use this new option, CIM GOLD version 7.8 or above must also be updated, because we added four fields to the Credit Reporting record (FPBU) that are used by the system to notify the credit reporting record that the account has been manually changed.

 

If users manually change one of the above fields using any method in CIM GOLD, including:

 

the Additional Loan Fields screen

the Account Detail screen

the Account Adjustment screen

the CP2 screen,

 

then the system updates these four new fields, so the CO Special Comment code will be appropriately applied.

 

The four new fields will not be seen on any screen in CIM GOLD but are behind-the-scenes. They are:

 

Manual Change to Term (BUMANT)

Manual Change to Rate (BUMANR)

Manual Change to P/I (BUMANP)

Manual Change to DUDT (BUMAND)

 

Additionally, if any changes are made to the Due Date, the Due Date Day field is also updated with the day of the month that the Due Date is changed to.

 

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Note: This option is used in conjunction with the other OPCO options described below. For example, if this option is on as well as the OPCO COTM option, then only when the Loan Term is modified manually will the account be flagged with the "CO" Special Comment for credit reporting purposes.

OPCO COND

Set this option after setting any or all of the other options in this table. This option indicates to the system that the selected options must all be present on the loan before the “CO” Special Comment is applied to the account.

 

For example, if the institution wants a “CO” Special Comment applied only if the loan has both a term and rate change that month, then you would turn on options COTM and CORT, and then you would turn on COND.

 

If you do not turn on this option, then the system will apply the CO code to accounts according to whether the other options listed below are turned on.

 

For example, if this option (COND) is not turned on, but option COTM and CORT are turned on, then if either the loan term or loan rate changes (can be either or both), the CO code will be applied. But if the P/I constant changes, the CO term will not be applied because the COPI option was not turned on.

 

Take the same example above and turn on option COND, as well as COTM and CORT. Now if the loan rate changes but not the loan term, the CO code is not applied to the account, because COND requires both to exist before the account receives the CO code.

OPCO COTM

If this option is turned on, accounts where the loan term (LNTERM) was modified that month will be reported to credit repositories with Special Comment code “CO.”

 

If loan term is this institution’s only criteria for setting the CO code, then do not turn on the COND option and only turn on option COTM.

 

If this institution wants additional criteria (term, loan rate, P/I constant, due date) before the loan receives a CO code, then turn on options COTM, CORT, COPI, and/or COPT, and then turn on option COND if all selected options must apply to generate special comment “CO”, or leave COND off if any of the selected options will generate special comment “CO.”

OPCO CORT

If this option is turned on, accounts where the loan rate (LNRATE) was modified that month will be reported to credit repositories with Special Comment code “CO.”

 

If loan rate is this institution’s only criteria for setting the CO code, then do not turn on the COND option and only turn on option CORT.

 

If this institution wants additional criteria (term, loan rate, P/I constant, due date) before the loan receives a CO code, then turn on options COTM, CORT, COPI, and/or COPT, and then turn on option COND if all selected options must apply to generate special comment “CO”, or leave COND off if any of the selected options will generate special comment “CO.”

OPCO COPI

If this option is turned on, accounts where the P/I constant was modified that month will be reported to credit repositories with Special Comment code “CO.”

 

If P/I constant is this institution’s only criteria for setting the CO code, then do not turn on the COND option and only turn on option COPI.

 

If this institution wants additional criteria (term, loan rate, P/I constant, due date) before the loan receives a CO code, then turn on options COTM, CORT, COPI, and/or COPT, and then turn on option COND if all selected options must apply to generate special comment “CO”, or leave COND off if any of the selected options will generate special comment “CO.”

OPCO COPT

If this option is turned on, and the Due Date on the loan is manually changed to a date in the future, the account will be flagged with Special Comment code “CO” in subsequent Credit Reporting transmission (FPSRP184). Special Comment code "CO" will continue to be reported for the life of the loan unless a higher priority Special Comment code applies to the loan. In which case, the higher priority Special Comment code will be shown on that particular transmission.

 

If due date is this institution’s only criteria for setting the CO code, then do not turn on the COND option and only turn on option COPT.

 

If this institution wants additional criteria (term, loan rate, P/I constant, due date) before the loan receives a CO code, then turn on options COTM, CORT, COPI, and/or COPT, and then turn on option COND if all selected options must apply to generate Special Comment “CO”, or leave COND off if any of the selected options will generate Special Comment “CO.”

 

Payoff Note

 

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.

 

Code

Description

Special Comment Code

1

Paid by Co-Maker/Guarantor

C

2

Paid by Company which Originally sold the Merchandise

BN

3

Paid through Insurance

BP

4

Paid by Garnishment

AM

5

Paid by Financial Counseling Program

B

6

Paid from Collateral (or Paid by Sale of Security)

AX

7

Paid by Third Party Collector. This does not set Special Comment code but does set Account Status 62 (collection account).

Not applicable

8

Paid by Non-file

S

 

If institution option OP24 SPHC (Add Special Handling Code) is enabled, the account has an action code 154 in the current month as well as an action code 93, but does not have a Special Comment code of BO, AI, AU, or AT, then this field will be updated to "S" (special handling).

 

The Special Comments codes are found on both the Credit Report (FPSRP184) and in the Base Segment of the transmission sent to credit repositories.

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