Exclusion of either a collection or a charge-off is based on the date of first delinquency, with exclusion required no later than 7 years plus 180 days from the date of first delinquency (FCRA 605(c)). The CRAs routinely grant exclusion a bit early, at approx 7 years from DOFD.
The date that a debt collector obtained their collection authority (i.e., "began collection") is irrelevant.
A creditor or debt collector that has reported either a charge-off or collection is required under FCRA 623(a)(5) to separately and explicitly report the DOFD to the CRA no later than 90 days after having reported their collector or charge-off.
The CRA then uses that reported DOFD to establish their exclusion date.
It is possible for a CRA to exclude a charge-off a bit earlier than a collection, even though they have the same reported DOFD, as there is discretion in earlier exclusion. However, there is no discretion in exclusion once the period of delinquency has reached 7 years plus 180 days from the date of initial delinquency.
Removal of a charge-off or collection can also occur if the creditor or debt collector decides, for some reason, to report deletion to the CRA.
The bank, in the posted scenario, could have reported deletion of the charge-off prior to when it reached exclusion by the CRA, and thus removal of the CO would not mandate that the CRA also remove the related collection.
What is the DOFD that was reported by the creditor and by the debt collector?
If the DOFD reported by the debt collector has reached 7 years plus 180 days, you can dispute the lack of requried exclusion by the CRA.
Otherswise, if it has not yet reached its required exclusion date, then you must either wait for the CRA to exclude it, or contact the CRA informally and ask that they consider granting you a discretionary early exclusion.
