Product: Credit reporting or other personal consumer reports

I am writing in response to your letter regarding my dispute of late payment reporting and charge-off status on my XXXXXXXX XXXX XXXX account XXXX in XXXX. Your response fails to address the core discrepancies in your reporting and does not provide the required validation under federal law. The selective response and refusal to correct inaccuracies indicate willful noncompliance with your legal obligations. 

Legal Violations Identified 1. Violation of 15 U.S.C. 1666 ( Truth in Lending Act - Billing Errors ) Under the Truth in Lending Act ( TILA ), 15 U.S.C. 1666, I have the right to dispute billing errors, which include inaccurate reporting of payments and balances. Your response fails to address whether all payments and past-due statuses were verified against proper documentation and account reconciliation.

2. Violation of 15 U.S.C. 1681n ( Willful Noncompliance with FCRA ) Under 15 U.S.C. 1681n, a furnisher of information to a credit reporting agency that fails to ensure accuracy and correct known errors is subject to statutory damages. Your refusal to verify all discrepancies while maintaining the reporting of potentially inaccurate delinquencies constitutes willful noncompliance with the Fair Credit Reporting Act ( FCRA ).

3. Violation of 15 U.S.C. 1681 ( a ) ( 1 ) ( Duty to Report Fair and Accurate Information ) The FCRA mandates under 15 U.S.C. 1681 ( a ) ( 1 ) that the banking system relies on accurate credit reporting. Your response states that you are unable to confirm the events described in my dispute ; however, you continue to report information that has not been fully verified. This failure to conduct a proper reinvestigation while continuing to furnish inaccurate information is a clear violation of this duty.

4. Violation of 15 U.S.C. 1681i ( Failure to Properly Investigate Disputed Information ) Under 15 U.S.C. 1681i, consumer reporting agencies and furnishers must conduct a proper reinvestigation of disputed items. Your refusal to correct the reported delinquencies from XX/XX/year> and XX/XX/year>, despite the inaccuracies presented, confirms that Comenity Capital Bank has not fulfilled this requirement. 

5. Violation of 15 U.S.C. 1681s-2 ( Furnishing Inaccurate Information ) As a furnisher of credit information, you are obligated to report accurate information to credit reporting agencies. Your refusal to properly validate and correct the late payments on my account violates this obligation.

Unresolved Discrepancies and Demands for Verification Your response acknowledges that Comenity Capital Bank removed one late payment but declines to correct the remaining inaccuracies. This selective correction confirms that Comenity is capable of making updates but has failed to conduct a full and fair investigation.

I demand the following immediate actions : Complete Verification of All Reported Late Payments Provide a detailed breakdown of how each late payment and delinquency was verified. 

Submit copies of transactional records validating Comenitys reporting. 

Affidavit of Accuracy Submit a sworn affidavit attesting to the accuracy of the reported information and confirming compliance with 15 U.S.C. 1681n and 15 U.S.C. 1681 ( a ) ( 1 ).

Correction or Deletion of Unverified Information If Comenity can not provide documented verification for the continued reporting of delinquencies, the information must be removed immediately from my credit report. 

Documentation of Reporting Authority Provide evidence that Comenity Capital Bank has the legal authority to continue reporting these delinquencies.

Legal and Arbitration Escalation Failure to fully address these discrepancies within 30 days will leave me no choice but to escalate this issue to the appropriate regulatory agencies, including : The Consumer Financial Protection Bureau ( CFPB ) The Federal Trade Commission ( FTC ) The Office of the Comptroller of the Currency ( OCC ) Additionally, I will initiate arbitration proceedings to seek full correction of the inaccuracies on my report and recover damages for the harm caused due to these reporting failures. I am well aware of the arbitration process and will pursue this remedy if necessary. The costs associated with arbitration will be the responsibility of Comenity Capital Bank, per arbitration agreements and industry practices. These fees include : Consumer Case Filing Fee : {$220.00} Case Management Fee : {$1400.00} ( single arbitrator ) or {$1700.00} ( three arbitrators ) Arbitrator Compensation : {$1500.00} per case for desk arbitration or {$2500.00} per day for hearings Hearing Fee : {$500.00} Should this matter proceed to arbitration, I will seek full correction of my credit report and damages incurred as a result of Comenitys inaccurate reporting, including any financial losses I have suffered. This will be my next step if Comenity does not comply with the verification or correction of my disputed information.