Product: Credit reporting or other personal consumer reports

Dated : XX/XX/XXXX Respectfully submitted, XXXX XXXX XXXX XXXX XXXX XXXX, XXXX, VA XXXX Email : XXXX Phone : ( XXXX ) XXXX Attorney for Plaintiff COMPLAINT Plaintiff, XXXX XXXX XXXX by and through the undersigned attorney, hereby files this Complaint against Defendant Affirm XXXX XXXX XXXX and alleges as follows : JURISDICTION AND VENUE This action arises under the Truth in Lending Act ( TILA ), 15 U.S.C. 1635, and the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681.

This Court has jurisdiction pursuant to 28 U.S.C. 1331.

Venue is proper in this judicial district pursuant to 28 U.S.C. 1391 ( b ), as the Defendant conducts business in this district and a substantial part of the events giving rise to the claims occurred within this district. 
PARTIES Plaintiff : XXXX XXXX, a consumer residing at XXXX XXXX XXXX XXXX, XXXX, VA XXXX, born XX/XX/XXXX. 
Defendant : Affirm , Inc. is a financial institution located at [ Defendants Address ]. 
FACTUAL BACKGROUND On or about XX/XX/XXXX, Plaintiff entered into a credit transaction with Defendant for the purchase of goods, financed through Affirm , Inc . The loan was governed by 15 U.S.C. 1635.

Defendant failed to provide Plaintiff with accurate material disclosures required under TILA, including information about Plaintiffs right to rescind the transaction.

On or about [ Rescission Date ], Plaintiff mailed written notice to Defendant seeking to rescind the transaction pursuant to 15 U.S.C. 1635 ( a ).

Despite receipt of the rescission notice, Defendant refused to honor Plaintiff 's rescission request in violation of TILA.

As a result of Defendants failure to comply, Plaintiff is entitled to rescission of the loan and seeks declaratory relief and damages for Defendant 's non-compliance with TILA.

INACCURATE REPORTING Defendant has inaccurately reported to the credit reporting agencies ( CRAs ) that Plaintiff was delinquent in payments related to the aforementioned loan, which has caused significant harm to Plaintiffs creditworthiness. 
Plaintiff disputed the inaccurate reporting with the CRAs, but Defendant failed to correct the errors in violation of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681.

CLAIMS FOR RELIEF COUNT 1 : VIOLATION OF THE TRUTH IN LENDING ACT ( TILA ), 15 U.S.C. 1635 Plaintiff realleges and incorporates by reference the preceding paragraphs. 
Defendant failed to provide the required disclosures under TILA regarding Plaintiffs right to rescind the loan. 
Plaintiff properly exercised the right to rescind the loan by sending a written notice within the statutory time limit. 
Defendants refusal to honor the rescission request constitutes a violation of 15 U.S.C. 1635. 
Plaintiff seeks rescission of the loan, return of all payments made under the loan, and statutory damages for the violation. 
COUNT 2 : VIOLATION OF THE FAIR CREDIT REPORTING ACT ( FCRA ), 15 U.S.C. 1681 Plaintiff realleges and incorporates by reference the preceding paragraphs. 
Defendant inaccurately reported Plaintiffs payment history to the CRAs, indicating late payments and delinquency where none existed. 
Despite Plaintiffs dispute, Defendant failed to investigate and correct the inaccuracies, in violation of 15 U.S.C. 1681i.

Plaintiff has suffered damages, including loss of creditworthiness and emotional distress, as a direct result of Defendant 's actions. 

PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment against Defendant as follows : Rescission of the loan under 15 U.S.C. 1635 ; Statutory damages under TILA and FCRA ; An order compelling Defendant to correct the inaccurate information reported to the credit reporting agencies ; Attorneys fees and costs ; Any other relief this Court deems just and proper.