Product: Debt collection

XX/XX/XXXX Consumer Financial Protection Bureau XXXX XXXX XXXX XXXX, IA XXXX Re : XXXX XXXX XXXX XXXX XXXX DOB : XXXX SSN : XXXX Re : XXXX XXXX XXXX, XXXX, Respondent C/O CKS Financial XXXX XXXX XXXX  XXXX XXXX XXXX, XXXX XXXX XXXX XXXX Account ID XXXX Re : XXXX XXXX XXXX XXXX XXXX ), Respondent XXXX XXXX XXXX XXXX XXXX GA XXXX XXXX Account No. XXXX XXXX Account No. XXXX XXXX Account No. XXXX XXXX XXXX XXXX, XXXX XXXX XXXX. XXXX XXXX XXXX, Pennsylvania. XXXX Re : XXXX XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX, Ga XXXX Re : XXXX ', XXXX XXXX XXXX. XXXX XXXX XXXX, Texas. XXXX Re : XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX, GA XXXX Complaint for a Debt Not Due Comes Now Complainant, XXXX XXXX XXXX XXXX and in support hereof presents : 1. Complaint brings this Complaint to resolve a question of controversy as to whether : A consumer credit account, enrolled in a credit protection program offered by the card issuer, with a live and active claim pursuant to the terms of which monthly minimum payments are made by the card issuer on behalf of the card holder due to XXXX, is delinquent for reporting purposes under the Fair Credit Reporting Act and the Fair Debt Collection Procedures Act. 

2. In XXXX, Complainant applied and was approved for lines of cred upon the referenced accounts issued by the XXXX  XXXX XXXX ( XXXX ). 

3. At all relevant times, XXXX offered a Credit Protection Program, pursuant to the terms of which enrollees could obtain payment relief whereby XXXX paid the monthly minimum payment due to, inter alia, XXXX. 

4. In XXXX, XXXX sold the referenced accounts to XXXX XXXX XXXX, XXXX ( XXXX ). 

5. Between XXXX XXXX, XXXX, CKS Financial ( CKS ), a debt collector and agent for CKS, furnished information that Complainant was and remains delinquent to the sum of {$1800.00} upon the referenced accounts to the following consumer reporting agencies ( XXXX ) to be included in consumer files, to wit : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX At the time of the sale, Complainant had and continues to have a live and active XXXX claim as pertains to the referenced accounts whereby XXXX is obliged to make the monthly minimum payments due upon the same. 

7. To secure my rights, privileges, and covenants thereunder, XXXX, as a matter of law, is obliged to honor the terms and conditions of Complainants cardholder agreement with XXXX, inclusive of the terms and condition of the XXXX Credit Protection Program. 

8. The foregoing considered, due to my participation in the XXXX Credit Program, and, further, upon which there is a live and pending XXXX claim which obliges XXXX and its assigns and successors to make the monthly minimum payments due upon the referenced account. 

9. Hence, the foregoing considered, as a matter of law, pursuant to the terms of the XXXX Credit Protection Program, the referenced accounts are not delinquent to the sum of {$1800.00}, or any other sum ( For want of maturity if no other reason ). Accordingly, reports of said delinquency reported to the referenced CRAs are inaccurate, false, and misleading under the terms of the FCRA and FDCPA. 

10. In resolution, Complainant asks : A. For CRA re-investigation of all issues raised in this Complaint. See : 15 U.S.C. 1681i ( a ) ( l ) ( ( A ) and 15 U.S.C. 1692g. 

B. That XXXX honor the terms and conditions of the XXXX Credit Protection Program as obliged when it purchased the referenced accounts. 

C. That XXXX and or CKS remove or cause to be removed from Complainants consumer files with the referenced CRAs the derogatory report of Complainants delinquency to XXXX to the sum of {$1800.00}. 


Cordially, _________________________ XXXX XXXX XXXX