Metro 2 ECOA Code W: Business / Commercial

Specification

Code	W
Meaning	Business / Commercial
Field	ECOA Code (Field 10)
Record	Base Segment
Length / position	1 char · 63–63
Category	Commercial and Guaranteed Business Credit
CRRG reference	CRRG ECOA Code table (Base Segment)

Code W identifies the obligation as commercial. It is a classification of the credit, not a description of one person's share of it.
It is not the same as code 7. Code 7 is the individual maker of a business obligation backed by a personal guarantee; code W says the account itself is commercial.
It does not exempt the record from Metro 2 accuracy rules. Balances, status, delinquency dates and payment history are still expected to be internally consistent.
It does not authorize furnishing a business obligation against an individual who has no personal liability for it. The presence of a commercial designator is not a substitute for the legal basis to report.

1A bank furnishes a commercial line of credit extended to an operating company.
2An equipment finance company reports a business lease written to a corporate lessee.
3A supplier reports a trade credit account opened in a company's name.
4A card issuer furnishes a corporate card program account that is classified as commercial credit rather than consumer credit.

Use code W where the obligation is genuinely commercial, and use code 7 where the record exists on a consumer file because a named individual is the maker with a personal guarantee.
Keep Portfolio Type and Account Type aligned with the commercial nature of the obligation.
Do not mix a commercial designator with associated-consumer segments that describe personal liability structures. If individuals are personally liable, their designators should say so.
Do not use code W to hide a consumer obligation from consumer-reporting scrutiny. The designator describes the credit, and mislabeling it is a data-integrity problem.

A file can be structurally valid and still be wrong. These are the cross-field conditions ECOA Code W has to satisfy.

Portfolio Type should describe the commercial product accurately. A commercial designator on a product type that only exists in consumer lending is a mismatch that should be resolved before filing.
Every consumer carried on the record still gets their own ECOA code in their own segment. A commercial designator on the Base Segment does not propagate to J1 or J2 segments.
Delinquency consistency still applies: a non-zero Payment Rating requires a Date of First Delinquency, and Amount Past Due must reconcile with the reported delinquency.
Code W and code 7 are alternatives. Decide which framing the record is furnished under and report one designator per consumer.