Product: Credit reporting, credit repair services, or other personal consumer reports

COMPLAINT HEREIN IS GIVEN BY XXXX XXXX XXXX/STUDENT LOAN BORROWER ( HEREINAFTER, BORROWER ) UNDER OATH/PENALTY OF PERJURY AGAINST XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX ) XXXX XXXX XXXX , XXXX PRESIDENT AND CHIEF EXECUTIVE OFFICER ( CEO ), ET AL. ( HEREINAFTER, XXXX ), EXPRESS ADMITTED AGENT ( S ) OF DEPARTMENT OF EDUCATION AND UNITED STATES SECRETARY OF EDUCATION,  XXXX XXXX XXXX, FOR KNOWING AND WILLFUL REPEATED STUDENT LOAN REPAYMENT FALSE REPRESENTATIONS TO U.S. GOVERNMENT RECORDS ( NATIONAL STUDENT LOAN DATA SYSTEM, NSLDS ) AND TO XXXX, XXXX, EXPERIAN, ( HEREINAFTER, CREDIT REPORTING AGENCIES, CRAS ) BORROWERS CREDIT REPORTS TO GAIN MORE THAN {$100000.00} STUDENT LOAN PAYMENT NOT OWED. 

XXXX EXPRESS ADMISSIONS RE XXXX XXXX XXXX GROUPED-SEVEN-LOAN ACCOUNT. 

Under Standard Loan Repayment Plan ( 120 fixed equal monthly payments to paid-in-full ), from XX/XX/XXXX through and including XX/XX/XXXX, borrower made 99/120 timely, monthly, as billed/equal payments of {$1000.00}, total repaid to date about {$100000.00}, total six-loans-grouped-account current outstanding, about {$17000.00}, ( EXHIBIT 1., EXHIBIT 2., and EXHIBIT 4. pages 2-3. ). A seventh loan, listed by XXXX in NSLDS, was never disbursed to borrower, balance : XXXX. 

COMPLAINT : XXXX ONGOING PATTERN-OF-PRACTICE SCHEME TO COLLECT APPROXIMATELY DOUBLE PAYMENT AMOUNT OWED. 

XXXX actions complained herein occurred from about XX/XX/XXXX-Present-XX/XX/XXXX ongoing. 

XXXX  pattern-of-practice scheme of false repayment representations began after borrower, account in good standing, had completed about 70/120 payments ( XXXX, EXHIBIT 5. ) and 99/120 payments ( XXXX, EXHIBIT 6. and EXHIBIT 7. ). XXXX false representations, left unchallenged, increase borrowers XXXX outstanding debt by about {$100000.00}, and in XXXX, {$120000.00} ( debt not owed ) ; and increase by 8-10 years borrowers repayment term ( EXHIBIT 5. Terms [ each of six loans ] : 132 Months-147 Months ), i.e. an increase from 120 months/10 years ( Standard Loan Repayment Plan ) to 18-20 years repayment total. 

THE TWO ISSUES OF HEREIN COMPLAINT ARE : I. XXXX FALSE REPRESENTATION ( S ) REPAYMENT RECORDS, EXPRESS DEMAND FOR BORROWER TO REPAY DEBT NOT OWED. 
TIMELINE XXXX WILLFUL AND KNOWING FALSE REPAYMENT REPRESENTATIONS THROUGH PRESENT-XX/XX/XXXX. 

