There is no requirement that a debt collector provide any prior notice to or have communication with a consumer prior to reporting their collection to a CRA.
The requirement is that after they have initiated a communication with the consumer, they must then send a formal collection ("dunning") notice to the consumer within 5 days thereafter. The primary purpose of the dunning notice is to take some of the mystery out of the asserted collection by requriing, at a minimum, they identify the currrent owner of the debt, its asserted amount, and advise the consumer of their right to request debt validation within 30 days.
Case law interpretation in many jurisdictions is that reporting to a CRA does trigger the requirment to send dunning notice. However, that does not preclude reporting prior to sending of dunning notice.
If they fail to send timely dunning notice, that is a possible FDCPA violation or which they may be subject to damages, but it is not per se basis for requiring deltion of their reporting.
The new CRA policy, as set forth in their National Consumer Assistance Plan, of not including collections in credit reports they issue if it is a medical debt that is under 180 days of age, is not a prohibition against a debt collector reporting to a CRA, it is basis for the CRA then delaying inclusion of that reporting in any credit report they issue prior to expiration of the 180 day delay period. There is no violation on the part of the debt collector in reporting of their collection.
