October 19, 2005

Memorandum

To: All DOI Employees

From: Debra E. Sonderman, Director /s/ Debra E. Sonderman

Office of Acquisition and Property Management

Subject: **New Credit Worthiness Requirement for Charge Card
Applicants**

The purpose of this memorandum is to provide information on new
requirements for obtaining a government charge card. Section 639 of the
Consolidated Appropriations Act, 2005, P.L. 108-477, as prescribed in
revised OMB Circular A-123, Appendix B, Improving the Management of
Government Charge Card Programs, Chapter 6, requires we conduct a credit
worthiness assessment for all new charge card applicants beginning
October 1, 2005. The Circular is available for review at
[www.whitehouse.gov/omb/circulars/index.html](http://www.whitehouse.gov/omb/circulars/index.html).

In practice, this will mean that a credit check will be conducted on all
new government charge card applications. In order to fully implement
this policy, a new Privacy Act Notice must be executed to cover the
collection and handling of new information not currently covered under
the Privacy Act Notice for the charge card program. The General Services
Administration will take action to implement a governmentwide Privacy
Act Notice. In the interim we will continue to process new applications
without a credit check. However, in the absence of a credit check, new
cards must be issued with restricted spending limits with travel and/or
purchase authority as needed.

After the Privacy Act Notice has been completed, Bank of America has
agreed, with the applicant's consent, to obtain the credit score and
issue a charge card with spending limits established by DOI. The
applicant's consent will be authorized by checking a box on the Account
Setup/Application Form. The new application form will be available
on-line at
[www.gov-eagls.bankofamerica.com](http://www.gov-eagls.bankofamerica.com/).

For additional information please see the attached questions and answers
(Q's and A's). The Q's and A's will be posted at
<http://www.doi.gov/pam/integratedcard.html> and updated as necessary.
If you have any questions regarding credit worthiness please contact
your agency/organization program coordinator or contact Cynthia Martin
on 202 606-3144 or cynthia_martin@ios.doi.gov.

**CREDIT WORTHINESS IMPLEMENTATION**

**QUESTIONS AND ANSWERS**

**1. Q: Who is subject to credit worthiness assessment?**

**A**: All new charge card applicants must be evaluated for credit
worthiness prior to issuance of a government charge card. A current
cardholder who leaves government service and then returns will be
considered a new applicant for the purposes of credit worthiness
requirements. A current cardholder changing bureaus within Interior will
not be considered a new applicant.

**2. Q: How will credit worthiness be assessed?**

**A:** The application form has been revised to include a place for
consent to a credit check. With the consent of the employee, Interior's
charge card contractor, Bank of America, will obtain a credit score for
new applicants on behalf of Interior.

**3. Q: Is there a passing score?**

**A:** The numerical score indicates the credit risk level associated
with a specific credit applicant. First time applicants will receive a
charge card with standard spending limits if the applicant has a credit
score of 660 or higher. Credit scoring information is available at
www.myfico.com.

**4. Q: What if my credit score is less than 660?**

**A:** For the first time travel business line applicant with a credit
score of less than 660, the bank may issue a card, but more stringent
restrictions will apply. For the first time purchase business line
applicant with a credit score between 500 and 660, the bank may issue a
card but more stringent restrictions will apply. The bank will not issue
the purchase business line to an applicant with a credit score lower
than 500.

**5. Q: What is the process if obtaining a credit score is not
possible?**

**A:** If obtaining a credit score is not possible (e.g., the applicant
refuses to provide consent or does not have a credit history), the
Circular allows a card with the most stringent restrictions to be issued
after an alternative credit worthiness assessment is conducted to
determine whether the individual possesses a satisfactory history. An
alternate process is being developed.

**6. Q: In keeping with the Privacy Act, what are the record keeping
requirements for credit scores?**

**A:** DOI will not receive your credit score. With your consent, Bank
of America will request your credit score, and from pre-determined
criteria as described above, issue the appropriate card. Since Bank of
America is obtaining the credit score record they are responsible for
maintaining those records in accordance with the requirements of the
Privacy Act.

**7. Q: How will I be notified if my credit score is less than 660
required for the standard card?**

**A:** The agency/organization program coordinator (A/OPC) will be
notified by Bank of America if the applicant is not eligible for a card,
or a restricted card will be issued. The A/OPC will notify both the
cardholder and their supervisor.

**8. Q: What is the purpose of the supervisor being notified?**

**A:** The supervisor will need to be aware that the employee's ability
to travel or make purchases may be affected.

**9. Q: I received a restricted card, or was denied a card. How can I
get a copy of the credit report that triggered this?**

**A:** If you are issued a restricted card, or are denied a card, you
may request a free copy of your credit report by contacting Equifax
Credit Information Services at 800 685-1111. General credit scoring
information is available on-line at www.equifax.com.

**10. Q: When are re-evaluations of credit worthiness required?**

**A**: A credit worthiness assessment must be conducted for restricted
cardholders before the cardholder is issued a renewed card. The
re-evaluation of credit worthiness may be conducted by obtaining a
credit score, or at the bureau's discretion, may be made by reviewing
the restricted cardholder's card usage during the initial period of card
issuance e.g., entire history prior to notification of card renewal.

**11. Q: How often may a credit check be obtained?**

**A:** A cardholder may request a new credit check after 60 days has
elapsed since their last credit check. Applicants who were denied a
charge card due to the outcome of their credit worthiness evaluation can
be re-evaluated at a time deemed most appropriate by the bureau. The
applicant's credit worthiness will again be evaluated based on the
requirements in this document.

**12. Q: Are there any circumstances in which credit worthiness
restrictions may be temporarily lifted?**

**A:** Yes. The credit worthiness restrictions may be temporarily lifted
at the discretion of the Bureau Director, in order to ensure the safety
of American citizens and/or property (e.g., during times of national
emergency, contingency, peacekeeping, or humanitarian missions.)

**13. Q: Will my government charge card spending line affect my
credit?**

**A:** Your government charge card spending line will not be included in
your credit report unless you become 180 days delinquent. At that time
your delinquency may be reported as a bad debt.

**14. Q: If I receive a restricted card, will it negatively affect my
personal credit report?**

**A:** No, the type of card you receive will not be reported.

**15. Q: Will this credit inquiry appear on my credit report?**

**A:** In order for you to know everyone who has requested information
related to your credit report, all inquiries are listed. Government
inquiries are coded "VF" so anyone reviewing your account will know it
was a government inquiry and not an inquiry based on a request for a
personal credit line.

**16. Q. Will requesting a credit check affect my credit rating?**

**A:** One credit inquiry will not significantly affect your credit
rating.