Only the FTC can sue under Section 611. So they're not required to delete? I've coupled 623 in my complaint alleging that if they do not provide a method of verification then I regard the TL as unverified.
No. A CO is only an accounting term. It doesn't mean the money isn't still owed. If you owed them the money you will always owe them the money until it is paid. Not all companies sell their COd accounts to JDB, some maintain them themselves.
Can't collect means the borrower didn't pay, not that it is uncollectable by any other term.