Can someone please provide guidance on the Date of First Delinquency (DOFD) as it relates to Mortgages with a due date on the 1st of the month? The CRRG manual says that the industry standard for reporting account delinquencies is that, "The “clock” for a 30-day delinquency starts 30 days after the due date, as opposed to the billing date."

I am encountering a problem that some colleagues want to state that the DOFD field should be the 30th when they are responding to ACDV’s or submitting AUD’s.

Logic would seem to be that if the mortgage payment is due on the 1st of the month that the DOFD would have to be the 1st of the following month. If this were not the case, then February customers would never be reported late because there are never 30 days in the month of February.

Can you explain to me where I am going wrong? Or, give me direction to locate documentation stating that the DOFD cannot be on day 30 when the payment is due in any month with 31 days?

Thank you for your help.

I would go with your logic too, but checked the CRRG to see what it said. The example in the CRRG for February shows if the payment is due on 2/1 and the payment isn't made, the DOFD is 3/3. The other examples look like they are strictly based on 30 days too.

Here are some other examples:
Due date 12/20 = DOFD 1/19
Due date 2/15 = DOFD 3/17
Due date 1/20 = DOFD 2/19

These examples are from the CRRG - Exhibit 9.

(A) Late Charge for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the end of ___________ calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be _____% of my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment.
(B) Default
If I do not pay the full amount of each monthly payment on the date it is due, I will be in default.
(C) Notice of Default
If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means.
(D) No Waiver By Note Holder
Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time.

Thank you for your input on this. I really appreciate it.

It did not occur to me to refer to the Note. Thank your for this.