CHardship, Workout and Payment Plans
Special Comment Code C: Account in Extended Forbearance
Special Comment Code C means "Account in Extended Forbearance". The same payment suspension as B, but running long enough to be a long-term hardship arrangement rather than a brief pause. Reported for as long as the extended forbearance is in force. It is reported in Special Comment (Field 31) of the Base Segment, 2 characters at position 213.
Specification
| Code | C |
|---|---|
| Meaning | Account in Extended Forbearance |
| Field | Special Comment (Field 31) |
| Record | Base Segment |
| Length / position | 2 chars · 213–214 |
| Category | Hardship, Workout and Payment Plans |
| CRRG reference | CRRG Exhibits 6 & 7 (Special Comment Codes) |
What Special Comment Code C means
- C is the long-duration counterpart of B. The distinction the source draws is duration of hardship, not a different legal mechanism.
- Like B, it describes a condition that is currently true and must be removed once the arrangement ends.
- C does NOT mean the debt was forgiven, settled, or reduced. Nothing about the amount owed changes because forbearance was extended.
- C does NOT substitute for a delinquency status if the borrower stops honoring the extended arrangement. Once the borrower falls outside the agreement, the account reports as what it is.
- Moving from B to C mid-hardship is normal. Only one Special Comment can be reported per cycle, so the record simply carries C from that cycle forward.
When to report C
- 1A mortgage servicer extends a hardship pause past the initial short-term window while a loss-mitigation review is under way.
- 2A student-loan servicer reports a long hardship forbearance for a borrower who has been out of work for most of a year.
- 3A lender continues a payment suspension for a borrower recovering from a long medical event.
- 4A servicer carries an extended disaster-related forbearance for properties in a declared disaster area.
Reporting rules
- Switch from B to C when the arrangement crosses from a short pause into a long-term one, and report C every cycle after that until it ends.
- Remove the comment in the first file after the extended forbearance ends, whether it ends by cure, by modification, or by default.
- If the extended forbearance is resolved by permanently changing the loan terms, report CN (loan modified) from the cycle the modification takes effect.
- Do not leave C in place through a subsequent charge-off. Once the account charges off, the comment no longer describes it.
- Do not report C on an account that never actually entered forbearance because a request was denied.
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 C has to satisfy.
- Account Status must remain truthful for each cycle of the extended arrangement; a long forbearance does not convert a delinquent account into a current one.
- Date of First Delinquency is unaffected. Extending a forbearance never moves the FCRA purge clock.
- Current Balance commonly grows across an extended forbearance as interest capitalizes; that growth should be consistent cycle to cycle.
- If the exit from extended forbearance re-writes Terms Duration, Terms Frequency, or Scheduled Monthly Payment, the comment should change to CN in the same record those values change.
Common errors involving C
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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