Collections drop after 7 1//2 years from the DOFD on the OC account.
The CRAs monitor this based upon a field code (25) in your credit file called the "FCRA Compliance/Date of First Delinquency."
The CRAs cant possibly, and independly, determine this date. They must rely upon timely and correct reporting of this date to them by the OC.
It works like this:
The first time that an original creditor reports an account to a CRA, they are required under the CRA reporting manual to provide a code indicating its current FCRA Compliance/Date of First Delinquency into field code 25. If, as in most cases, the first reporting does not include any account delinquency, they enter a code of "0" That is a "sticky" reporting data field, which means afte it is first entered, it carries over from month to month until expressely updated. The first month that an OC reports a delinquency with the CRA, they are supppsed to then also a report of update to filed code 25. That becomes your new, "sticky" DOFD until a later update, if any, is made by the OC. The OC will update under only two circumstances. If the delinquent account then becomes current, they are to then update field code 25 back to "0," and you therafter have no date of first default in your credit file. It goes away. There is no problem with this, for the DOFD only has any relevance in the calculation of dropoff of an OC or CA from your CR, and if the account is back in good standing, it will take a new delinquency upon which the OC can then base a CO or CA.
If a new delinquency occurs after that, then a new DOFD is updated to field 25, and all prior reporting to this code is updated.
So, if OCs fully comply with the CRA reporting manual, you should always have the current and correct DOFD stored in this easy to access field code of your credit file.
But they dont. Timely reporting of the DOFD is not regulated under the FCRA. OCs often ignore timely or even correct, reporting simply because while your account with them is open, the DOFD has no relevancy to them. So they become negligent in prioper updating. Then, when they do a CO or refer it for collection, they may still fail to enter any DOFD, or may even enter an improper one, such as the date of the last payment, date of the CO or collection referral, etc, which is clearly inaccurate.
Additionally there is the possible scenario of an OC no never posted anything to your CR while the account was open, and thus had no obligation to put anything into your credit file. Then, if a CO or or CA pops up. the CRA is clueless on how to meet their obligation under FCRA 605(c) in determining how long it can remain in their credit reports.
So, to deal with lack of prior reporting by the OC, the FCRA includes section 63(a)(5). which finally sets a statutory reporting of DOFD by the OC to the CRA.
That requires the original credti to, within 90-days of reporting a CO, or of placing the debt for collection (even if no CA has yet reported), the DOFD on the account, to confirm or provide a DOFD. What FCRA does specifically mandate (FCRA 623(a)(5)(B)(i), is that if the OC previously reported a DOFD to the CRA, the date they provide in further coimpliance with FCRA 623(a)(5) must match that date. That all is the statutory framwork to ensure the CRA will have a compliance date to then use. But, as with any statute, compliance is often ignored or incorrectly provided.
No CA can reset your DOFD. They dont have the facts to even guess at it. Only the OC does.
I give this long-winded explanation primarily because what DOFD is in your credit file, and thus the projected drop off date of a CO or CA, is determined by correct information provided by the OC. It is not usually the fault of the CRA, or even the CA, if the date is incorrect. OCs common make inconsitent reporting to different CRAs.
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