I just read a very interesting opinion by Judge Cleland in the case of Purnell v Arrow Financial, 2007 U.S. Dist Lexis 7630 (Decided Feb 2007).
The collection agency defendant reported a debt that was disputed by the consumer to Equifax over a period of several months. The court held that each of these reportings to Equifax, without the dispute marker, constituted a discrete violation of the Fair Debt Collection Practices Act. Without boring you with the details, the statute of limitations for an FDCPA action is one year. In this case, however, that statute was renewed every time the collection agency reported the debt without the dispute marker.
Moral of the story to collection agencies – Be careful to report any debt that has a dispute with that dispute marker.