Nothing in the FCRA mandates deletion of an OC account itself based on expiration of a credit report exclusion period for adverse information reported under the account.
CR exclusion under FCRA 605(a) only pertains to adverse items of information that were reported under the account.
Section 605(a)(1-4) itemizes certain specific adverse items of information that have their own set exclusion periods, and then provides section 605(a)(5) as a catch-all for any other type of adverse information not specifically listed in subsections 1-4.
Subsection 4 applies to a charge-off or similar action. Repos have been considered in the case law, depending upon the circumstances, to be a "similar action" to a charge against profit and loss, and thus under that provision, would have an exclusion date of 7 years plus 180 days from the date of first delnquency on the OC account.
Catch-all provision (5) sets a period of 7 years from the date of the adverse action, so at the very least, it would have a period of 7 years. However, being based on the date of the adverse action (i.e., the repo), that would usually be more than 7 plus 180 from DOFD, and would not be the interpretation that I would argue to be applicable.
Thus, depending upon what type of adverse item you consider a repo to be, it would become excluded either no later than 7 years plus 180 days from the DOFD, or 7 years from the date of repo. I would argue 7 plus 180 from DOFD.
