Tending my Garden til 2/2020
Quick question.... is this a full report obtained through annualCreditReport.com? It may be that an ACR report would include richer information about the DOFD. I have little practical knowledge about derogs, since it was about 13 years since my last derog fell off, but I thought I'd just throw that out. Others can advise you better.
Credit report exclusion date calculation can be a bit complicated for one who does not have an understanding of the details of the FCRA.
Exclusion is pegged to the type and date of occurence of different types of derogs that are reported to a CRA.
Some have explicit begin dates for the exclusion period that are clearly specified in the FCRA, such as collections and charge-offs, which must become excluded no later than 7 years plus 180 days from the begin date, with the begin date clearly defined as the date of first delinquency (DOFD), while others have implied begin dates based on CRA interpretation/policy, such as monthly delinquencies, which the CRAs excludes as a common chain once the first delinquency in the chain reaches 7 years from the date of first delinquency in the chain.
Rather than rely upon consumer knowledge of the different exclusion periods and their definitions, the CRAs will do the calculation based on the type of derog, and provide the resulting estimated exclusion date. To further complicate the estimated date, they normally do not include the additonal 180 days in their calculation of the exclusion date for a collection or charge-off, and thus their estimated date includes an automatic early exclusion of approx 6 months. Thus, when they will normally exclude has a cushion from when the statute requires that they must esclude a collection or charge-off.
For a collection, neither the date it was place for collection nor the date it was paid has any relevance to when the collection must become excluded from your credit report. Exclusion of a collection is based only on the begin date that is a factual date-certain, and defined as the date that the debt first became delinquent with the original creditor, and thereafter remained delinquent up to the time of the collection referral. That is commonly referred to as the DOFD, and is requried under FCRA 623(a)(5) to be explicitly reported to the CRA by the debt collector. However, most commercial credit reports dont provide the DOFD, and you will need to either get a report from annualcreditreport.com or direclty from the CRA to see the reported DOFD.
The estimated month and year of exclusion of a collection is almost invariably calculated by the CRA based on the reported DOFD plus 7 years. However, if they dont exclude at 7 years, there is no violation, as they have an additional 180 days from that date before exclusion is mandated.