Under Section 623(a)(5) of the Fair Credit Reporting Act (15 U.S.C. § 1681s-2(a)(5)), any person who furnishes information to a consumer reporting agency regarding a delinquent account placed for collection, charged to profit or loss, or subjected to similar action must notify the agency of the date of delinquency on the account within 90 days of furnishing. The statute defines DOFD as the month and year of the commencement of the delinquency on the account that immediately preceded the collection or charge-off action. Under Section 605(c) (15 U.S.C. § 1681c(c)), the 7-year statutory obsolescence period for reporting delinquent accounts begins 180 days following that commencement date. Establishing an accurate DOFD ensures that negative trade lines automatically purge from consumer credit files after the statutory period. Manipulating or rolling forward the DOFD is known as unlawful debt re-aging.
Date of First Delinquency (DOFD)
The date of first delinquency (DOFD) is the month and year of the initial account delinquency immediately preceding placement for collection or charge-off that anchors the FCRA 7-year obsolete-information reporting window.
How this term is used
What the law covers
This is a defined federal statutory concept under 15 U.S.C. § 1681s-2(a)(5) and § 1681c(c). It governs credit reporting on consumer accounts. DOFD does not determine a state's judicial statute of limitations for filing a lawsuit to collect a debt; state limitation periods depend on state contract law, cause-of-action accrual rules, and specific debt categories. Subsequent events—such as selling the debt to a buyer, assigning it to a new collection agency, or partial payments that do not bring the account completely current under the contract—do not legally advance or reset the DOFD for credit reporting obsolescence purposes.
This note is informational. It is not legal, credit, or tax advice. Check the cited source and its date before you rely on it.
Why this matters
DOFD is the chronological anchor of consumer credit reporting compliance. Accurate tracking of DOFD across account sales and agency assignments prevents illegal re-aging, which is a major enforcement focus of the CFPB and FTC. When debt buyers acquire charged-off portfolios, preserving the original DOFD provided by the originating creditor is essential for accurate Metro 2 reporting and audit defense.
FAQ
What does Date of First Delinquency mean?
The date of first delinquency (DOFD) is the month and year of the initial account delinquency immediately preceding placement for collection or charge-off that anchors the FCRA 7-year obsolete-information reporting window.
Which official source covers Date of First Delinquency?
The sources at the bottom of this page link the statute, rule, or agency document this entry relies on. Check the date on that source before you rely on it.
What else is Date of First Delinquency called?
Other names used for this term include DOFD, Delinquency commencement date, FCRA obsolescence anchor date, First delinquency date.
Sources
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