Product: Credit reporting or other personal consumer reports

XX/XX/year> Consumer Financial Protection Bureau po box 27170 Washington, D.C. 20038 Subject : Formal Complaint Against XXXX and CarMax Auto Finance for Unlawful Credit Reporting, FCRA Violations, and Deceptive Practices Dear Sir/Madam, I am submitting this formal complaint against XXXX and CarMax Auto Finance for their blatant violations of the Fair Credit Reporting Act ( FCRA ), deceptive credit reporting practices, and failure to comply with federal laws regarding consumer disputes and reinvestigations. These violations have caused significant harm to my creditworthiness, and I am demanding immediate corrective action, including the permanent removal of the CarMax Auto Finance account from my XXXX credit report. XXXX. Unlawful Reporting and Verification of an Invalidated Account by CarMax Auto Finance CarMax Auto Finance has unlawfully reinserted and continues to verify an invalid account as accurate on my XXXX credit report, despite having removed the same account from both XXXX and XXXX over three months ago. This selective reporting is a direct violation of FCRA Section 623 ( b ) ( 1 ) ( D ) [ 15 U.S.C. 1681s-2 ( b ) ], which requires furnishers to update and correct all credit reporting agencies when a dispute results in modifications or deletions. CarMax Auto Finances failure to notify XXXX is an unfair, deceptive, and illegal practice. Violations by CarMax Auto Finance Include : Failure to Report Corrections to All CRAs ( FCRA Section 623 ( b ) ( 1 ) ( D ) ) CarMax Auto Finance removed this account from XXXX and XXXX but failed to update XXXX as required by federal law. This selective reporting is deceptive and results in an inaccurate and misleading credit report. Illegal Reinsertion of Previously Deleted Information ( FCRA Section 611 ( a ) ( 5 ) ( C ) ) An account that has been removed can not be reinserted unless the furnisher follows strict procedural safeguards, including written notification to the consumer within five business days. I have not received any notification, meaning this reinsertion is unlawful. Knowingly Reporting False Information ( FCRA Section 623 ( a ) ( 1 ) ( A ) ) CarMax Auto Finance knows this account is inaccurate and knows it was removed from XXXX and XXXX, yet it continues to report and verify it with XXXX. This is a willful violation of the FCRA, subjecting CarMax Auto Finance to civil liability under 15 U.S.C. 1681n. Civil Penalties for CarMax Auto Finances FCRA Violations Under the FCRA [ 15 U.S.C. 1681n & 1681o ], CarMax Auto Finance is liable for the following : Willful violations : Up to {$4100.00} per violation in statutory damages. Negligent noncompliance : Actual damages plus attorney fees. Punitive damages due to the intentional and reckless nature of their violations. I demand that CarMax Auto Finance : XXXX. Immediately cease reporting this account to XXXX and delete it from my credit report. XXXX. Provide a full explanation of why this account was removed from XXXX and XXXX but remains on XXXX. XXXX. Provide written certification that they have updated XXXX to remove the account. XXXX. Experians Sham Dispute Investigations and Unlawful Allowance of False Reporting XXXX has knowingly participated in this illegal reporting scheme by failing to properly investigate my disputes and continuing to verify an account that is demonstrably false and unverified. Violations by XXXX Include : Failure to Conduct a Proper Reinvestigation ( FCRA Section 611 ( a ) ( 1 ) ( A ) ) XXXX is blindly accepting CarMax Auto Finances false verifications without requiring any evidence, violating its duty to conduct a reasonable reinvestigation. Failure to Ensure Maximum Possible Accuracy ( FCRA Section 607 ( b ) ) By allowing CarMax Auto Finance to report an account that has already been removed from two other CRAs, XXXX is actively misrepresenting the accuracy of my credit report. Negligence in Handling Consumer Disputes XXXX has ignored multiple disputes and continues to report a false and legally invalid tradeline, damaging my credit profile. Civil Penalties for Experians FCRA Violations Each violation of the FCRA ( including improper reinvestigation, failure to notify, and failure to ensure accuracy ) is subject to : Statutory damages up to {$4100.00} per violation Actual damages for harm caused to my creditworthiness Punitive damages for reckless disregard of my rights XXXX. XXXX Pattern of MisconductCFPBs Investigation Experians actions are part of a larger pattern of illegal behavior that has already led to CFPB lawsuits for similar violations, including : Sham dispute investigations that fail to resolve consumer complaints. Illegal reinsertion of previously deleted tradelines without notice. Systemic failure to notify consumers of dispute outcomes. My case is a clear example of these unlawful practices. If XXXX does not take immediate corrective action, I will escalate this matter with legal action and additional regulatory complaints. Requested Actions Given these blatant violations, I demand : XXXX. The immediate and permanent deletion of the CarMax Auto Finance account from my XXXX credit report. XXXX. A full explanation from CarMax Auto Finance regarding why they removed this account from XXXX and XXXX but continue to report it to XXXX. XXXX. A statement of certification from XXXX confirming removal of this account and details of the reinvestigation process. XXXX. Immediate compliance with FCRA requirements to ensure accuracy across all CRAs. Failure to Comply Will Result in Further Action If XXXX and CarMax Auto Finance fail to correct these violations, I will : File lawsuits for willful and negligent violations of the FCRA. Submit formal complaints to the Federal Trade Commission ( FTC ), my state Attorney General, and consumer protection agencies. Seek statutory and punitive damages under 15 U.S.C. 1681n. Conclusion XXXX and CarMax Auto Finance have engaged in clear, willful violations of the Fair Credit Reporting Act, resulting in ongoing harm to my creditworthiness. I expect an immediate response within 15 days, as required under federal law.