Equifax Credit Report comment section changed? Worth disputing?

[Anonymous]

Obtained a copy of my credit report directly from Equifax a few weeks ago and after going back over it tonight i noticed something interesting and was wondering the right course of action.

It was from a BOA student builder credit card i opened in 2008 with a CL of $1,100 and was settled/closed in 2012 after multiple lates and ending balance of $1,296. I have a few questions and are only listing the parts i see blank/important to mention:

Looking at the account it's listed as follows:

Account Number: 

Account status: pays as agreed

Available credit: $1,100

reported balance: $0

Amount past due:

Date of last activity:

months reviewed: 57

Activity designator: 

Deferred payment start date:

Date of first delinquency:

Date of last payment: Oct 1,2012

Delinquency first reported: 

Date closed: July 2012

Comments: Payment is payroll deductible

now my first question is this:  since the Date of first delinquency isnt listed and is blank, is that worth disputing? I thought DOFD was suppose to be reported in writing on the account?

Second: Is the 7 year rule starting from the date the account was closed down, or the date the last payment was made? Also I dont see delinquency first reported on there.

Third: Earlier in the year when i pulled my report from EQ I noticed in the comment section it was listed as  "account closed by credit grantors request".  This time around when i pulled my report again and went through it I noticed that the comment was changed to "Payment is payroll deductible".  

I did some searching and apparently this refers to wage garnishment and the need to deduct from my paychecks.  However the account has been closed and reporting in good standing since 2012 and this is the first time I have recently seen this comment.  I check my paystubs(electronically) every time i get paid and there has been no wage garnishment(nor need)- does this qualify as inaccurate reporting and worth disputing even though the account has been reporting normal since 2012?

i appreciate the advice and time taken to read my long post!

[Anonymous]

anyone?

[RobertEG]

The separate reporting of DOFD is only required under the FCRA when a charge-off or collection has been reported.

See FCRA 623(a)(5).

That is because the credit report exclusion of a collection or charge-off is, by statute (FCRA 605(c)), based ONLY on the reported DOFD.

More specifically, a collection or charge-off must become excluded no later than 7 years plus 180 days from the DOFD.

When a creditor reports monthly delinquencies, there is no requirement under the FCRA that they separately and specifically also report the DOFD.  

However, the CRA does also use the date of initial delinquency in a chain of delinquencies to determine the exclusion dates of each delinquency in the chain.  More specifically, all delinquencies in a common chain are excluded, under CRA practice rather than statute, at the same time, which is when the initial delinquency has reached 7 years.

The CRA credit reporting manual requests creditors to also report a DOFD when an account becomes delinquent, but it is not a requirment.

If no DOFD is reported, the CRAs use other, and less reliable, means to guess at the DOFD and then determine credit report exclusion of monthly delinquencies.

What, based on your own account records, is the likely date of initial delinquency for any prior reported delinquency chains, and has at least 7 years expired from that initial delinquency date?  If so, you can dispute and provide the CRA with your documentation that proves the initial delinquency date, and request their exclusion under FCRA 605(a)(5) based on the 7 year exclusion provision policy applied by the CRAs.

[Anonymous]

thanks for your explanation RobertEG, I will look into that.

ALso does anyone have any insight into the payroll  comment?