The question relates to reporting requirements to the CRAs as opposed to requirements for sending billing statements to the consumer.
Because billing statements are necessary to set due dates, and thus compliance with revolving account agreements, the Truth in Lending Act, as modified by the Fair Credit Billing Act, require sending of monthly statements whenever there is either an account balance or a finance fee due.
However, the reporting of updated balances and current status of the account to the CRAs does not mandate a strict monthly reporting period or date. Rather, Fcra 623(a)(2) mandates only that updates necessary to reflect any changes in prior reported information be "prompt."
That provides some leeway for normal business processing/events, and is only covered by a "reasonableness" standard as opposed to strict dates/periods.
Not reporting updates for three consecutive months could clearly be argued to not be a reasonable compliance with the broad "promptness" standard under the FCRA.
You can file a dispute with the CRA contesting accuracy of the non-updated information, and lack of reasonable compliance with section 623(a)(2). You could also file a complaint with the CFPB for non-compliance witht he FCRA, forcing the creditor to explain the reasonable business events leading to their delay.
However, they cannot be sued for noncompliance for lack or compliance with the prompt update requirement of section 623(a)(2), and private civil action could not be pursued until the consumer first provided the creditor with the ability to correct by filing a dispute with the CRA. See FCRA 623(c).
I would thus recommend beginning by making an informal call of inquiry as to when updated reporting can be expected.
