UPDATE: ECMC is deleting after I filed a CFPB complaint. (original post regarding the background here.)
I noted they violated of FCRA by *twice* changing the DofFD and DofLA. Got a response that there was a "system conversion" issue that affected my account.. (??) and they would instruct credit bureaus to deleate. I would like to share two things I got from this whole episode:
1) There is a significant lack of information regarding what is allowable for student loan reporting -- whether FCRA applies, what date triggers the fall-off date from credit reports, etc. Best I was able to determine, the Higher Education Act makes federal student loan lenders and guarantors exempt from certain requirements, including FCRA. However, that does NOT apply to third party collection agencies collecting student loan debt. They must comply with FCRA. Additionally, new case law (Seamans v. Temple University)says that HEA does not exempt the lenders and guarantors from FCRA, either. So, while unpaid student loan debts can remain on indefinitely, PAID debt does rely on DofFD for the end of the reporting period and CRAs should abide by that. And, student loan lenders, guarantors, or collectors cannot change those dates.
2) ECMC seems to be a very difficult and hard-ball player. Don't be too sure that a GW request "can't hurt" with them because it might. Just make sure that you get as much info as possible before you approach them. Sounds like they have removed lates and things for some people, but they were very harsh with me on a paid collection & I ultimately was unable to resolve anything directly with them. Requesting a GW with them created a situation where the account ended up on my report for two extra months than it would have otherwise and resulting in a lot of extra work for me in putting together and documenting my case.
Starting Score: TU 490 on 11/2012