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Calculating Days Past Due for Credit Reporting

Answered by: 
Andy Zavoina | CRCM

Question: 
We are having an issue with our application giving a compliance error when the 30 days past due is not taken into account on the payment history. Can anyone direct me to a rule/regulations concerning calculating the days past due for credit reporting? If an account is due on April 1st and it was reported on April 30th then it is only 29 days past due so it is reported as a current account with an Account Status of “11 – Current Account (0-29 days past the due date)”.. If it is not paid in May, on May 31st it is now 60 days past due. The account status would then jump to “78 – Account 60-89 days past the due date”. Skipping Account Status ’71 – Account 30-59 days past the due date”. Is this correct? Would the Payment History read “2000000000000000000000000”.
Answer: 

I do not recall the FCRA defining this period. I have seen reports made that counted the actual number of days and some reported that 2 payments owed was a 30-day account because a "month" often assumes 30 days and two payments is a 30-59 day account. The Consumer Data Industry Association (CDIA) is generally followed by the CRAs and it recommends a strict counting of the days, but CDIA is not the FCRA.

And yes, Payments due April 1 and May 1 would reach a 60 day status on May 31 using the strict counting of actual days.

First published on 07/29/2018

Filed under: 
Compliance
Filed under compliance as: 
FCRA
Reg. V

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