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Shouldn't a collection come off of all 3 of your reports at the same time, since the DOFD is the same? On what basis would they come off several months apart (say more than 6 months)?
What FCRA 605(c) mandates is the maximun time that a collection can continue to be included in the consumer's CR, not when it can fall off.
The criteria for maximum CR inclusion for a CA or CA set forth in FCRA 605(c) has a window of 180-days after the DOFD before the 7-year period begins.
Thus, the max is DOFD plus 180-days plus 7 years.
The CRAs maintain algorithms to determine when they will cease CR inclusion for COs and CAs.
They can choose to just use 7 years from the DOFD as their deletion criteria, instead of 7 1/2 years, thus avoiding the common misunderstanding of the adddtional 180-days by many consumers. Using either 7 years or 7 years plus six months from DOFD would both be in compliance with the FCRA.
That is one reason why using the CRA projected fall-off date to back-calculate DOFD can be inaccurate.
wow, thanks for that really in-depth answer, robert!
my question is really, why don't they come off at exactly the same time? why does each report get to do what it wants, with the same information?
in this case, i had a midland collection come off of experian in february all by itself (no connection whatsoever to DOFD or the 7 to 7.5 years), & now i'm playing the waiting game for it to come off my other reports. one says april, one doesn't say anything at all, but i figured the 7.5 years would be november 2011. why don't they just come off all at the same time? i can't figure out why midland would voluntarily drop early from experian, but stay on my other reports. i wish i could just dispute it right off.
Dropping of a CA prior to, or without regard to, DOFD may be an indication that its removal from your CR had nothing to do with deltion on the part of the CRA.
It might mean that the debt collector deleted it because they have sold the debt to another debt collector. You would expect that they would delete with all three CRAs, but who knows why debt collectors do some of the things they do.
You might be on the lookout for a new CA reported by another debt collector. Who knows. If a new CA is reported, it is still subject to the same 7 years plus 180-days from the DOFD as was the first CA.
a new CA, i hadn't thought of that! that's a great thing for me to keep in mind. thanks robert!