A debt collector is not required to provide any notice to the consumer prior to reporting their collection to a CRA.
The requirement is that they must send a formal collection ("dunning") notice within 5 days after an "initial communication with the consumer." FDCPA 809(a).
There is no violation based on reporting of a collection without prior notice to the consumer.
The Date Opened of a collection is reported as the date that the debt collector obtained their collection authority.
It could be any date after initial delinquency on the OC account, and up to and including the date they initially report their collection. The consumer generally has no way, other than it being within that time period, to contest the Open date.
The Open date is not a factor in scoring or in determining the exclusion date, so it is rarely a substantive issue.
A furnisher can always correct any reporting if it is found to be inaccurate. The issue is not one of whether they can change prior reporting, the issue is whether the new reporting is knowingly inaccurate. FCRA 623(a)(1).
Once a furnisher has discovered that prior reporting is inaccurate, they are then legally required to change/update the reporting. FCRA 623(a)(2).
