# Collections Metro 2 launch checklist

The pre-furnishing steps that keep a collections or small-lender first file from getting rejected — and keep you compliant once you start reporting.

- [ ] **Confirm your bureau subscriber codes are active** — You need an active subscriber/furnisher code with each bureau you intend to report to. Reporting under the wrong or inactive code is a common cause of rejected or misattributed files.
- [ ] **Decide which bureaus you will furnish to** — You are not required to report to all four. Pick Equifax, Experian, TransUnion, and/or Innovis deliberately, and report consistently to the ones you choose.
- [ ] **Send the Regulation F validation notice before furnishing** — Under CFPB Regulation F, a debt collector generally may not furnish information about a debt to a CRA until after sending the validation notice and waiting the required period. Confirm timing before the first file goes out.
- [ ] **Capture a Date of First Delinquency (DOFD) for every account** — The DOFD controls the 7-year obsolescence clock and must carry through correctly, especially on purchased debt. A missing or re-aged DOFD is a top dispute and FCRA-liability driver.
- [ ] **Record the original creditor for purchased or placed debt** — Debt buyers must report the original creditor (K2 segment / Purchased From) and a Purchased Indicator. Placed-account collectors must reflect the creditor relationship accurately.
- [ ] **Map each account's status to the correct Metro 2 code combination** — Open collection, paid collection, settled-for-less, and disputed accounts each require a specific Account Status, Compliance Condition Code, and Special Comment combination.
- [ ] **Set Compliance Condition Codes for disputed accounts** — Accounts the consumer has disputed (e.g., XB) and accounts where the dispute is resolved (XR) must carry the right Compliance Condition Code so the bureaus display them correctly.
- [ ] **Plan your Delete (DA) policy** — Use the Account Status DA (or compliance deletion) only when you actually intend to remove the tradeline — recalled, sold-back, or invalid accounts — and never to mask re-aging.
- [ ] **Validate the Header and Trailer record counts** — The Trailer's totals must reconcile to the Base Segment counts in the file. Mismatched totals cause whole-file rejections regardless of how clean the data is.
- [ ] **Stand up an e-OSCAR / ACDV dispute-response workflow** — Once you furnish, FCRA 1681s-2(b) requires you to investigate disputes received through e-OSCAR and respond within the statutory window (generally 30 days).
- [ ] **Keep an audit trail of every file and validation result** — Retain the generated file, the validation report, and delivery confirmation for each cycle so you can defend the data later if challenged.
- [ ] **Run the first file in test/sandbox mode before going live** — Generate and validate against the CRRG in sandbox first, confirm it passes, then promote the same file to a live delivery.

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From the Metro 2 Furnisher Launchpad — https://metro2.switchlabs.dev/launchpad