Product: Debt collection

XX/XX/XXXX Consumer Financial Protection Bureau XXXX XXXX XXXX XXXX, IA XXXX Re : XXXX XXXX XXXX XXXX XXXX DOB : XXXX SSN : XXXX Re : Galaxy International Purchasing , LLC, Respondent C/O XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX, XXXX XXXX XXXX XXXX Account ID XXXX Re : XXXX XXXX XXXX  XXXX XXXX ), Respondent XXXX XXXX XXXX XXXX XXXX GA XXXX XXXX Account No. XXXX XXXX Account XXXX. XXXX XXXX Account XXXX. XXXX XXXX XXXX XXXX, XXXX XXXX XXXX. XXXX XXXX XXXX, Pennsylvania. XXXX Re : XXXX XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX, Ga XXXX Re : XXXX ', XXXX XXXX XXXX. XXXX XXXX XXXX, Texas. XXXX Re : XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX, GA XXXX Complaint for a Debt Not Due Comes Now Complainant, XXXX XXXX XXXX XXXX and in support hereof presents : 1. Complaint brings this Complaint to resolve a question of controversy as to whether : A consumer credit account, enrolled in a credit protection program offered by the card issuer, with a live and active claim pursuant to the terms of which monthly minimum payments are made by the card issuer on behalf of the card holder due to XXXX, is delinquent for reporting purposes under the Fair Credit Reporting Act and the Fair Debt Collection Procedures Act. 

2. In XXXX, Complainant applied and was approved for lines of cred upon the referenced accounts issued by the XXXX XXXX XXXX ( XXXX ). 

3. At all relevant times, XXXX offered a Credit Protection Program, pursuant to the terms of which enrollees could obtain payment relief whereby XXXX paid the monthly minimum payment due to, inter alia, XXXX. 

4. In XXXX, XXXX sold the referenced accounts to Galaxy International Purchasing , LLC ( XXXX ). 

XXXX. Between XXXX XXXX, XXXX, XXXX XXXX XXXX XXXX ), a debt collector and agent for XXXX, XXXX information that Complainant was and remains delinquent to the sum of {$1800.00} upon the referenced accounts to the following consumer reporting agencies ( XXXX ) to be included in consumer files, to wit : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX 6 . At the time of the sale, Complainant had and continues to have a live and active XXXX claim as pertains to the referenced accounts whereby XXXX is obliged to make the monthly minimum payments due upon the same. 

7. To secure my rights, privileges, and covenants thereunder, Galaxy, as a matter of law, is obliged to honor the terms and conditions of Complainants cardholder agreement with XXXX, inclusive of the terms and condition of the XXXX Credit Protection Program. 

8. The foregoing considered, due to my participation in the XXXX XXXX XXXX, and, further, upon which there is a live and pending XXXX claim which obliges XXXX and its assigns and successors to make the monthly minimum payments due upon the referenced account. 

9. Hence, the foregoing considered, as a matter of law, pursuant to the terms of the XXXX XXXX XXXX XXXX, the referenced accounts are not delinquent to the sum of {$1800.00}, or any other sum ( For want of maturity if no other reason ). Accordingly, reports of said delinquency reported to the referenced CRAs are inaccurate, false, and misleading under the terms of the FCRA and FDCPA. 

10. In resolution, Complainant asks : A. For CRA re-investigation of all issues raised in this Complaint. See : 15 U.S.C. 1681i ( a ) ( l ) ( ( A ) and 15 U.S.C. 1692g. 

B. That Galaxy honor the terms and conditions of the XXXX XXXX XXXX XXXX as obliged when it purchased the referenced accounts. 

C. That Galaxy and or XXXX remove or cause to be removed from Complainants consumer files with the referenced CRAs the derogatory report of Complainants delinquency to Galaxy to the sum of {$1800.00}. 


Cordially, _________________________ XXXX XXXX XXXX