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In 2016, Credit Bureaus started enforcing an updated regulation which affected most collection agencies and other companies.

Collection agencies have always been required to ‘Hold’ or age a newly opened collection account for 60 days; 30 days from the date of first delinquency to the date opened and another 30 days from the date opened and date of account information which makes it a full 60 days before an account is actually eligible to be reported as a collection to a credit bureau.

This regulation changed, the 30 day gap between the Date of First Delinquency and the Date Opened increased to 90 days, which really means you need to have about 92 full days to satisfy the bureau validation for this condition.

What Does It Look Like?

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© copyright all rights reserved, image is not intended for legal advice.

What To Do About It?

Well you have to fix it if you want to continue reporting those accounts that fall into this new 90 day condition. Your credit bureau will simply stop processing those accounts until they are fixed but you don’t want to keep reporting fatal error accounts to your bureau. Stop reporting them until you figure out how to handle it.

Rolling the date opened forward aprox 62 days is one way to do this. You don’t want to change the date of first delinquency since this date is a critical reflection of account age and FCRA compliance.

What will happen, some accounts will be just fine, others may have to wait several days to be reported since the new date opened will now be in the future because we just increased it by X number of days.

How to Change The Date Opened?

This is where the real magic will happen, one way to approach this is programmatically. If you have in-house IT, they should be able to adjust data wherever it is stored. If not, they you have a problem, you will need to either manually correct the dates one at a time or hire a programmer who is capable of filtering and adjusting your data.

Related Error Messages:

  1. Error: Reported Date of First Delinquency is 1-90 days less than the Date Opened – Source: Experian Metric Report
    1. Description: The reported Date of First Delinquency is less than or equal to 1-90 days of the Date Open. Incorrect reporting: DOFD = 08/01/2013 and Date Open = 10/15/2013 (less than 1-90 days between the dates).
    2. Correction: he Date Open is the date the account was placed into collection with your agency or purchased by your company.  The Date of First Delinquency is the date the account first went delinquent with the original credit grantor.  In order to process these record(s) there must be at least 91 days between the Date Open and DOFD.

In the end, you need to make sure your solution is acceptable by the credit agencies you report with. They may want you to take a less automated approach when it comes to adjusting dates. Its always wise to make sure you understand the impact of changing a specific date for multiple credit histories.

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