# Non-prime lender Metro 2 launch checklist

The pre-furnishing steps that keep a small-dollar, title, or lease-to-own first file from getting rejected — and keep you compliant once you start reporting.

- [ ] **Obtain a furnisher agreement and subscriber code from each bureau** — Each bureau approves furnishers independently and issues its own subscriber code. This paperwork typically runs several weeks and is the single most common reason a launch slips — start it before the data work, not after.
- [ ] **Get an honest read on portfolio-size thresholds before you commit** — Bureaus weigh portfolio size during onboarding. Equifax's prospective-furnisher guidance states no minimum data requirement but notes that furnishers under 500 accounts per month may need a monitoring subscription; Innovis in practice applies a far higher threshold. Confirm you clear the bar for the bureaus you intend to report to.
- [ ] **Decide the structural treatment for each product you originate** — Single-pay advances, installment loans, title-secured loans, and lease-to-own agreements are not interchangeable. Settle account type, terms duration, terms frequency, and payment-rating applicability per product before the first file, not per cycle.
- [ ] **Capture a Date of First Delinquency for every delinquent account** — DOFD drives the seven-year obsolescence clock. On short-tenor loans it can be only days after origination, which makes it easy to omit and costly to get wrong — a missing or re-aged DOFD is a leading dispute and FCRA-liability driver.
- [ ] **Define how renewals, rollovers, and refinances are reported** — Whether a renewed advance is a new account or a continuation of the existing one depends on how your loan documents and state law characterize it. Decide once and apply it consistently; the wrong choice creates duplicate tradelines or a hidden gap.
- [ ] **Define the ending for every outcome path** — Paid in full, paid early, charged off, repossessed, voluntarily surrendered, merchandise returned. Each is a different closing status, and for title and LTO products the difference between them is where accuracy problems concentrate.
- [ ] **Confirm you will report the complete portfolio** — Furnishing only delinquent accounts while omitting performing ones is not permitted. Plan to report the full book you choose to furnish, consistently, every cycle.
- [ ] **Handle accounts that open and close within one cycle** — On the shortest tenors an account's entire life can fall between two monthly files. Confirm those accounts are captured with the correct open date, closure status, and payment history rather than never appearing at all.
- [ ] **Validate 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 underlying 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. Decide who owns this before the first file, not after the first ACDV.
- [ ] **Retain the file, validation report, and delivery confirmation each cycle** — Keep the generated file, its validation results, and proof of delivery so you can defend what you reported if it is challenged months later.
- [ ] **Run the first file in sandbox before going live** — Generate and validate in test mode with environment-tagged records, confirm it passes, then promote the same file to a live delivery.

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From the Metro 2 Furnisher Launchpad — https://bureaurelay.com/launchpad