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Can you tell us more about this? It's not at all rare for a creditor to stop reporting an account once they have reported it closed. Some might continue to continually send an update with the same "closed" status every month, but many do not and there is no particular reason why they should.
Although you do not mention accounts that are so profoundly late that they have been turned over to a collection agency (or the in-house collection dept of a creditor) I am guessing that this is what you are thinking of, since that is what the FDCPA deals with. Most accounts that are simply closed are closed in good standing -- like loans that are paid off, credit cards closed by the consumer, credit cards closed due to inactivity, etc. -- and I can't see how the FDCPA would apply to them.
If you explain I bit more what you have on mind, then our resident legal expert RobertEG may be able to help you out.
If an account with reported delinquencies remains delinquent once the derogs (montly delinquencies or CO, or both) reach their required exclusion date, then the account will also be deleted by the CRA based on the need to also remove the current status as remaining delinquent.
However, that period is 7 years or 7 years plus 180 days from DOFD.
There is no provison of statute or regulation that mandates deletion of an account simply because it has a CO that has not been updated for a specified period.