FDCPA 809(a) mandates that a collection ("dunning") notice must include advisement to the consumer of their right to request debt validation within 30 days of receipt of the dunning notice. It is thus not a valid dunning notice.
If they made any initial communication with you prior to sending the notice, then they are required under FDCPA 809(a) to have sent the notice within 5 days after the initial communication. If that notice did not fully comply with the advisement requriment of section 809(a), and more than 5 days have now expired, they are in violation of FDCPA 809(a).
You can file a civil action seeking statutory damages of $1,000 for violation of the FDCPA.
Regardless of whether you pursue damages for violation of FDCPA 809(a), you can file a DV request without first receiving a dunning notice, and it will still be timely. In that request, you can request the name of the original creditor.
A DV reqeust does not compel them to provide the date of first delinquency on the OC account.
They are not required to obtain the DOFD until they have first reported a collection to a CRA. That will then requrie them to obtain the DOFD from the creditor, and report it to the CRAs no later than 90 days after reporting of their collection.
