FCRA reporting period for adverse items (runs from the date of first delinquency)
needs research· statutory · US · fcra.reporting_period.adverse_items v1 · file sha256 5f593f48744a…
Rationale
Seed rule. The numeric period and the extra-days parameter are placeholders written from general knowledge; they must be read from the primary source snapshot and anchored before this rule can be marked verified. Until then any computed date is labeled needs_research.
Authorities
- 15 U.S.C. § 1681c(a) primary statute — FCRA reporting periods for adverse items (consumer report contents) · source
- 15 U.S.C. § 1681c(c) primary statute — Running of reporting period (commencement of delinquency) · source
- CDIA Metro 2 Format — Date of First Delinquency field supporting industry convention — Industry reporting convention for the date of first delinquency field
Convention, not law. Cannot support a legal finding on its own. - Bureau policies on early removal of adverse items limitation bureau policy — Bureau practice of removing some items before the statutory period ends
Policy, not law. Must be researched per bureau and dated.
Links open public legal sources in your browser; this application itself never fetches them.
Primary-source snapshots
None on file. Import one with cda rules import-source.
Verification record
No human verification record.
Applies to
Account types: collection, charge_off, late, repossession, foreclosure · Circumstances: account.is_derogatory
Required elements
| Element | Fact tested | Test | Quote anchor |
|---|---|---|---|
| The item is an adverse account/collection/charge-off | account.is_derogatory | true | no anchor yet |
| The date of first delinquency is known from a reliable source | account.date_of_first_delinquency | known | no anchor yet |
Exceptions / limitations
- transaction_amount_thresholds (inapplicable if true, needs research) — Statutory exceptions for certain large credit/insurance/employment transactions; research whether any applies.
- bankruptcy_item (note, needs research) — Bankruptcy items have a different period (separate rule).
Calculation
method reporting_period_from_dofd · params {'trigger_fact': 'account.date_of_first_delinquency', 'years': 7, 'extra_days': 180} · parameters are part of the rule and inherit its verification status.
Contrary considerations
- Research question: the statute appears to run the period from the commencement of the delinquency that preceded collection/charge-off rather than from sale, assignment, charge-off date, or last activity; confirm from the primary text before relying on it.
- A date of last activity or last payment is not a substitute for the DOFD.
- Bureaus may remove items earlier as a matter of policy; that is policy, not a legal obligation.
Potential outcomes (not predictions)
potential_obsolete_reporting
Routes this rule can suggest
- Review whether the item is beyond its reporting period — Establish the DOFD from your own records, then compare with the reporting-period rule once verified.
- Investigate the date of first delinquency / possible re-aging — Collect your own statements and prior reports to establish the first missed payment before contacting anyone.
- Dispute the item with the bureau(s) — A written dispute to the consumer reporting agency identifying the specific inaccuracy and enclosing supporting documents.
- Dispute directly with the furnisher — A direct written dispute to the data furnisher about specific reported information.