Metro 2® Compliance Audit Service

Metro 2® Data Furnisher
Compliance Validations

Validations performed by Hutchins Systems Inc. during an audit or pre-submission file review.

Most Metro 2® problems aren't formatting errors — they're logic or DOFD errors, which create the greatest regulatory risk. Our comprehensive audit catches every category before files reach the bureaus.

Key Compliance Vulnerabilities

Furnishers must address these critical risk areas when reporting data. Hutchins Systems validates all of them automatically — catching errors before they reach the bureaus.

01

Inaccurate DOFD

Misreporting the Date of First Delinquency triggers premature or delayed 7-year obsolescence — a top FCRA violation risk.

02

Re-Aging Accounts

Resetting delinquency dates on past-due accounts extends negative reporting beyond legal limits and exposes furnishers to disputes.

03

Incorrect Account Status

Reporting active accounts as closed, or vice versa — creates Metro 2® logic errors and misleads credit bureaus on account standing.

04

Missing or Wrong ECOA Codes

Accounts with co-signers require accurate ECOA coding. Errors affect both parties' credit files unfairly.

05

Balance Reporting Errors

Reporting outstanding balances after settlement, or failing to zero out paid accounts, contradicts Metro 2® logic rules.

06

Reporting Deposits as Debt

Security deposits are not delinquent debt and should not automatically be reported as charged-off debt.

1Structural & Format
2Field-Level Logical
3Regulatory Risk (FCRA)
4Mapping & System-Level
5Bureau Onboarding

Our validations fall into four major categories — plus bureau onboarding support.

Category 1

Structural & Format Validations

Will the file pass bureau technical standards?

Header Segment format validation
Trailer record validation
Record Descriptor Word accuracy
Field length & padding checks
Numeric vs alpha field enforcement
Required field presence
Proper segment sequencing (Base, J1, K1...)
Character set compliance
Activity Date & Program Date format validation
Purpose: Prevent file rejects by Experian, Equifax, and TransUnion.
Category 2

Field-Level Logical Validations

Do the fields make sense together?

Account Status ↔ Payment Rating alignment
Account Status ↔ Current Balance consistency
Charge-Off Amount ↔ Account Status validation
Paid accounts reporting zero balance
Past Due Amount logic validation
Payment History Profile alignment with status
Date Closed present when required
Bankruptcy indicator consistency with account status
Purpose: Reduce logical inconsistencies that trigger bureau edits or disputes.
Category 3

Regulatory Risk Validations (FCRA)

Reduce exposure under the Fair Credit Reporting Act.

Date of First Delinquency (DOFD) accuracy
7-year obsolescence trigger validation
Charge-off timing compliance
Re-aging detection
Dispute code reporting compliance
Settlement coding (Special Comment Codes)
Consumer info accuracy (ECOA codes, SSN format, DOB)
Purpose: Minimize legal exposure, disputes, and CFPB complaint risk.
Category 4

Mapping & System-Level Validations

Is your servicing system populating Metro 2® correctly?

LOS/servicing system to Metro 2® field mapping review
Automated rule testing
Conditional trigger validation (when to populate Special Comment Codes)
Charge-off workflow reporting accuracy
Bankruptcy lifecycle coding
Regression testing before submission
Purpose: Identify systemic errors — not just surface-level file issues.
Category 5

Bureau-Readiness & Onboarding Support

For new furnishers — smoothing the path to bureau acceptance.

Test file validation
Pre-certification review
Field usage compliance
Edit rejection prevention
Purpose: Supports onboarding with Experian, Equifax, and TransUnion.

Most Metro 2® problems aren't formatting errors

They're logic or DOFD errors — which create the greatest regulatory risk. A comprehensive validation approach protects every stakeholder.

Data Furnisher Reputation

Accurate reporting builds trust and avoids bureau disputes.

Bureau Relationships

Clean files mean fewer edits, rejections, and escalations.

Consumer Trust

Correct data protects consumers from unjust negative reporting.

Regulatory Posture

Proactive compliance reduces CFPB complaints and legal exposure.

SOC 2 Type 2 Certified · FCRA Compliant · 38+ Years Experience

Ready to audit your Metro 2® files?

Our compliance experts will review your data furnishing setup, identify every risk category, and deliver a detailed audit report — so you can fix issues before they become bureau rejections or CFPB complaints.

CONSUMER DATA INDUSTRY ASSOCIATION®, CDIA®, the CREDIT REPORTING RESOURCE GUIDE®, and METRO 2® are registered trademarks of the Consumer Data Industry Association. Hutchins Systems Inc. is not affiliated with or endorsed by CDIA.

Metro 2 Compliance Audit Service — Data Furnisher Validation & Error Detection | Hutchins Systems