1. XXXX  billing not fixed not equal monthly payments, unquestionable breach of Standard Loan Repayment ( 120 months fixed equal payments to paid in full, EXHIBIT 4. Page 3 ). 
XXXX billed {$150.00} outstanding interest, paid by borrower XXXX XX/XX/XXXX, check number XXXX. 
Loans entered repayment XXXX XX/XX/XXXX : XXXX billed {$1200.00} monthly payment grouped-six-loans account paid by borrower XXXX XX/XX/XXXX, check number XXXX. 
XXXX billed {$1000.00} monthly payment, paid by borrower on XXXX XX/XX/XXXX, check number XXXX. 
XXXX billed {$0.00} due XX/XX/XXXX. 
XXXX billed {$690.00} monthly payment, paid by borrower on XXXX XX/XX/XXXX, check number XXXX. 
XXXX monthly billed {$1000.00} ( EXHIBIT 4. XXXX  letter page 3 ), XX/XX/XXXX through and including XX/XX/XXXX. Payment allocations to each of six loans ( EXHIBIT 4. XXXX Letter, page 3,  Table ) are reflected in EXHIBIT 1. from XX/XX/XXXX through and including XX/XX/XXXX. 
2. XXXX knowing and willful payments misallocation ( EXHIBIT 1. ). XXXX, thereby, engineers fictitious underpayment representation ( s ). 
XXXX knowingly and willfully misallocated borrowers monthly payment of {$1000.00} among the six loans in repayment so that loans were simultaneously overpaid- and remaining loans were underpaid ; then the next month XXXX alternating the loans to make prior overpaid loans underpaid and prior underpaid loans overpaid, repeating for XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX ( EXHIBIT 1. ). The net result was that despite borrowers timely {$1000.00} monthly payments all five said months, most/if not all six individual loans falsely represented underpayment one or more times during these five months misallocations time period. 
3. XXXX ( EXHIBIT 5. Experian, CRAs example ) falsely represents to CRAss borrowers credit reports : Terms extension from 50/120 monthly payments remaining to 132-147 monthly payments outstanding ; Status Deferred, payments begin XX/XX/XXXX ( contradicted by EXHIBIT 1. XXXX account review showing 70/120 Standard Loan Repayment payments made timely, as billed/equal payments of $ XXXX/month ) ; and Comment : Account in Forbearance. ( No Forbearance requested or consented to by borrower, per se unlawful. ) 4. XXXX  knowing and willful monthly billing underpayment amounts in clear violation of Standard Repayment Plan ( $  XXXX/month, EXHIBIT 4., page 3 ), absent legally required express notification to borrower. 
XXXX XXXX XXXX {$900.00} billed/ {$1000.00} paid ; XXXX XXXX XXXX {$980.00} billed/ {$1000.00} paid ; XXXX XXXX XXXX {$1000.00} billed/ {$1000.00} paid ; XXXX XXXX XXXX {$1000.00} billed// {$1000.00} paid ; ( EXHIBIT 2.  ). 
XX/XX/XXXX-Present-XX/XX/XXXX billed {$1000.00}, borrower paid {$1000.00} every month ( EXHIBIT 2. ). ( EXHIBIT 4. XXXX  letter, page 3, Standard Loan Repayment is $ XXXX/month/120 months to paid-in-full ) 5. XXXX knowingly and willingly falsely represents to NSLDS ( EXHIBIT 6. ) on or shortly after XXXX XX/XX/XXXX : Borrowers six loans entered repayment XX/XX/XXXX. Yet, XXXX ADMITS loans entered repayment XXXX XX/XX/XXXX, EXHIBIT 1.,  EXHIBIT 2. and EXHIBIT 4. ) borrowers account shows 99/120 payments from XX/XX/XXXX through and including XXXX XX/XX/XXXX. 
Borrowers six loans are Repayment Progress 82 % -94 %, yet inexplicably in NSLDS XXXX falsely represents borrower XXXX XX/XX/XXXX has {$120000.00} Amount Remaining, after borrower made 99/120 monthly payments, total repayment of about {$100000.00} through and including XX/XX/XXXX ( EXHIBIT 1. and EXHIBIT 2. ). Further, XXXX ADMITS ( EXHIBIT 2., page 1 ) borrowers outstanding debt, after XXXX XX/XX/XXXX payment is credited, is about {$17000.00} ( EXHIBIT 2., page 1 ). 
6. XXXX knowingly and willingly falsely represents to CRAs borrowers credit reports ( EXHIBIT 7.  XXXX, example ) XXXX XX/XX/XXXX : High Balance of six loans original unpaid amount from XX/XX/XXXX to XX/XX/XXXX for each of borrowers six student loans, thereby, XXXX denies borrowers 99/120 months loans repayment through XX/XX/XXXX. Yet, XXXX ADMITS 99/120 payments completed EXHIBIT 1. and EXHIBIT 2. 
Terms paid monthly for 120 months for each of borrowers six student loans, thereby, XXXX denies borrowers 99/120 months loans repayment through XX/XX/XXXX. Yet, XXXX ADMITS 99/120 payments completed EXHIBIT 1. and EXHIBIT 2., and only about 17/120 months, $ XXXX/month repayment outstanding. 
In summary, XXXX represents in monthly billing to borrower ( EXHIBIT 1. and EXHIBIT 2. ) good standing loans repayment ; while XXXX knowingly and willingly simultaneously falsely represents to U.S. government database, NSLDS ( EXHIBIT 6. ), and to CRAs borrowers credit reports ( EXHIBIT 5. Experian, example. and EXHIBIT 7. XXXX, example. ) borrowers alleged nonpayment/underpayment. 

