Equifax notified us for the first time on May 24, 2022, that a coding issue introduced during a technology change to Equifax’s legacy online model platform (OMS) may have resulted in the potential miscalculation of certain report attribute values. As a result, for some transactions, certain attribute values – such as “number of inquiries within one month” or “age of oldest tradeline”– may potentially have been incorrect. This data issue affected all of Equifax’s customers that received consumer reports utilizing the OMS during the time period stated below.
o Equifax’s analysis showed that approximately 88% of overall transactions scored with the impacted models used for mortgage during the time-frame of this coding error experienced no change to their scores. Fewer than 9% experienced a change of 10 points or less; less than 3% experienced a change of 11-20 points; and less than 1% experienced a score change of more than 20 points.
o Equifax confirmed that this issue took place between March 17 and April 6, 2022. A temporary fix was put in place on April 6 and a permanent fix was put in place on April 8.
o Equifax advised that it is confident that this issue was isolated to the legacy OMS platform and contained given the controls in place and the limited changes allowed on this environment.
As of May 26, 2022, Equifax has now provided us with an impact assessment for our customers.
• If transactions were mis-decisioned based on an Equifax report, Equifax has not yet advised us of any specific remediation that it agrees to provide. However, it has agreed to work collaboratively with us to support the actions our customers determine are necessary to address their concerns. For our part, we will provide Equifax with our customers requests immediately upon our receipt them.
• Equifax is not directly notifying consumers at this time. Equifax advised us that our customers should refer to their own underwriting guidelines when assessing whether to take any actions related to their consumer customers, and to please note that loans already “Closed” or “Denied” (or other similar adverse action) do not have a permissible purpose to pull a new credit report. However, if they closed on the loan and still own it, they may pull a new credit report under the “Account Review” permissible purpose.
Questions and Answers from Equifax are listed below.
Q: What happened?
A: A coding issue introduced during a technology change to Equifax’s legacy online model platform (OMS) may have resulted in the potential miscalculation of certain attributes. As a result, for some transactions, certain attribute values – such as ‘number of inquiries within one month’ or ‘age of oldest tradeline’ – may potentially be incorrect. The issue occurred between March 17 and April 6, 2022.
Q: How did this situation happen?
A: On March 17, Equifax conducted testing of this legacy environment in anticipation of a scheduled migration of the OMS platform to the Equifax Cloud. That testing included a code change. This code change inadvertently included a coding error.
Q: Why am I only being notified of this issue now?
A: Equifax states this was a complex issue requiring detailed analysis to provide accurate information on any potential score changes. Equifax has now processed and validated the score impacts with pre and post data to calculate the score and attribute changes at the transaction level.
Q: What is the impact of this issue on transactions?
A: Equifax analysis showed that approximately 88% of overall transactions scored with the impacted models used for mortgage during the timeframe of this coding error experienced no change to their scores. Fewer than 9% experienced a change of 10 points or less; less than 3% experienced a change of 11-20 points; and less than 1% experienced a score change of more than 20 points.
Q: What transaction impact analysis are you providing and when?
A: Equifax is currently processing and validating the score impacts with data taken prior to the code change and after the code change to calculate the score and attribute impacts at the transaction level. This data will feed into the specific score change analysis that Equifax will provide to each of us. We intend to then develop an organization- specific impact assessment where appropriate.
Q: If transaction attributes were miscalculated during the time in which this issue took place, is it possible that they were mis-decisioned?
A: Equifax analysis showed that approximately 88% of overall transactions scored with the impacted models used for mortgage during the timeframe of this coding error experienced no change to their scores. Fewer than 9% experienced a change of 10 points or less; less than 3% experienced a change of 11-20 points; and less than 1% experienced a score change of more than 20 points.
Q: If transactions were mis-decisioned, how will Equifax assist us in rectifying the situation?
A: Equifax will work collaboratively with its resellers to support the actions its customers determine are necessary to address consumer concerns.
Q: Are you or Equifax planning to notify consumers?
A: Neither Equifax nor SARMA is directly notifying consumers at this time. Equifax will work collaboratively with us to ensure that we are supporting any consumer actions you determine are necessary.