FCRA 605(c) mandates that collections and charge-offs must be excluded from your credit report no later than 7 years plus 180 days from the date of first delinquency that immediately preceded the reported charge-off or collection. Thus, credit report exclusion is based solely upon the date of first delinquency.
While the FCRA sets a max period of 7 years plus 180 days, the CRAs choose to exclude a bit earlier, which is normally at approx 7 years from DOFD. There is a slight variance amongst the big-3 CRAs, but 7 years from DOFD is the normal and expected exclusion date.
Since DOFD is the key for exclusion of a CO, the FCRA also mandates that once a creditor has reported a CO, they must, within 90 days of that first reporting, provide the CRA with the actual DOFD. See FCRA 623(a)(5). While the explicitly reported DOFD is thus required to be in the consumer's credit file, most commercial credit reports choose not to include that info in their reports, and substitute and estimated excllusion date that they have calculated based on the reported DOFD plus approx 7 years.
You can normally obtain the actual, reported DOFD from annualcreditreport.com.
You cannot, for several reasons, rely solely upon the payment history profile to determine the DOFD. That is why the FCRA explicitly rquires separate reporting of the DOFD whenever a CO or collection is reported.
While a reported 30-late will provide a good estimate, it does not always reflect the DOFD. Many creditors, for example, will not report a 30-late for several months after actual occurence of initial delinquency, and some will even wait until a higher level of delinquency, such as 60 or 90-late, has occured, while others will wait until charge-off to report delinquencies to the payment history profile.
