Product: Debt collection

Subject : Rebuttal to Concord Servicings Response and Request for Immediate Resolution To Whom It May Concern, I am responding to Concord Servicings inadequate reply to my CFPB complaint. Their response continues to disregard my claims and violates several federal and state laws. Below, I outline the specific issues and legal violations, supported by evidence, including their own submission of a fraudulent loan application and my FTC Identity Theft Report.

Issues with Concord Servicings Actions 1. Fraudulent Loan Application Details Provided by Concord Servicing : Concord Servicing included a screenshot in their response, allegedly showing my application for the loan in question. However, this application includes an address, phone number, and email address that are not mine. This proves that the application is fraudulent and supports my claim of identity theft.

2. Lack of Licensure in South Carolina : Concord Servicing, also known as Blackwell Recovery, is not licensed to collect debts in South Carolina, as verified through the Nationwide Multistate Licensing System & Registry ( NMLS ). Collecting without proper licensure is unlawful under South Carolina law.

3. Failure to Validate the Debt : Concord Servicing has failed to provide proper validation of the debt, including : Proof that the debt is valid. 
Documentation showing I authorized the debt or that the information on the application matches my personal details. 
Their reliance on fraudulent application data highlights their failure to properly investigate this debt.

4. False and Inaccurate Reporting : Despite their inability to validate the debt and their use of fraudulent data, Concord Servicing continues to report this account to credit bureaus, damaging my credit reputation.

Laws Violated by Concord Servicing 1. Fair Debt Collection Practices Act ( FDCPA ) : Section 807 ( 15 U.S.C. 1692e ) : Prohibits false, deceptive, or misleading representations, including false implications of legal authority to collect debts or reliance on fraudulent data. 
Section 809 ( 15 U.S.C. 1692g ) : Requires debt collectors to provide proper validation of the debt upon request.

2. Fair Credit Reporting Act ( FCRA ) : Section 611 ( 15 U.S.C. 1681i ) : Requires debt collectors to verify disputed debts and prohibits reporting inaccurate or unverifiable information.

Section 623 ( 15 U.S.C. 1681s-2 ) : Prohibits furnishing information to credit reporting agencies that is known or should be known to be false or inaccurate.

3. South Carolina Debt Collection Practices Law : Collecting debts without proper licensure is a direct violation of South Carolina state law.

4. Unfair, Deceptive, and Abusive Acts or Practices ( UDAAP ) : Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, engaging in unfair or deceptive acts ( such as collecting in an unlicensed state and reporting fraudulent information ) constitutes a violation.

5. Identity Theft and Reporting Violations : Failing to investigate and relying on fraudulent application data violates the Identity Theft and Assumption Deterrence Act ( 18 U.S.C. 1028 ).

Supporting Evidence 1. FTC Identity Theft Report : Filed and attached to this complaint.

2. Proof of Lack of Licensure : NMLS database confirmation showing Concord Servicing is not licensed in South Carolina.

3. Credit Report Excerpt : Showing Concord Servicing continues to report the fraudulent debt.

4. Fraudulent Loan Application : Submitted by Concord Servicing, showing an incorrect address, phone number, and email that are not mine.