Repos come in two flavors. First are those that result in a loss to the creditor, which then becomes an account charged to profit and loss, or "subjected to any similar action," and second are those that are redeemed without any charge to profit and loss or similar action.
The first type of repo is governed by the credit report exclusion provisions of FCRA 605(a)(4) as modified by section 605(c), which is based on the DOFD, with an exclusion of no longer than 7 years plus 180 days from the reported DOFD.
The second type of repo is governed by the credit report exclusion provision of FCRA 605(a)(5).
A redeemed repo that is not charged-off or subjected to any similar action, such as auction of the vehicle that then results in some offset of the net loss, is not subject to the charge-off or similar action provisions of sections 605(a)(4) and 605(c). Repossessions dont have their own, specific exclusion provision under any subsection of FCRA 605(a), and are thus covered under the catch-all provisions of section 605(a)(5), which covers "any other adverse item of information" not specifically listed under any other subsection of section 605(a). The adverse item of information under subsection 605(a)(5) (i.e., the repo of the redeemed vehicle) must become excluded no later than 7 years from the date of occurence of the advere item.
The "adverse item of information" at issue is the repo of the vehicle, NOT the repayment of the delinquent debt that permitted the redemption of the vehicle.
Thus the credit report exclusion of the redeemed repo would be 7 years from the date of their repo of the vehicle, and NOT the date that you made payment.
The account would remain absent any showing of the repo, and could then be subject to the housecleaning deletion by the CRA at ten years from its date of closing.
The failure to comply with FCRA 605(a)(5) can be handled by admin complaint to the CFPB or by bringing your own civil action against the CRA for their violation of FCRA 605(a)(5).
