Credit Reporting: Compliance Condition Code

What is the Compliance Condition Code (CCC)?

The is reported in a Metro 2 data field which allows furnishers to report a condition that is required for legal compliance. CCCs are used to reflect accounts closed at consumer’s request, and consumer disputes under the Fair Credit Billing Act (FCBA), the Fair Debt Collection Practices Act (FDCPA), or the direct dispute provisions of the Fair Credit Reporting Act (FCRA) .

According to the Consumer Data Industry Association (CDIA), which publishes yearly written reporting procedures on behalf of the national consumer reporting agencies (Trans Union, Equifax and Experian) to be followed by their data furnishers, CCCs should not be reported in response to a consumer dispute investigation request the data furnisher receives directly from the consumer reporting agencies, unless the data furnisher uses a CCC to satisfy its FDCPA obligation to communicate that a debt is disputed.

When the CCC is used to report that some information about the account is or was in dispute, this “dispute flag” should, in principle, be removed or changed to indicate the investigation is complete. In practice, furnishers and consumer reporting agencies often fail to remove this dispute flag from the CCC field after a consumer’s dispute has been resolved. As a result, the dispute flag often remains on the account long after the consumer’s dispute. Moreover, the dispute flag provides essentially no detail on the content of the dispute, including whether the dispute was initially lodged with the furnisher or the consumer reporting agency.