Reporting Delinquencies in Metro 2®
Accurate delinquency reporting is critical for FCRA compliance. This guide covers the account status codes, payment history construction, and Date of First Delinquency rules you need to implement correctly.
1. Account Status Codes for Delinquency
These Account Status codes (Field 17A) indicate delinquency. Each corresponds to a specific stage of late payment.
11CurrentAccount is current (0-29 days past due). Not delinquent.
7130 Days Past DueAccount is 30-59 days past the due date.
7860 Days Past DueAccount is 60-89 days past the due date.
8090 Days Past DueAccount is 90-119 days past the due date.
82120 Days Past DueAccount is 120-149 days past the due date.
83150 Days Past DueAccount is 150-179 days past the due date.
84180+ Days Past DueAccount is 180 or more days past the due date.
97Charge-OffUnpaid balance reported as a loss. Typically after 120-180 days.
2. Payment History Profile Construction
The Payment History Profile (Field 21) is a 24-character string that tracks monthly payment status. Position 1 is the most recent month, position 24 is the oldest.
// Payment History Profile for a delinquent account
// Position: 1 2 3 4 5 6 7 8 ... 24
// Meaning: Jan Dec Nov Oct Sep Aug Jul Jun ... Feb(2yr ago)
// Example: Account went 30 days late in November,
// caught up in December, current in January
"001000000000000000000000"
^ ^
| └── November: 1 (30 days late)
└── January: 0 (current)
// Example: Account progressively delinquent
"321000000000000000000000"
^^^
||└── 3 months ago: 0 (was current)
|└── 2 months ago: 1 (went 30 days late)
└── This month: 3 (now 90 days late — escalated through 2 and 3)Status Codes for Payment History
0 — Current (0-29 days)1 — 30-59 days late2 — 60-89 days late3 — 90-119 days late4 — 120+ days lateD — Deferred/ForbearanceE — CollectionL — Charge-off — (space) No history3. Date of First Delinquency (DOFD) Rules
Warning
Incorrect DOFD reporting is the #1 cause of FCRA disputes. Getting this wrong can result in regulatory action and consumer lawsuits.
The Date of First Delinquency (Field 25) determines the 7-year purge date for negative information on a consumer's credit report. It must be set correctly and never altered inappropriately.
When to SET the DOFD
- • When the account first becomes delinquent (status changes from 11 to 71+)
- • Set it to the date of the missed payment that started the delinquency
- • For charge-offs: DOFD is the date of the first missed payment that led to the charge-off
When to KEEP the DOFD
- • As delinquency progresses (71 → 78 → 80, etc.)
- • When the account is charged off
- • When the account is sent to collections
- • During bankruptcy proceedings
When to CLEAR the DOFD
- • When the account returns to current status (Account Status 11)
- • When the delinquent balance is paid in full and status returns to current
- • Do NOT clear DOFD just because a partial payment was made
// DOFD logic example
function updateDOFD(record, previousStatus, newStatus) {
const isDelinquent = (s) => ['71','78','80','82','83','84','97'].includes(s);
if (!isDelinquent(previousStatus) && isDelinquent(newStatus)) {
// Transition from current to delinquent: SET DOFD
record.dateOfFirstDelinquency = record.paymentDueDate;
} else if (isDelinquent(previousStatus) && !isDelinquent(newStatus)) {
// Returned to current: CLEAR DOFD
record.dateOfFirstDelinquency = null;
}
// If staying delinquent: KEEP existing DOFD (do nothing)
return record;
}4. Amount Past Due Tracking
The Amount Past Due (Field 19) must reflect the total amount of payments that are overdue. This amount must be consistent with the Account Status code.
// Amount Past Due must match Account Status
// Account Status 11 (current): Amount Past Due = 0
// Account Status 71 (30 days): Amount Past Due = 1 missed payment
// Account Status 78 (60 days): Amount Past Due = 2 missed payments
// Account Status 80 (90 days): Amount Past Due = 3 missed payments
// Example: $500/month payment, 60 days past due
{
"accountStatus": "78",
"scheduledPaymentAmount": 500,
"amountPastDue": 1000, // 2 months * $500
"currentBalance": 15000,
"dateOfFirstDelinquency": "2024-11-01"
}Key Rules
- • Amount Past Due must be greater than zero for any delinquent status
- • Amount Past Due must be zero when Account Status is 11 (current)
- • For charge-offs (97), report the remaining unpaid balance
- • Partial payments reduce Amount Past Due but may not change the status code
5. Transitioning Between Delinquency Stages
Delinquency must progress naturally through each stage. You cannot skip stages or move backwards without the consumer bringing the account current.
// Valid progression: each month advances one stage
Month 1: Status 11 → Payment missed → Status 71 (30 days)
Month 2: Status 71 → Still unpaid → Status 78 (60 days)
Month 3: Status 78 → Still unpaid → Status 80 (90 days)
Month 4: Status 80 → Still unpaid → Status 82 (120 days)
Month 5: Status 82 → Still unpaid → Status 83 (150 days)
Month 6: Status 83 → Still unpaid → Status 84 (180 days)
// INVALID: Skipping from 71 directly to 80
// You must report 78 (60 days) in between
// Account catches up: consumer pays all past due
Month 7: Status 84 → Paid current → Status 11
// DOFD is cleared, Payment History retains the delinquent monthsPartial Payment Rules
- • A partial payment does not automatically bring the account current
- • The consumer must pay all past-due amounts to return to status 11
- • A payment that covers only the current month but not arrears does not reduce the delinquency stage
6. Re-aging Prevention Rules
Re-aging is the illegal practice of resetting the DOFD to make negative information stay on a report longer than the 7-year FCRA limit. The following rules prevent re-aging violations.
Never Do These
- • Never change the DOFD when transferring an account to a new servicer
- • Never reset the DOFD when a consumer makes a partial payment on a charged-off account
- • Never change the DOFD when selling the debt to a collection agency
- • Never report a new account for the same debt with a new open date
Correct Practices
- • Carry the original DOFD through all account transfers
- • Only clear DOFD when the full past-due amount is paid and status returns to current
- • When reporting a charged-off account, DOFD stays as the date of the first missed payment in the sequence that led to charge-off
- • Document all DOFD values for audit and dispute resolution