XXXX. XXXX ARBITRARY UNILATERAL PER SE UNLAWFUL FORBEARANCES AND -DEFERMENT TO OBFUSCATE XXXX FALSE REPAYMENT REPRESENTATIONS, TWO OF FOUR FORBEARANCES APPLIED TO BORROWERS ACCOUNT RETROACTIVELY. 

Second, to obfuscate XXXX willful and knowing false repayment representations ( Issue I. ), XXXX unilaterally imposed numerous Forbearances ( two, in the last three weeks, XXXX XXXX XXXX XX/XX/XXXX on borrowers grouped-six-loan-account, EXHIBIT 3. ). A  legal definition of Forbearance is given 34 C.F.R. 682.211 ( a ) ( 1 ) : Forbearance means permitting the temporary cessation of payments, allowing an extension of time for making payments, or temporarily accepting smaller payments than previously were scheduled. Thereby, per se unlawful ( imposed absent borrowers request or consent ) Forbearance ( s ), XXXX willfully and knowingly represents false borrowers default or nonpayment or underpayment when neither default nor untimely, nor nonpayment, nor underpayment exists. ( EXHIBIT 1 and EXHIBIT 2,  XXXX ADMITTED XX/XX/XXXX through XX/XX/XXXX, 99/120 timely, monthly, equal-/as billed payments of {$1000.00}, total to date about {$100000.00} repaid, total six-loans-grouped-account current outstanding, about {$17000.00}, Standard Loan Repayment-120 fixed equal monthly payments to paid-in-full ). 

XXXX FORBEARANCES AND DEFERMENT ARE PER SE UNLAWFUL AND MUST BE EXPUNGED. 

To lawfully place a Forbearance on borrowers account XXXX must : ( i ) 34 C.F.R. 682.211 ( b ) ( 1 ) prior have the borrowers consent ( oral and/or written ) ; ( ii ) 34 C.F.R. 682.211 ( a ) ( 1 ) borrowers account is in default, or nonpayment, or delinquent ; ( iii ) 34 C.F.R. 682.211 ( e ) ( 1 ) when Forbearance is granted and placed on borrowers account XXXX must expressly specify the terms of the Forbearance to borrower ; ( iv ) 34 C.F.R. 682.211 ( e ) ( 2 ) ( vi ) at any time upon  borrowers request XXXX must cancel Forbearance. 

