Many commercial credit reports dont include the specific DOFD reported to your credit file. Somethimes they include an inferential date by providing an "expected" or "anticipated" exclusion date, calculated is some unspecified manner. The expectation of many is they can just back-count 7 or 7 1/2 years and get the DOFD. further, the statutory date is the maximum, and statement that it will cease inclusion at date X or Y does not tell you what that date was based on.
The fact is that the reporting of DOFD to your credit file is REQUIRED to be provided within 90-days of a charge-off or collection referral under the provisions of FCRA 623(a)(5). It is an important date when any CR includes the reporting of a collection or charge-off, yet it is often omitted, while various other less significant dates such as date opened, date of last activity, etc. are normally included. Since the CRAs are the party responsible for monitoring the DOFD and ensuring that collections and charge-offs dont remain in CRs they issue beyond the statutory limit of 7 years plus 180 days, it would seem that the party benefitting most from routine exclusion of this important information from most CRs would be the CRA.
Consumers are entitled, under the provision of FCRA 609(a)(1), to request the reported DOFD that is of record in their credit file, but the CRAs get a fee of $11.00 for filling such information requests. We must pay to see one of the potentially most important items in our CRs. But consumer's do have access to this date under the provisions of section 609(a)(1), and if the precise date is necessary, you can utilize that source.
Just as, and in many cases even more important, is the determination of the party who reported the DOFD to the CRA. It can come from either the OC or the debt collector, depending upon the various scenarios set forth in section 623(a)(5). One needs to know the source of the reporting in order to file a direct dispute with the furnisher of that information. FCRA 609(a)(2) can additionally be used in those situations, but also requires payment of the $11.00 fee to the CRA.
