Consumer complaint received 06/27/2016 about Credit reporting () with Experian Information Solutions Inc. (CA).
Issue: Incorrect information on credit report
Sub-issue: Account status

Complaint: NEW INFO - DUNNING LETTER DATED XXXX/XXXX/XXXX ATTACHED! FTC PLAIN LANGUAGE OF 623 ( a ) ( 5 ) DOES NOT MATCH WHAT FURNISHER IS REPORTING AS DOFD XXXX XXXX, XXXX, Experian and XXXX continue to report old account on credit file due to furnisher purposely re-aging the account DOFD. Several links to FTC Opinion/Guidance included within, clearly confirm XXXX, Experian, XXXX and XXXX are in violation of FCRA with this account tradeline. Unsecured Line Of Credit ( LOC ) with XXXX XXXX XXXX in XX/XX/XXXX, defaulted in XXXX XXXX. First delinquency commenced in XXXX XXXX ( See attached Statement ). 
1 ) XXXX XXXX - XXXX XXXX restricted credit limit to XXXX ( as noted by XXXX XXXX on XXXX XXXX statement ). This was " denial or revocation of credit '' 2 ) XXXX XXXX - XXXX XXXX terminated the promotional APR and increased the APR due to derogatory/delinquent status of the account ( as noted by XXXX XXXX on XXXX XXXX statement on invoice and last page of statement where XXXX XXXX provides explanation that promotional APRs will be terminated if a consumer defaults on the account ). This was " a change in the terms of an existing credit arrangement '' 3 ) XXXX XXXX - XXXX XXXX transferred the account to internal collections department and sent dunning letter with specific language, " help resolve the delinquency '', " negative information will be reported on your credit '', and is signed by " XXXX XXXX '' ( attached ). 
4 ) XXXX XXXX - XXXX XXXX closed account on XXXX/XXXX/XXXX as noted on XXXX Credit File XXXX. Partial payments continued through XXXX XXXX, the account was never brought current. 
5 ) XXXX XXXX - XXXX XXXX charged off the account and is attempting to use this date as DOFD as opposed to following FTC guidance to use the earlier DOFD as required by FCRA 623 ( a ) ( 5 ) - CHARGE OFF DATE IS IRRELEVANT, FURNISHER MUST USE XX/XX/XXXX AS DOFD PER FTC DOCUMENT ATTACHED ( 40 Years of FCRA FTC Comments with Interpretations ) There were partial payments made on this account from XX/XX/XXXX - XX/XX/XXXX, account was never brought current. Delinquency occurred in XXXX XXXX and XXXX XXXX delayed reporting the charge-off to the CRAs for 44 months which is irrelevant ( exact language used by FTC ) per FTC guidance, the DOFD must be the date when the account first went to internal collections, not the date of the charge-off. Account sent to XXXX internal collections in XXXX. 
XXXX XXXX XXXX XXXX XXXX Please comply with FCRA Section 623 ( a ) ( 5 ), failure to comply after receiving this FTC guidance and documentation is considered willful violation of the FCRA by continuing to report inaccurate information with knowledge of its inaccuracy. The XXXX XXXX Research & Remediation Analyst at XXXX XXXX who validated the DOFD inaccurately is XXXX XXXX at XXXX ext. XXXX. I believe the FTC information attached demonstrates she has misinterpreted the FCRA Section 623 as she continues to validate the DOFD is the month prior to charge-off while neglecting to report the date noted in the dunning letter from XX/XX/XXXX. XXXX XXXX is aware of the correct guidance as they had input on the FTC compliance as indicated in the footnotes of the XX/XX/XXXX FTC Report to Congress. 
Thank you in advance for FINALLY removing this tradeline from my credit file!

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation