The definitive CR exclusion dates are based on the actual dates of the adverse items scheduled for exclusion. Once the date of the adverse item itself in known, the exclusion date is a simple matter of addition of the relevant period set forth in FCRA 605(a).
Reported dates may be inaccurate, so should not be taken as gospel.
Do you have account records showing the actual dates of each item? If not, are the dates of the items themselves reported in your CR?
Monthly delinquency dates should be there, so simply add 7 years to each.
Collections and charge-offs require knowledge of the DOFD on the OC account, and then the simple addition of 7 years plus 180 days to that date.
Does your CR show either the DOFD, or the reported date of the first delinquency in the most recent chain prior to any reported CO or collection?
If you cannot determine the date of any adverse item from your commercial CR, you can always file a request with the CRA under FCRA 609(a)(1), which entitles you, for the processing fee of $11.00, to obtain any information of record in your credit file.
