Reporting requirements accepted and used by the CRAs are set forth in the "Credit Reporting REsource Guide" (c)2006, Consumer Data Industry Association. This is the manual of standard reporting requriements adopted by all of the CRAs.
The OC is required to report and update in a separate field the date of first delinquency in the last chain of consecutive delinquencies.. It is stored in your credit file, but not usually reported to you in your CR This date is the date used by the FICO algorithm to ensure compliance with the legal reporting periods in the FCRA, and are called compliance codes.
The "clock" for a 30-day delinquency starts 30 days from the due date for a payment, and not the billing date, so an account that goes overdue at 31 days from the billing date is not counted as delinquent if paid within 30 days of the due date.
These accounts have a stored compliance code of 011. If the account then goes 61 days from same prior due date, it trips up to a 60-day late, with a code of 071, and so on, but the date of first delinqency in the chain remains 30 days from the first delinquency in the chain, and does not change.
Once the account is then paid, but lthen has a later delinquency of 31+ days from a new billing due date, the DOFD is RESET, with a code of 011, and the old compliance code is gone. You then have a new DOFD. And so on. It is thus technically the date of first delinquency in the last chain of recorded consecutive delinquencies.
That is the date that triggers dropping of the derog from your CR at 7 years for CC debt, and 7 1/2 years for CO and CA accounts.
Dates of all prior delinquencies and dates of subsequent account activities, such as DOLA, are still stored in other fields of you credit file, and remain for other scoring uses, so update of the DOFD does not erase prior account delinquency information. It is used only for FCRA compliance purposes.
Efforts to require the CRAs to include this DOFD in all credit reports has been liitigated using the argument that a consumer has no way of monitoring complance with the FCRA without knowing this date, but as of now, the courts have not upheld this argument, so it is usually invisible to you. But it is in your credit file. A CA cannot reset this period based on anything they or you do in connection with collection account activity.
Message Edited by RobertEG on
07-31-2008 09:00 PM
