A sticky one if interpreted under the strict language of the statute, which states that "the debt collector shall cease collection of the debt or any disputed portion thereof, until the debt collector obtains verification of the debt.....and a copy of the verification ... is mailed to the consumer."
Technically, if one interprets "collection of the debt" to mean any activity, it could be asserted that taking payment was barred.
One could also interpret lack of having mailed verification to the consumer as still precluding credit reporting of their prior collection on the debt.
However, my reaction is that neither was intended by the statute to be a barred collection on the debt.
If payment was offered by the consumer without any prior conversation, it is a stretch to interpret the intent of section 609(b) as preventing action solely on the part of the consumer. The intent of section 609(b) was to relieve consumers of active collection until they have benefit of assurance from the debt collector that they have basis for determining that the debt is valid and that the consumer is the responsible debtor.
Negotiations on a settlement for less or a PFD request are clearly barred, but I would not interpret the statute as intending to bar unsolicited payment.
It does not fall under the congressional intent of section 809(b), and not something I would pursue.
AS for credit reporting after payment, yes, that too could be asserted as a technical violation as a collection activity.
However, my interpretation is that it is not. Once paid, there is no more debt, period. Thus, credit reporting would not thereafter be associated with any collection of the debt, but rather an activity intended to provide the CRA, and thus others, credit history on the consumer. Their reporting would not be disputable under the FCRA based on any DV issues under the FDCPA, as the reporting of current balance of $0 is accurate.
Debt verification, if they were required to provide it prior to reporting, would simply be the statement that "we verify the debt to be $0."
That could still be done, thus permitting the reporting, and leaving only taking them to task for an asserted violation.
I doubt the FTC/CFPB or any judge would consider any violation of section 809(b) simply because that obvious fact had not yet been conveyed in writing to the consumer.
In my opinion, that is form over substance.
