The FCRA does not specifically mandate that a furnisher must initially report to a CRA, or that all information regarding payment history must be reported.
It also does not require that a furnisher report the exact same payment history derogs to all CRAs.
A creditor can, for example, wait to report a delinquency until it has exceeded a certain level, and is not required to report any and all 30-lates to each CRA.
They can report a 30-late to one CRA, but not another.
While an account that reaches 60+ days late could arguably be requried to show that level to be accurate, it has been acceptable practice over the decades of the FCRA for a furnisher to report 30-late when a higher level of delinquency could be reported.
Discrepancy in reporting between the CRAs, where one shows a substantially higher number of 30-lates than another, is not considered knowingly inaccurate reporting under FCRA 623(a)(1), and is not normally challenged under FCRA 623(a)(2) as requring update to a higher level of delinquency.
The question in the extra showing of 30-lates with a given CRA is not that they are not shown with another CRA, but rather whether the account was actually delinquent for that month/year.
For each reported 30-late, is the assertion that the account was in pays as agreed, good standing that month, and not delinquent at all, or that the reporting as 30-late should or could be reported as a different level of delinquency?
