There is no actual statutory prohibition against reporting to a CRA at any time, provided the furnisher does not report information that is knowingly inaccurate.
Legal action for reporting would thus be appropriate only if it can be shown that the landlord had knowlege that what was being reported was inaccurate.
State statutes set limitations on how long creditors can sue on debt, which are totally separate from any credit reporting exclusion periods.
The FCRA sets periods after which any adverse item of information that has been reported can be included by a CRA in any credit report they issue.
Those periods, except for unpaid tax liens, are all based on a date fixed to when the adverse item occured.
A landlord is most likely reporting delinquency in payment or, if corporate, possibly a charge-off of the debt.
Monthly delinquencies in payment are all excluded from a consumer's credit report 7 years after their date of occurence.
If the landlord charged-off the delinquent debt, it would be excluded 7 years plus 180 days from the date of first delinquency (DOFD).
None of those dates are updated based on when the landlord chose to report.
Thus, any delinquency that occured prior to 4/20006 should now be excluded.
If the landlord did a charge-off or referred the debt to a debt collector, either of those reportings would now be excluded if the date of first delinquency with the landlord was prior to 11/2005.
