Is this reaging??

[Anonymous]

Hey guys,

I have two accounts that I "think" may have been reaged. I'll try and post the info as painless as possible

Account 1:

OC Bank of America Credit Card, the transunion credit report clearly says "estimated date to be removed 11/2010"   This OC has "fallen" off the report however

the Collection agency Midland says on the same report "estimated date of removal 09/11"

Account 2:

OC Bank of American checking account no longer on my report since before 2009.  But the Collection agency has listed on a copy of my 3/2009 report "estimated date to be removed 12/2010"  I checked my report today and now RJM is saying "estimated date to be removed is 4/11"??!!!

Are either of these reaged?? I am especially curious about the RJM one since it was due to fall of this month, and they just changed it.

Thanks

[llecs]

While the drop off dates are a general quide, I wouldn't put full faith behind them. They certainly can change. DW had a CapOne CO listed and her drop off date with TU changed monthly from October to December of this year before it fell off. I don't think CapOne re-aged it, but do think that TU changed it up each month.

Per the FCRA, bad accounts generally stay on 7 to 7.5 years from the DOFD. You'd want to find DOFD. A general guide is to subtract 7 yrs from the drop off date, however, since your goal is to disprove the drop off date, you shouldn't rely on that method. The surest thing to tell if DOFD was changed is to look in your org. records or even on your full CR as pulled directly from each CRA. Look for that first late. Assuming you didn't recover and get current, that first 30 day is the DOFD. Count 7-7.5 years from that date to come up with an accurate drop off date range. If the CR's drop date lies within or prior to your range, then they are reporting OK. If later, then it's quite possible the baddie was re-aged. Going off the drop off dates alone won't prove or disprove re-aging.

[RobertEG]

Maybe, maybe not.  You cant tell from an "estimated date of removal."

No creditor or debt collector ever reports an estimated date of removal of anything, and they are not responsible for determining estimated CR dates of removal.

They report the actual dates of delinquencies  themselves. They are not involved in determining how long any delinquency, be it a monthly delinquency on an OC account, a charge off reported by the OC, or a CA reported by a debt collector.  That determination is made, under FCRA 605(a) and (c) solely by the credit reporting agency. 

OC accounts themselves never have an estimated date of removal.  "Removal" does not relate to removing information in your credit file.  It only relates to how long an item of information can be included in a credit report issued by a CRA.  Nothing is "removed" from your credit file.  It is just a block of what can be reported.

FCRA 605(a) is about the date of required blocking of indivual items of information contained in your credit file from normal inclusion by a CRA in credit reports they issue after certain dates.  Each individual monthly delinquency reported by the OC has its own, separate date of removal from your CR after 7 years from its individ date of occurance.  A CO reported by an OC or a CA posted by a debt collector each has its own separated CR removal date of 180-days plus 7 years from the DOFD on the OC account,  Reaging would only occur if the OC has improperly updated the DOFD in your credit file.  Debt collectors dont update DOFDs

Dates of estimated removal of items that you see in your CR came from calculations made by the CRA, and are only as good as the accuracy of the underlying dates reported to them.  It is also totally dependent on the algorithm used by the CRA to determine this mystical "estimated date of removal."

Take, for example, the estimated date of removal of a CO or CA.  FCRA 605(c) clearly stipulates that a CO or CA must be delted from your CR after the max date of DOFD plus 180-days, plus 7 years.  But that is simply the statutory maximum.  Nothing prohibits any CRA from removing the reporting of any derog in your credit file from inclusion in their credit reports at an earlier time.  Perhaps, in order to give themselves some cushion in assuring their compliance with FCRA 605(c), they decide in their "estimated date of removal" algorithm to just use 7 years from DOFD, and forget about the additional 180-days.  Or maybe drop it to only 6 years.  Their discretion. No sweat off their backs, and they maybe then avoid a lot of consumer letters dealing with dates of removal.

Bottom line, in  my opinion, is that you cannot use estimated dates of removal of anything in your consumer credit report as evidence of illegal reaging of reporting done by the creditor/debt collector.