To lawfully place a Deferment on borrowers account XXXX must : ( i ) 34 C.F.R. 685.204 ( a ) ( 4 ) ( i ) the borrower must request the deferment andprovide the Secretary with all information and documents required to establish eligibility for the deferment. 
( i ) 34 C.F.R. 685.204 ( a ) ( 5 ) ( iii ) If the Secretary grants a deferment, the Secretary notifies the borrower  that the deferment has been granted and that the borrower has the option to cancel the deferment and continue to make payments on the loan. 
None of said four requirements for Forbearance ( 34 C.F.R. 682.211 Forbearance. ) or two requirements for Deferment ( 34 C.F.R. 685.204. Deferment. ) exist from XXXX XXXX XXXXPresent ( XX/XX/XXXX ) for borrowers group-six-loan-account serviced by XXXX ( EXHIBIT 3. Table 1. List of Forbearances and Deferment since  XXXX XX/XX/XXXX ). Further, borrower finds no provision in 34 C.F.R. 682.211 or borrowers Master Promissory Notes ( MPNs ) contract for XXXX lawfully to retroactively ( XXXX XX/XX/XXXX express notice ) unilaterally to apply Forbearance ( effective XXXX XX/XX/XXXX ) to nonconsenting borrowers account in good standing during which XXXXetroactive-Forbearance three monthly payments ( $ XXXX XXXX, $ XXXX XXXX, $ XXXX XXXX, EXHIBIT 2 ) have already been billed by XXXX and timely paid by borrower ( EXHIBIT 2. pages 1-6 ) to XXXX. XXXX never provided legally required, 34 C.F.R. 685.204 ( a ) ( 5 ) ( iii ), notice retroactive Deferment ( EXHIBIT 5. ) existed  to borrower, borrower being monthly billed by XXXX and paying uninterrupted {$1000.00} monthly ( EXHIBIT 1. ) throughout said fictitious CRAs borrowers credit reports published Deferment, ending XX/XX/XXXX ( EXHIBIT 5. Experian, CRAs example, XXXX XX/XX/XXXX, Status. ). 

XXXX PER SE UNLAWFUL FORBEARANCES AND DEFERMENT XXXX FOLLOW BORROWERS COMPLAINTS OF XXXX FALSE REPAYMENT REPRESENTATIONS ( EXHIBIT 3. Table 1. Forbearances and Deferment List. ). 

See, Consumer Financial Protection Bureau, CFPB, complaints : XXXX, submitted XX/XX/XXXX ; XXXX, submitted XX/XX/XXXX ; XXXX, submitted XX/XX/XXXX. ) Said XXXX CFPB complaints reflect replicated intentional fraud as herein XXXX complaint fraud-/extortionate process. ( EXHIBIT 7. Last page, borrowers 100-word dispute statement in XXXX. ) XXXX via per se unlawful Forbearances and Deferment scheme, herein described, willfully and knowingly and repeatedly ( XXXX ) represents false borrower nonpayment/underpayment/default and by said fictitious unpaid-debt reports repeatedly attempts to justify unjustifiable false representations to obtainapproximately double repayment amount ( EXHIBIT 5., EXHIBIT 6., and EXHIBIT 7. ), from borrower, in clear violation of Master Promissory Note ( s ) contract ( s ). Said XXXX express allegation ( s ) of nonpayment/underpayment/default by insertion of about four per se unlawful Forbearances and one per se unlawful Deferment in less than three years in NSDLS and CRAs borrowers credit reports clearly will be deemed libel per se to extort from borrower more than double repayment owed. 

All four Forbearances XXXX placed on borrowers account from XXXX XXXX and Deferment XXXX   through Experian reported XXXX XX/XX/XXXX are per se unlawful and must be expunged, failing compliance with 34 C.F.R. 682.211 and 34 C.F.R. 685.204. prerequisites/requirements and borrowers MPNs, latter, unambiguous breach of contract by XXXX XXXX 

BORROWERS STATEMENT. 

Borrower/XXXX  XXXX XXXX reiterates under penalty of perjury that after borrowers student loans serviced by XXXX entered repayment on XXXX XX/XX/XXXX : ( i ) Borrower never requested- nor by any means ( oral or written ) assented to any Forbearance or Deferment ; ( ii ) Borrower never deviated from-, or modified-, or assented to any modification from Standard Loan Repayment ( 120 equal monthly payments, $ XXXX/month, to paid-in-full, now through XX/XX/XXXX, 99/120 payments completed, about {$100000.00} paid, as of XX/XX/XXXX, borrower owes about {$17000.00} total to paid-in-full for six ( a seventh loan was never disbursed/canceled, {$0.00} owed ) loans grouped account ( EXHIBIT 1 and EXHIBIT 2 ) ; ( iii ) In EXHIBIT 1., EXHIBIT 2. compare payments amount ( $ 1077.97/month ) and dates paid with XXXX Deferment and XXXX Forbearances dates listed in EXHIBIT 3. Borrower made every monthly payment ( grouped-, six loans account ) uninterrupted, timely, as billed/equal payment, and continued uninterrupted equal $ XXXX/month payment timely every month throughout all XXXX  per se unlawful Forbearances ( XXXX about four Forbearances in less than 3 years, and, throughout the CRAs borrowers credit reports fictitious Deferment ( EXHIBIT 5. Experian, example, dated XXXX XX/XX/XXXX, showing unlawful pop-up/absent borrowers request or consent, and, absent Deferment terms and conditions notice to borrower ) ; ( iv ) Every monthly payment was made by paper check, bank records verification showing date and amount paid/withdrawn ( EXHIBIT 2., last three pages, examples ), and check, sent via US mail XXXX receipt signature-required ( proves timely receipt by XXXX ) ; and ( v ) Borrower retains original executed copies of Master Promissory Notes ( MPNs ) for student loans serviced by XXXX . 

