ASTransfers, Refinances and Replacements
Special Comment Code AS: Refinanced or Replaced
Special Comment Code AS means "Refinanced or Replaced". The obligation was refinanced or otherwise replaced by a new one. The old tradeline ends and a separate tradeline reflects the replacement loan. It is reported in Special Comment (Field 31) of the Base Segment, 2 characters at position 213.
Specification
| Code | AS |
|---|---|
| Meaning | Refinanced or Replaced |
| Field | Special Comment (Field 31) |
| Record | Base Segment |
| Length / position | 2 chars · 213–214 |
| Category | Transfers, Refinances and Replacements |
| CRRG reference | CRRG Exhibits 6 & 7 (Special Comment Codes) |
What Special Comment Code AS means
- AS marks the closing tradeline in a refinance, explaining that the balance went to zero because a new obligation took its place, not because the borrower paid it off from savings.
- AS does NOT mean the borrower stopped owing money. The debt moved into a new account that reports separately.
- AS does NOT mean the loan was modified. A modification amends the existing contract and keeps the same tradeline; that is CN. A refinance creates a new one.
- The replacement loan is a new tradeline with its own Date Opened. Do not attach the new loan's terms to the old record.
- AS is terminal for the old tradeline. Once the refinance closes, the old record stops changing.
When to report AS
- 1A homeowner refinances a mortgage with the same servicer and the original loan closes with a zero balance while a new mortgage tradeline opens.
- 2A credit union rolls a member's two consumer loans into a single new consolidation loan.
- 3An auto lender refinances a vehicle loan at a lower rate under a new contract.
- 4A card issuer replaces an old product with a new account number and a new agreement rather than amending the existing one.
Reporting rules
- Report AS on the closing tradeline with a zero Current Balance and a populated Date Closed.
- Open the replacement loan as its own tradeline with its own Date Opened, terms, and history going forward.
- Do not report AS on a loan that was amended in place. Use CN for a modification.
- Do not carry the old loan's delinquency history onto the new tradeline; each tradeline reports the history that belongs to it.
- If the refinance was done by a different lender that also purchased the balance, make sure the sale is reflected correctly rather than implying an internal event.
Codes and fields that must agree
A file can be structurally valid and still be wrong. These are the cross-field conditions Special Comment Code AS has to satisfy.
- Current Balance must be zero and Date Closed must be populated on the refinanced-away tradeline.
- Account Status should describe the account as paid and closed, or as transferred where the balance genuinely moved to another party.
- Amount Past Due must be zero; a refinanced tradeline cannot still be carrying arrears.
- If the balance was sold or assigned as part of the transaction, a K2 Purchased From/Sold To Segment names the counterparty.
- The new tradeline's Date Opened is the refinance date. Reusing the original Date Opened would misstate the age of the new obligation.
Common errors involving AS
Vocabulary
Keep browsing
- All 24 special comment codes — the full set with categories and cross-field rules.
- Metro 2 codes cheat sheet — every CRRG code set on one page.
- Special Comment field reference — position, length, and validation rules.
- Metro 2 format reference
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