06/15/2020: CARES Act COVID-19 Credit Bureau Reporting Update

As mortgage industry processes surrounding the COVID-19 CARES Act continue to be refined, there has been a recent servicer/subservicer shift to discontinue the use of the Special Comment Code AW (Affected by Natural or Declared Disaster) or CP (Account in Forbearance) in the monthly credit bureau reporting of customers on COVID-19 forbearance plans. 

The use of these Special Comment Codes AW or CP was based on the original guidance (recommendation) issued by the CDIA (Consumer Data Industry Association) – this approach was the historically utilized method for credit bureau reporting on “disaster” forbearance plans.

Although these special comment codes were deemed as neutral with the leading score modelers, Vantage Score and FICO, this code reporting did create issues with other credit services and tools, such as Credit Karma.  In a continuous effort to optimally follow the intent of the CARES Act, there has been a methodology shift to discontinue the credit reporting of AW or CP Special Comment Codes.

Fairway Retained Servicing customers on COVID-19 forbearance plans have been reported (as applicable to their start/end date on the COVID-19 forbearance plan) with a Special Comment Code CP (Forbearance).  Commencing with June credit bureau reporting activity (reported in early July), the CP code will no longer be used.

Fairway Servicing will communicate any additional changes as they occur.  Please contact Servicing 911 at Servicing911@fairwaymc.com for internal assistance or questions.  

This communication is for internal use to provide you with information to assist your customers.  This is not approved to post on social media.