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

    CodeAS
    MeaningRefinanced or Replaced
    FieldSpecial Comment (Field 31)
    RecordBase Segment
    Length / position2 chars · 213214
    CategoryTransfers, Refinances and Replacements
    CRRG referenceCRRG 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

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    Source: CRRG Exhibits 6 & 7 (Special Comment Codes). Last reviewed 2026-08-25.

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    Metro 2 Special Comment Code AS: Refinanced or Replaced