The exclusion period of 7 years plus 180 days from DOFD applies only to charge-offs and collections.
See FCRA 605(a)(4), as clarified by section 605(c).
The exclusion of monthly delinquencies is separately covered under FCRA 606(a)(5), which sets an exclusion period of 7 years (i.e., no additional 180 days applies).
CRA interpretation of exclusion of monthly delinquencies uses the date of initial delinquency as the start date for the 7 year exclusion period, and not the date of occurence of later and higher levels of monthly delinquency.
More concisely, all monthly delinquencies that are in a common chain that began on an initial date of delinquency are excluded once the period of delinquency reaches 7 years from the initial date of delinquency.
