FCRA 605(a) is a comprehensive statute that applies to any adverse item of information reported to your credit file, and requries its exclusion after the prescribed period.
Various subsections of section 605(a) list specific adverse items of information and their specifici exclusion periods.
Any other adverse item of information that is not explicitly listed in another subsection falls under the catch-all provision of subsection 605(a)(5), whic reads:
"Any other adverse item of information, other than records of convictions or crimes, which antedates the report by more than seven years."
Regardless of whether it is reported as a speciifc monthly delinquency or a comment that asserts a delinquency, it must become excluded not later than 7 years from the date of occurence of the delinquency.
Exclusion under section 605(a) is the responsibility of the CRA, not the creditor, so your recourse is to file a complaint with the CRA of their continued showing of that adverse iinformation in your credit report beyond the exclusion period set forth in subsection 605(a)(5). With due deference to the CRA, it is understandable how they might miss a exclusion of only a comment. Once brought to their attention, it is clearly must be excluded.
