Credit report exclusion of either a collection or charge-off is based ONLY on the reported date of first delinquency on the account with the original creditor. Use of a single, date-certain to define the begin of the exclusion period was added to the FCRA back in the 90's to clearly establish that no other date, such as the date of payment of a debt, the date of reporting of a collection or charge-off, of the expiration of the state statute of limitations on civil action, has any relevance to when the charge-off or collection must become excluded.
There are no conditions under which the exclusion of a charge-off or collection is extended based on any action of the consumer or the debt collector.
FCRA 605(C).
More specifically, no collection or charge-off can continue to be included in any credit report provided by a CRA after a maximum date of 7 years plus 180 days from the DOFD.
The CRAs choose to exclude at approx 7 years from the DOFD, which is the expected, actual exclusion date that is provided in many commercial credit reports. However, the CRA does not become in violation until the full 7 years plus 180 days has expired.
