Under FCRA 605(c), a reported charge-off or collection must be excluded from your credit report no later than 7 years plus 180 days from the DOFD. The DOFD is a date-certain that is defined as the date the consumer first became delinquent on the debt in the chain of account delinquencies that led up to and includes the charge-off.
However, the FCRA only sets the maximum date after which the CRA can no longer include the charge-off or collection in credit reports they issue. The CRA has discretion in excluding at an earlier date, and will typically exclude at approx. 7 months from the DOFD.
The CRAs and other vendors of commercial credit reports make the assumption, and rightfully so, that most consumers do not understand all of the preceding, and in particular what a DOFD actually is, so they simplify their reports by providing an estimated date of credit report exclusion rather than only showing the DOFD, and leaving it to the consumer to determine when it will become excluded.
Since the estimated exclusion date that is routinely provided for a charge-off or collection is 7 years, but exclusion is not mandated until an additional 6 months has expired, it is not uncommon for a chrge-off or collection not to actually be excluded by the estimated date.
That does not mean there is any violation, and it is not disputable until the full 7 months plus 180 days has expired.
The CRAs are fairly consistent in exclusion after the estimated exclusion date, but dont scream violation if there is a delay of up to six more months.
The CRAs may also, solely at their discretion, grant an additional early exclusion of a few more months.
Note that exclusion of credit reporting is not the same as removal of the charge-off from your credit history or removal of the debt if it remains unpaid. Prior history remains in your credit file, and can still be obtained under certain and very limited conditions, as defined under FCRA 605(b). Additionally, if applying for credit and requested to list any unpaid, delinquent debt, the fact that the charge-off or collection has become excluded from your credit report is not basis for omitting disclosure of the unpaid debt.
