FCRA · RE-AGING·5 min·2026-04-22

Re-aging: How Bureaus Manipulate the DOFD

The Date of First Delinquency (DOFD) is the anchor of the 7-year FCRA limit. When furnishers or bureaus reset it to a later date, they extend the reporting life artificially — a direct §1681c(c) violation.

How re-aging works

  • Original delinquency: January 2018.
  • Account sold to a collector in 2022.
  • Collector re-reports with "opened date" = 2022 or newer DOFD.
  • Item stays on report until 2029+ instead of expiring 2025.

Forensic signatures

  • Multiple DOFD values for the same debt across bureaus.
  • Balance transfers to new accounts without discharge of original.
  • Account status changes from "charge-off" to "active" post-sale.
  • Inquiry records pre-dating the supposed "opened date".

Statutory damages

  • Willful re-aging → $1 000 per violation + punitive (§1681n).
  • Reckless disregard (Safeco standard) is usually easy to show.
  • Class potential is high: same automated system affects many consumers.

15 U.S.C. §1681c(c) · §1681n · Safeco v. Burr

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