I dont see how the CRAs are the target of your complaints.
I know that it is quite often said that prior reporting of DOLAs on an account, such as dispute dates, dates of partial payments, dates of reporting of a CO or CA, etc., somehow act to reset the impact of derogs on the account when it comes to FICO scoring. I have no objective information to support or contest this assertion. Some have offered anecdotal experiences that seem to confirm this. And that is about the best you can probably get…. anecdotal experiences. Whether true or not, I don’t see that it leads to any FCRA violations.
FICO has never, to my knowledge, made any specific statements about the inner workings of their scoring algorithms when it comes to the aging affect of prior derogs., either with or without DOLA account updates.
The FCRA regulates credit reporting, and not credit scoring per se, except for two matters.
First are the provisions of FCRA 605(a) and (c), which specify so-called “drop off dates,” after which a prior derog with an OC or debt collector can no longer be included in your credit report, and thus your credit score. It is an all or nothing requirement on the CRAs under the FCRA. Your date of any actual delinquency cannot be reset, nor can your DOFD. That is clear, and objective. The FCRA does not specify how scoring is done on any derogs while still legally in your CR. It speciries 7 year drop off for monthly OC account delinquences from their date of occurence, and 7 1/2 year drop off for COs and CAs once 7 1/2 yers has expired from the DOFD on the OC account. No DOLAs can reset these dates.
Second, the FCRA does regulate, under FCRA 609(f), your entitlement to receive credit scores under various conditions, but it does not regulate how they are produced.
I am not sure what would be the basis for a complaint with the FTC against a CRA for any administrative or legal violation of the FCRA, based on the impact of their legitimate entries on your credit score.
The creditors can legitimately report activities on their accounts, including intitial derogs and changes in account status due to various activities commonly referred to as DOLAs and account status update codes. Once reported, the CRAs are obligated to record them in your credit file. Once recorded, then FICO decides how to score them. That scoring is not regulated by the FCRA. How they score is protected under federal trade secret law. Little chance in getting that changed, unless a major overhaul of federal intellectual property laws is first enacted.
The FTC currently has no jurisdiction over FICO credit scoring. I don’t think your evil nemesis is the CRAs, unless you can show that their handling of their recordation of what is reported to them violated some provision of the FCRA. I don’t think the FTC will choose to take any action against the CRAs,
