The use of DOFD for calculation of exclusion of derogs is only required under the FCRA for charge-offs and collections. See FCRA 605(c), which clarifies the exclusion provisions of FCRA 605(a)(4), which applies only to charge-offs and collections.
More specifically, exclusion must occur no later than 7 years plus 180 days from the DOFD.
To that end, creditors or debt collectors are required to separately and explicitly report the DOFD to the CRA no later than 90 days after reporting of a charge-off or collection. See FCRA 623(A)(5).
The use of DOFD for calculation of the exclusion of monthly delinquencies is not explicitly required under the FCRA, but rather is an interpretaiton made by the CRAs of the delinquency exclusion section, which is FCRA 605(a)(5).
More specifically, all monthly delinquencies occuring within the same chain of delinquency become excluded after 7 years from the date of the initial delinquency in that chain.
Thus, the separate reporting and storage of the DOFD is not required under the FCRA.
While the common credit reporting manual used by the big-4 CRAs permits reporting of DOFD after monthly delinquencies, it is not explicitly required, and thus may not be of record in your credit file.
If a DOFD is reported, it is stored under its own reporting code under the General Segment, Field Code 25, and is titled the "FCRA Compliance Date/DAte of First Delinquency."
Many commercial credit reports choose to omit showing of the DOFD, even if it has been reported.
You can usually find it in a report ordered from annualcreditreport.com.
