FCRA 605(a) sets forth the maximum dates that adverse items of information may continue to be included in credit reports issued by the CRAs.
The FCRA does not regulate when an adverse item is actually discontinued from CR inclusion. A CRA is certainly entitled to discontinue its reporting at an earlier time, but common experience is that it is usually fairly close to the maximum permissible date. Exclusion too far prior to its maximum inclusion date fails to make important information available to creditors, which is the main reason for CRs in the first place.
DOFD is not the universal date applicable to continued inclusion of adverse account delinquency items. The DOFD is only relevant for charge-offs and collections, and affixes the maximum date for their inclusion in a consumer's CR. Individual monthly delinquencies each have their own individual exclusion dates, which is 7 years from the date of the reported delinquency.
The use of estimated fall off dates is thus not an accurate predictor of deletion, as what was used by the CRA to determine such dates is not disclosed.
The most common issue pertaining to predicted fall-off dates applies to collections and charge-offs. For some unexplicable reason, most commercial credit reports dont provide the legal date that determines the date of CO and CA exclusions, which is the reported DOFD on the OC account. Instead, they cloak the date-certain from the consumer, and instead state some predicted date, without stating the date upon which this expectation is calculated. One can attempt to back-date from the predicted exclusion date and attempt to determine the reported DOFD, but that is inaccurate. It would be no problem for the CRAs to just include the reported DOFD, but they tend to cloak it for some unknown reason.
DOFD should, in my opinion, be a required item in all credit reports vended to consumers. A consumer can always require the CRA to provide it to them, but such requests require payment of a processing fee to the CRA under fCRA 609(a).
