As part of your integration with Peach, we can generate a monthly Metro 2® compliant file representing the status of your consumer accounts using your provided PII. We run Metro 2 reports on the first of each month to show the current status of your borrower accounts based on activity during the previous calendar month. Once generated, we send the file(s) to your specified SFTP location. If you have more than one product on Peach, you can choose which one(s) you want to report on. We support the Metro 2 format for both installment and line of credit products, and offer expanded reporting capabilities for non-retail credit cards, savings and loan companies, banks, credit unions, private student loans, sales finance and loan finance companies, and retail store exclusive accounts.
Metro 2 is the required file format for Equifax, Experian, and TransUnion. To populate the Metro 2 header, we will need your program identifier numbers from the agencies you choose to report to. To obtain your identifier numbers, you will need to establish a relationship with your agencies of choice and pay any fees associated with data furnishing within their network. Please note that some agencies require a minimum of 100 accounts to qualify as a data furnisher, so you may not be able to furnish data during the early stages of your lending or credit program. Peach does not directly support Metro 2 files for business borrowers, or other file formats for alternative reporting agencies. However, your data within Peach is always accessible to you through our snapshot and replica data tables should you need to generate other file formats.
Reporting on migrated accounts
If you are migrating accounts with existing bureau reporting histories, we will need the most recent 24 months of values in the Payment History Profile field of your Metro 2 files. This field contains a 24-character string representing payment activity for each month. Going forward, we’ll maintain reporting for previous months while layering in new payment activity.
Brand new loans originated and boarded to Peach for servicing will have their entire Metro 2 reporting managed by Peach. Our system is designed to handle reporting for migrated portfolios where legacy accounts are serviced alongside new accounts. And since Metro 2 reporting is a loan-by-loan view, we are also compliant in reporting on borrowers who have both migrated and net-new loans or lines of credit. This is just one of the ways we make the complex work of migration less painful for you and your teams.
Handling disputes
Consumers can dispute information on their credit report through the pertinent credit bureau. When this happens, the credit bureau will send the dispute to you through the e-OSCAR intermediary system. You’ll then respond to the dispute through e-OSCAR and either validate the information you originally reported or provide an update to the consumer’s credit report.
Because we automatically generate Metro 2 files for you, you’ll also make any necessary updates to consumer data through the Peach Agent Portal so that the next month’s file accurately reflects the outcome of the dispute. We’re here to support you if you run into any issues or have credit reporting requirements outside of what’s covered in this article.
lender’s priority list. But that doesn’t mean compliance is straightforward, even for lenders with the most earnest intentions. Often, legacy infrastructure is the culprit, making it difficult for lenders to take the actions clearly outlined in the law. Even regulations that haven’t changed for some time—like the—still present significant challenges for many lenders.
The SCRA grants active-duty service members the ability to request certain protections during the period of their deployment, enabling them to devote their energy to serving the country. These protections include a reduction in interest rate to a maximum of six percent on any pre-service loans. While the SCRA in its current version has been law since 2003, the number of recent enforcement actions indicates just how difficult it is for many lenders to comply with the SCRA’s interest rate protections.
Blunt tools in the absence of a scalpel
For example, in October of 2022 the Department of Justice (DOJ) announced that the financial leasing arm of GM agreed to pay over $3.5 million to resolve allegations in relation to
Peach’s approach to SCRA
At Peach, we brought real-life lending experience to the design of our platform. So from day one, we recognized the importance of being able to make retroactive changes to loans. (There are numerous applications beyond SCRA, including our Supported Portfolio Migration.) In the case of SCRA, Peach has long enabled lenders to retroactively change interest rates and waive past fees—as separate, manual actions.
Peach’s approach to SCRA
This was functional, but the ideal way to implement SCRA is to make these changes simultaneously. We now support this capability by leveraging the power of Peach's Loan Replay™ engine, which can make changes to the ledger at any time, and then recalculate a loan’s history in light of those changes. The new combined functionality is as user-friendly for your agents as processing a payment.
Peach’s approach to SCRA
Specifically, the new SCRA feature allows your agents to perform the following adjustments simultaneously on a loan of an active-duty service member:
- Lower interest rates to 6% (and lower the recurring payment during the active-duty period to account for the interest rate reduction)
- Waive fees, if necessary
- Enact these changes retroactively, if necessary, and replay the loan history with the rate and fee adjustments
- Preview the intended changes
“We launched our first product on Peach in six weeks. Eighteen months later.”
John Smith, CMO
Our SCRA functionality is available via API as well as through our white-label agent tool. The white-label agent interface can be seen here:
Peach’s approach to SCRA
Our SCRA functionality is available via API as well as through our white-label agent tool. The white-label agent interface can be seen here:
For those working directly with the API, this can be as simple as sending the following request body to the SCRA endpoint:
You’ll receive a response with either the actual post-SCRA adjusted payment plan or a preview of it. Below is a comparison of a payment plan prior to the SCRA adjustment, and the expected payments after the SCRA adjustment. The SCRA period is in effect for the first two months, and thus you will see the interest rates lowered to 6% in the response body (and the recurring amount due lowered by the amount of the interest rate reduction for the two relevant months). The origination fee has also been canceled.
The breadth of loan data needing to be adjusted means that rewriting loan histories requires the right design and abstractions, and having a built-in layer of abstraction to handle retroactive changes is the only feasible approach. Because of our team’s combined experience in the real world of lending, we know that the need to edit past loan events is inevitable. So we’ve designed a system that makes these changes as painless and automated as possible.
