I’m asked about the Date of Last Activity (DLA) once a week, and have been for the past
several years. So what is it, why does it matter, and how are companies (debt collection
agencies) changing it? And, is changing the date of last activity abusive and possibly
illegal?
First things first, the DLA seems to have changed its definition since I was at Equifax.
The date was always changed whenever the consumer made a payment, missed a
payment, or the balance of an account increased. It was also the date that was used as
the purge from date. It’s the purge from function that seems to have changed.
The DLA still changes when you make a payment or the balance of an account or
collection is updated by the debt collector. However, it’s no longer the date used to
set the purge clock. There’s an actual date specifically used for that purpose called, to
nobody’s surprise, the purge from date.
For example, on a collection account, the dates reported with the item include two dates.
The first date is the “Date Opened”, which is the date the account was purchased or
acquired by a debt collector. The second date is the Date of First Delinquency, which
is the date the account went into default with the original creditor. It’s this second date
that is used as the purge from date. That date cannot change, unless it was reported in
error.
You’ll notice that the DLA is not one of the two options. Debt collectors do not control
the DLA. The credit bureaus control the DLA. However, I have heard of debt collectors
making changes to their accounts so that a balance increase is sent to the CRAs, which
does update the DLA.
The argument, and it’s a good one, is that if the balance on a collection grows month
over month or quarter over quarter the collector is obligated to update the balance on
the consumer’s credit report so that it’s accurate. The problem is updating the DLA can
possibly lead to a lower credit score because of the recent activity.
“The Credit Guru”, Longtime FICO Insider & Credit Industry Authority President Of The Ulzheimer Group, LLC
John Ulzheimer is a nationally recognized expert on credit reporting, credit scoring and identity theft. He is the President of The Ulzheimer Group, the Director of Credit Education at DisputeSuite.com, Credit Expert at CreditSesame.com and the credit blogger for Mint.com. Formerly of FICO, Equifax and Credit.com, John is the only recognized credit expert who actually comes from the credit industry. He has served as a credit expert witness in more than 150 cases and has been qualified to testify in both Federal and State court on the topic of consumer credit.
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