I am looking for someone who may have some knowledge of law and reading credit reports.
I have been reading through the Navient settlement and the Consent Judgement submitted by the state of New Jersey. In the Consent Judgement, I am having trouble understanding the definition they use for Charge-Off or "Past Due Status".
The Navient Parties agree to discharge and forgive not less than $1,710,000,000.00 of private education loans meeting the categories and criteria below as of June 30, 2021 ("Debt Relief ForgivenessDate").
In order to qualify for Categories 1 through 3, below, a private education loan must be charged-off* as of the Debt Relief Forgiveness Date ("PastDue Status"); and (1) have reached Past Due Status no more than seven years prior to the Debt Relief Forgiveness Date, or (2) be within the applicable statute of limitations based on the borrower's last known address as of the Debt Relief ForgivenessDate.
*The Navient Parties' policy for"Charge-off accounts due to delinquency" requires a loan to be charged-off by the end of the month in which the interest on or principal of that loan becomes 212 days or eight billing cycles past due, which ever is earlier.
The underlined part is what I am confused about. Does this mean the "First Date of Delinquency" or the "Delinquency First Reported" (as seen on an Equifax credit report)?
Fico 8 Starting Score (06/2020): Current Score (05/2022):