Credit Reporting Agencies
TO STATE IV-D DIRECTORS
The purpose of this letter is to clarify Federal laws which govern reporting child support obligors to credit reporting agencies. No Federal law restricts the reporting of child support obligors to credit bureaus--whether current or in arrears in their support payments.
The law and OCSE's regulations establish reporting minimums, not limits. OCSE encourages state agencies to report all noncustodial parents with a legitimate child support obligation.
Some state agency officials, according to a recent GAO draft report on credit bureau reporting, erroneously believe the Social Security Act restricts who can be reported to credit bureaus. Officials in several states, according to the report, said that this law allows them to report only parents with arrears.
Federal law merely sets forth minimum reporting requirements, including who must be reported and does not preclude states from reporting others. Child support enforcement agencies are therefore free to provide information to credit bureaus on any noncustodial parent with a legitimate child support obligation, whether or not in arrears. On other Federal law, the Privacy Act of 1974, as amended, is applicable to this discussion. This law applies only to Federal agencies and not to state child support enforcement agencies.
Some states are doing just that. Vermont, for example, reports virtually all noncustodial parents, including those who are current with their support payments. Timely reporting enhances the effectiveness of credit bureaus as information sources for locating noncustodial parents whose whereabouts are unknown.
Many States are moving ahead with routine reporting to credit bureaus. Enclosed is a map showing the current status of routine credit reporting by states.
Allie Page Matthews
Office of Child Support
cc: Regional Representatives