Credit Bureau Furnishing (Metro 2) — impact tolerance ≤ monthly cycle — ITOL

Impact tolerance: ≤ monthly cycle — any missed monthly Metro 2 file, or systemic accuracy defect (mass mis-reporting) that would require ACDV correction under FCRA 1681s-2 (illustrative default — trace the derivation, then replace with your own harm analysis)

Definition: Monthly submission of loan and deposit tradeline data to the three nationwide consumer-reporting agencies in Metro 2 format, under furnisher obligations in the FCRA (Fair Credit Reporting Act).

Why it is designated: FCRA furnisher accuracy and completeness duties are strict. Systemic errors trigger CFPB / FTC enforcement — recent years have seen multiple $10M–$100M consent orders. Missing a cycle or mass mis-reporting creates measurable consumer harm at scale.