Product: Debt collection

To : Consumer Financial Protection Bureau From : XXXX XXXX XXXX : XXXX Subject : Clarification of " Loan Type '' under the FCRA and Dispute of Verification by Equifax I. Introduction This memorandum addresses XXXX ( XXXX ) related issues : The improper classification of " CHILD SUPPORT '' as a " Loan Type '' under the Fair Credit Reporting Act ( FCRA ). 

As well as The deficiencies in XXXX verification process regarding the disputed credit report information, the response submitted by Equifax to the Consumer Financial Protection Bureau ( CFPB ) regarding a dispute involving inaccurate information on a consumer credit report. Specifically, it challenges XXXX claim of having verified the disputed information, which is central to compliance with multiple provisions of the Fair Credit Reporting Act ( FCRA ). The response violates 15 U.S.C. 1681 ( a ) ( 1 ) ( 2 ) ( 3 ), 1681b ( a ) ( 2 ), 1681e ( a ) ( b ), and 1681s-2 ( a ) ( 1 ) ( A ) ( B ) ( i ), as verification as defined under statutory and legal interpretations requires substantiation by formal oath, affidavit, or equivalent authenticated processes. As reported to the Consumer Financial Protection Bureau ( CFPB ) Complaint Portal # XXXX. 

XXXX. Clarification of " Loan Type '' Under the FCRA and Dispute of Child Support Classification A. Background Under the FCRA, " Loan Type '' refers to obligations arising from formal contractual agreements involving mutual agreement, repayment obligations, and consideration. Typical examples include mortgages, auto loans, personal loans, and credit card accounts. 

The attached document lists " CHILD SUPPORT '' as a " Loan Type '' on credit reports. This classification is legally inaccurate as child support obligations are determined by court orders, not by any contractual loan agreement. 

B. Key Observations Absence of a Contractual Agreement Child support arises from court orders, not mutual agreements between parties. 

There is NO LOAN CONTRACT or REPAYMENT terms that meet the XXXX definition of a " Loan Type. '' There was XXXX XXXX of Funds. 

Child support involves no transfer of funds or credit from a lender to a borrower. Instead, it reflects a legal obligation to support a dependent. 

Misclassification as a Loan Type Listing child support as a " Loan Type '' misrepresents the nature of the obligation and creates inaccuracies on credit reports, which adversely affects my financial opportunities. 

XXXX Conclusion and Remedy The classification of " CHILD SUPPORT '' as a " Loan Type '' violates the XXXX mandate for accurate reporting. I request the immediate removal/deletion from my credit report. A formal acknowledgment of this dispute and details of corrective actions taken are requested in compliance with the FCRA. 

XXXX. Contesting XXXX XXXX Process A. Background Equifaxs response to the CFPB in Complaint # XXXX : XXXX. ) COUNTY OF XXXX XXXX EQUIFAX VERIFIED THAT THIS ITEM BELONGS TO YOU. 
XXXX. ) XXXX XXXX XXXX XXXX XXXX EQUIFAX VERIFIED THAT THIS ITEM BELONGS TO YOU. 

These accounts were reported as open accounts with past-due balances, which is inaccurate given their non-credit nature as child support obligations. 

B. Legal Deficiencies in Equifaxs Verification Process Violation of FCRA Provisions 15 U.S.C. 1681e ( b ) : CRAs must use reasonable procedures to ensure maximum accuracy. Equifax failed to provide substantive evidence of verification, relying on superficial affirmations.

15 U.S.C. 1681s-2 ( a ) ( 1 ) : Information furnishers are obligated to correct or delete inaccurate data. XXXX response perpetuates inaccuracies in violation of this duty. 

XXXX*Improper Use of " Verification '' As per XXXX XXXX XXXX, verification entails authentication through oath or affidavit. XXXX failure to provide such substantiation invalidates its claims of verification. 

Impact on XXXX Rights The inaccurate reporting and flawed verification process undermine consumer protections under the FCRA and cause unjust harm to financial reputation and opportunities. 

XXXX Remedies Requested Immediate deletion of disputed inaccurate information from my Equifax XXXX XXXX XXXX. 

Formal acknowledgment of XXXX failure to verify information per statutory requirements. 

Consideration of penalties for non-compliance with FCRA obligations. 
IV. Broader Implications and Potential Violations A. FDCPA Violations The Fair Debt Collection Practices Act ( FDCPA ) prohibits harassment and abusive practices. Misreporting child support obligations as credit accounts and inconsistently reporting balances constitute grounds for an FDCPA complaint. 


B. Violations of 18 U.S.C. 242 The continued harassment and misrepresentation of obligations constitutes deprivation of rights under XXXX of law. Such actions deny equitable access to financial resources and violate fundamental rights to life, liberty, and the pursuit of happiness. 

XXXX Conclusion The reporting of child support obligations as " Loan Types '' and the flawed verification process by Equifax represents serious violations of the FCRA. Immediate actions are necessary to restore accuracy, uphold consumer rights, and ensure compliance with federal law. 

Failure to comply with this request within 30 days will leave me with no alternative but to escalate this matter, including filing complaints to the Federal Trade Commission ( FTC ), and pursuing legal remedies under the FCRA. Furthermore, your actions constitute willful violations of my rights under 15 U.S.C. 1681n and negligent violations under 15 U.S.C. 1681o, which entitle me to seek statutory and punitive damages. 

Please acknowledge receipt of this request and confirm your actions in writing within the time frame prescribed by the FCRA. I expect prompt and complete resolution of this matter. 

Requested Actions : Deletion of All disputed accounts with formal confirmations. 

Adoption of improved verification processes and penalties and consideration for non-compliance. 

A formal cease-and-desist order against harmful and inaccurate reporting practices by the child support agency. 

Respectfully submitted, By : XXXX XXXX [ Without Prejudice ] ( Authorized Representative )