70Government Obligations
Account Type Code 70: Government Over-Payment
Account Type Code 70 means "Government Over-Payment". Money a government entity paid to or on behalf of the consumer in excess of what was owed, which the consumer is now obligated to return. It is reported in Account Type (Field 15) of the Base Segment, 2 characters at position 84.
Specification
| Code | 70 |
|---|---|
| Meaning | Government Over-Payment |
| Field | Account Type (Field 15) |
| Record | Base Segment |
| Length / position | 2 chars · 84–85 |
| Category | Government Obligations |
| CRRG reference | CRRG Exhibits 1 & 2 (Account Type Codes) |
What Account Type Code 70 means
- Not a loan. Nothing was borrowed. The obligation arises because the agency paid too much and has a right to recover it.
- Code 70 is the general government overpayment. Code 75 is the narrower case where the overpaid amount was a benefit payment.
- Does NOT mean a fine (71) or a fee for service (72). Those are amounts imposed or charged, not amounts erroneously paid out.
- The overpayment may have arisen from an agency error, a reporting error by the consumer, or a change in eligibility applied retroactively. The Account Type does not distinguish among those causes.
- Reported as Portfolio Type I because agencies normally establish a repayment schedule, which makes the obligation behave like an installment.
When to report 70
- 1An agency reports an overpayment established after an audit found the consumer was paid more than the entitlement allowed.
- 2An agency reports an overpayment being repaid on an agreed monthly schedule.
- 3An agency reports an overpayment being recovered by administrative offset against future payments.
- 4An agency reports an overpayment that was waived in part, with the remaining balance still being repaid.
- 5An agency reports an overpayment that was satisfied in full and closed at a zero balance.
Reporting rules
- Report the established overpayment amount as the Original Loan Amount and the unrecovered portion as the Current Balance.
- Reduce the Current Balance as offsets are applied, and reflect those offsets in the payment fields so the tradeline shows the obligation is being satisfied.
- If a waiver reduces the amount owed, reflect the reduced balance rather than continuing to report the original establishment amount.
- Do not furnish an overpayment that is still under appeal in a way that asserts a settled obligation, and follow your written policy for accounts in administrative review consistently.
- Do not recode to 74 when the overpayment ages. Miscellaneous debt is a residual category, not a delinquency stage.
Codes and fields that must agree
A file can be structurally valid and still be wrong. These are the cross-field conditions Account Type Code 70 has to satisfy.
- Portfolio Type must be I (Installment).
- Portfolio Type I requires Terms Duration and Scheduled Monthly Payment. Where recovery is by offset rather than by an agreed payment, report the recovery amount and interval the agency actually applies.
- Credit Limit must be blank or zero.
- Original Loan Amount is the established overpayment and must be greater than zero; a waiver changes Current Balance, not the establishment amount.
- Actual Payment Amount should reflect amounts actually recovered in the cycle, including offsets, so that balance movement and payment reporting reconcile.
- Date of First Delinquency runs from the first missed payment under the repayment obligation, not from the date the erroneous payment was made. Using the erroneous payment date can push the FCRA purge window years out of position.
- Terms Frequency must match the interval at which recovery is actually taken, which for an offset arrangement may be the benefit payment cycle rather than a calendar month.
- Amount Past Due should be zero while an agreed repayment or offset arrangement is being honoured, even though a balance remains outstanding.
Common errors involving 70
Vocabulary
Keep browsing
- All 56 account type codes — the full set with categories and cross-field rules.
- Metro 2 codes cheat sheet — every CRRG code set on one page.
- Account Type field reference — position, length, and validation rules.
- Metro 2 format reference
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