While the CRA is trying to sort it all out, I would suggest you require the posters of information and the CRAs to sort it out, using your OC account records.
There are several ways of dealing with "pop up" or "submarine" collections on your own, and you may not want to just sit back and wait or the CRA to "resolve" the issues. The CRAs, unfortunately, are not known for complete resolution.
Any entires of information to incorrect files is their error, not yours. So I would take action against how those errors are now affecting you, and not just trust them to make it right. Make sure each party reporting to the CRA has, and reports, your SSN as the primary matching factor, And secondarily your full name and current address.
You may want to take your own proactive measures in the interim.
First, how did these old "pop up" collections get into your credit file without consumer knowledge? FDCPA 809(a) was enacted by Congress primarily to prevent this type of garbage. From the day the debt collector posted a CA, they were required under FDCPA 809(a) to have separately advised you, in writing within 5-days of such a posting, of that fact, and your right to request its verifiction, by sending you a written collection (dunning) notice. Did they do this? Many consuemers are not as saavy of credit reporting as you are, and dont pick up CAs in their CR as you have done. They cant submarine you. Mayber a letter, while admittedly without any real legal teeth as of now, but maybe worth a stamp, to advise the posting CAs who have not complied with dunning notice requirements of their violtion of FDCPA 809(a), and advise them of your intent to file a complaint with the FTC. Additionally, the presence of lack of compliance with collection practices does not fall under the FCRA, and thus is not even an issue the the CRA will give even fleeting attention to. You need to adress this with the CA.
Going to the FICO scoring issues of these pop-up CAs, do you know the date of first delinquency on the OC account that preceded each of these reported collections?
IF you know the DOFD, then take the (DOFD + 180-days), add 7 years to that date, and the CRA is barred therafter from normally even including that CA in any credit report they issue. If the DOFD is known and not disputed, then you can write to the CRA for removal of the CA based on THEIR (the CRA's) violation of FCRA 605(c).
If you are unsure of the DOFD posted in your CR, the simple fact that a commercial consumer CR that you ordered does not clearly specify the DOFD, does not mean that it is not in your credit file. It just means that the CR you received is not a complete reflection of the information you need from your credit file.
When a CO or CA is posted, the creditor who referred the debt for either collection or did a charge-off is REQUIRED to have reported the date of first delinquency on the OC account within 90-days of their intial referral for collection or doing a charge-off. FCRA 623(a)(5)(A). That MUST be in your credit file. It is stored by the CRA as your legal "FCRA Compliance Date/Date of First Delinquency." How do you get it? Just file a request with with the CRA under FCRA 609(a)(1) for "all information in the consumer's credit file at the time of the request" for each and every DOFD for each and every CA account, reported in complaince with FCRA FCRA 623(a)(5)(A).
The CRA must comply with this. However, it does requrie that you accompany the request by payment of a fee of $10.50 to the CRA, under the provisions of FCRA 612(f).
Now, if you REALLY want to pull out ALL the big guns, also file a direct dispute with each CA under FCRA 623(a)(8) if you feel the information does not relate to any account of yours:
“This is a Notice of Direct Dispute with you, under the provisions of FCRA §623(a)(8)(D), of the accuracy of information you have reported to my credit file.
► (If sent to a debt collector, (CA), it might be beneficial to also include the blurb:
► This is a direct dispute of credit reporting. This is not a request for debt
validation/verification under FDCPA §809(b).
(don’t let them just simply sluff it off as a meaningless DV letter)
“In compliance with FCRA §623(a)(8)(D), and enacting regulations published at 16 CFR § 660.4, this Notice of Direct dispute includes:
“Identification of the specific information being disputed:
(specify the account number, and the specific information that is disputed under
that identifying account)
“Basis for the dispute:
(how the reporting was inaccurate; not associated with any debt of yours; no debt verification offered or provided)
“Supporting documentation:
(all documents that support your dispute; make sure to include,
as part of your documentation, at least a copy of the portion only of your
recent credit report showing their reporting of the disputed information was
actually reported to your credit flle. The implementing rule requires showing
that it appeared in your credit report;; if an identify theft for account not yours, a copy of your\
"Police/Identifty theft report"
“Under the provisions of FCRA §623(a)(8)(E) and 16 CFR §660.4,, you have the duty to review all of the information I have provided to you, to complete your investigation of this Direct Dispute, and report back to me the results of your investigation within 30-days of this Notice of Direct Dispute.”
I know this all sounds like a lot of legal and sdministrative BS leading to a lot or work and headache on your part, but the best defense is often a good offense. They pull this crap because they dont think consumers are saavy. I would be ready if, and probably when, the CRAs dont meet all of your entitled corrections.I just offer you a menu of things that could be pursued on your own.
took well over an hour for to just verify the stuff that SHOULD be on there. So I'll be back to having a thin file. There really was no explanation for it, but I was told I had better be sure to use my middle name from here on out.
