FCRA 605(c) was added to the FCRA to make it clear that you have one, and only one, DOFD on an account, and that is based on your date of first delinquency in the chain of delinquencies on your OC account that immediately preceded a collection, and applies equally to ANY collection reported on the debt. It is one, single, date-certain with one single date of CR exlcusion, which is 7 years plus 180-days from that single date.
The OC is required (if they have previsously reported the account to a CRA) to report a DOFD to the CRA within 90-days of referring a debt for collection, regardless of whether the debt collector has reported their collection to a CRA. So a DOFD must be in your credit file for any OC account included in your file within 90-days of a collection referral by the OC.
Debt collectors, in their required reporting of DOFDs to a CRA, are bound by very strict statutory provisions, added under FCRA 623(a)(5) at the same time as section 605(c) was added. While that statute can be a bit confusing, due to the need to cover numerous credit reporting scenarios, it in substance says that a debt collector, when reporting a DOFD to a CRA, must abide by the date reported by the OC, or if the OC did not report to the CRA, they must go directly to the OC and ascertain that date. They cant report dates of activity on their collection as your DOFD. YOur DOFD occured with the OC, and they are the source of the information.
