08/24/2020: Credit Bureau Reporting Changes for Customers on COVID-19 Forbearance Plans

Summary: Customers delinquent 30 days or greater at the start of their COVID-19 forbearance plan have been reported to the Credit Reporting Agencies (CRA) as current through June 2020 (reported on July 6, 2020).  The CARES Act requires these loans be reported to the CRAs with the same rolling delinquency as was present at the start of their COVID-19 forbearance plan.  


Beginning with credit bureau reporting data for July 2020 (reported on August 5, 2020) and forward, loans delinquent 30 days or greater at the onset of their forbearance plan will report to the CRAs based on their delinquency status at the onset of their plan. 


Detailed Information and Customer Talking Points: Customers whose loans were delinquent 30 days or greater at the start of their COVID-19 forbearance plan (requested by customers as a result of a COVID-19 hardship) have been reported to the Credit Reporting Agencies (CRA) as current (no delinquencies reported) on their loans through June 2020 (reported on July 6, 2020) although the CARES Act requirement is to report those loans with the same rolling delinquency as was present at the start of their COVID-19 forbearance plan.  


From March 2020 to June 2020, Fairway had to report these loans as current due to servicing system constraints (MSP could not report this rolling delinquency status). 


Beginning with credit bureau reporting data for July 2020 (reported on August 5, 2020) and forward, loans delinquent 30 days or greater at the onset of their forbearance plan will report to the CRAs based on their delinquency status at the onset of their plan.  This is based on the required reporting approach under the CARES Act that the delinquency at commencement of the forbearance plan be reported, but that the delinquency not be advanced (increased) as forborne payments are not made and delinquencies compound (30 day delinquent rolls forward each month at 30 days delinquent even if the customer ceases making payments as allowed under their plan, and the same for 60 days and 90 days and so on).

  • Example - A loan 60-days delinquent prior to the COVID-19 forbearance will report to the CRAs as a 60-day delinquent loan throughout the COVID-19 forbearance period - regardless of the building delinquency – unless the loan is brought current 


This may impact credit scores and prompt questions from customers.  Advise the following:

  • Prior to the July 2020 data cycle, delinquent loans on COVID-19 forbearance plans were reported to the Credit Reporting Agencies (CRA) as current due to technology constraints which customers temporarily benefited from
  • Beginning with the July 2020 data – reported to the CRAs on August 5, 2020 – Fairway is required to report the delinquency status of your loan as of the beginning of your COVID-19 forbearance plan
  • This is a guideline outlined in the CARES Act (actual language further below – this can be shared with customers as needed)
  • Impacted loans will continue to report this delinquency status through the duration of the forbearance period regardless of the building delinquency – unless the loan is brought current


Customers should be advised to contact the CRAs directly regarding questions regarding how this may impact the calculation of their credit score  Please contact your manager if you have any questions.



CARES ACT – ACTUAL LANGUAGE – SECTION 4021 – Clause (ii) (II)