When negative accounts are reporting to your credit inaccurately, then it will rarely reappear on your credit report once it has been removed. In the event that this does happen, the credit-reporting agency is required by law to notify you that this has happened.
When an account is removed it is highly unlikely that it will appear. In most instances when an account is placed back on the credit report after it was removed, happens largely due to the fact of an individual or credit repair company using dishonest tactics which later were discovered by the credit reporting agencies. Once the discovery is made, the credit agencies will re-report the account back to the credit report.
This type of issue can be easily avoided by using 100% ethical, honest credit repair tactics.
Scenarios in which negative accounts are actually reported back to the credit report after they were removed:
1. Credit sweep- Filing identity, although your identity wasn't stolen.
2. Filing disputes online- This is an absolute NO NO. When you dispute online accounts are often reinserted back to the credit report.
3. Filing disputes saying "The account is not mine". This is an illegal, outdated and incorrect method of disputing. After they discover the account is yours, they'll report it back to your credit report.