You are correct that section 809(b) does not explicity list reporting to a CRA as initiating collection on the debt.
However, there are innumerable case law decisions holding that credit reporting is considered to be initiation of collection on a debt, thus triggering dunning notice.
On a parallel note, seciton 809(b)similarly does not require itemization of the amount of the asserted debt as part of adequate debt validation if it is requested by a consomer. However, the courts have rountinely held that a consumer cannot evaluate the asserted amount of the debt without an itemization, and thus cannot determine if a debt collector is complying with FDCPA 808(1), which states that it is a violation for a debt collector to attempt to collect any amount that is either not specifically authorized in the agreement that creared the debt or otherwise permiited by law.
Statutory language alone does not always define the law.
Precendentail case law must also be considered.
