The CRA employee that you spoke with clearly has NO comprehension of credit reporting.
The statement that any exclusion is based on date of a CO is simply rediculous.
The date that a creditor took a charge-off is not even reported to the CRAs. It is an internal accounting measure, and has no codes that permit the reporting of the date of a CO to the CRAs. It is not relevant to the CRA or to credit scoring, period.
Creditors only report, at some subsequent date, that they have previously taken a charge-off. They do not report the date of their CO.
If they have taken a CO, that then permits them to report CO as either the current status, of as the prior payment history profile delinquency status for any month after it was charged off.
The CRA has no ablility to determine the date of a charge off, and thus any statement that the exclusion date is based on the CO date is simply incorrect.
A creditor is required to separately and explicity report the DOFD to the CRA once they have reported a CO as either the current status or as a prior monthly payment history stauts, and the CRA uses that date to determine credit report exclusion.
I would call the CRA and ask for a supervisor, who should understand the clear inaccuracy in what their employee has stated.
If that does not get clarification, then I would send a formal complaint to the CFPB for their clear non-compliance with the FCRA exclusion provisions, as established by both the FCRA and current interpretation of the NYS early exclusion date statute.
A letter from the CFPB will be handled by a management official, and should obtain correct interpretation.