BORROWERS PRIOR NOTICE TO XXXX AND SECOND UNLAWFUL NONCONSENSUAL FORBEARANCE UNILATERALLY BY XXXX XXXX XX/XX/XXXX. 

Borrower orally/by phone : XXXX, provided notice and request for correction to XXXX of herein false student loans repayment representations in NSLDS and CRAs borrowers credit reports and nonreceipt of US mail XX/XX/XXXX billing for monthly payment due XX/XX/XXXX : XXXX XX/XX/XXXX about XXXX XXXX  XXXX employee ID, XXXX ; XXXX XX/XX/XXXX about XXXX XXXX  XXXX, ID, XXXX, transferred about XXXX to XXXX , ID, XXXX ; XXXX XX/XX/XXXX about XXXX XXXX  XXXX , ID, XXXX ; XXXX XX/XX/XXXX about XXXX XXXX  XXXX , ID XXXX ; XXXX XX/XX/XXXX about XXXX XXXX  XXXX , ID, XXXX. On XXXX XX/XX/XXXX, after borrower reported said fraudulent repayment reporting and XXXX XXXX XXXX XX/XX/XXXX unlawful Forbearance, XXXX stated XXXX XX/XX/XXXX that as a result of borrowers phone call borrowers grouped XXXX account would undergo Administrative Review purportedly resulting in a second Administrative Forbearance, now, two fraudulent Forbearances ( XXXX XX/XX/XXXX and XXXX XX/XX/XXXX ) unilaterally XXXX imposed on borrowers grouped-six-loans-account in the past three ( 3 ) weeks. XXXX received neither request nor consent from borrower to impose said Forbearance, no notice of terms and conditions of said Forbearance has been received by borrower to date-26 XX/XX/XXXX. On XXXX XX/XX/XXXX about XXXX XXXX XXXX, ID XXXX stated in error XXXX XX/XX/XXXX retroactive Forbearance had been expunged from NSLDS on XXXX XX/XX/XXXX ; denied knowledge of false XXXX XX/XX/XXXX repayment start date in NSLDS and also, denied knowledge of outstanding [ six-loans ] balance of {$120000.00}. Borrower reiterated that said false representations were extortionate and borrower would file formal complaint unless all was corrected within next 24 hours ( borrower having provided prior notice from XXXX XX/XX/XXXX to no avail ). 

XXXX KNOWING AND WILLFUL HARM TO BORROWER FOLLOWING BORROWERS COMPLAINTS RE XXXX PER SE UNLAWFUL ONGOING ACTS. 

As licensed attorney, borrowers professional license is predicated on financial responsibility mandated by ethics rules and state law ( Mass. Gen. Laws Ann. Ch. XXXX ). Here, XXXX knowing that said outstanding debt express representation of about {$120000.00} was false ( EXHIBIT 1. and EXHIBIT 2. ), willingly repeatedly ( XXXX ) falsely represented to the US government National Student Loan Data System, NSLDS, and  CRAs, for publication as fact that borrower owes ( EXHIBIT 5., EXHIBIT 6., EXHIBIT 7. ) over {$100000.00} and via numerous unlawful Forbearances and -Deferment false representations ( XXXX ) borrower ( a licensed attorney ) delayed/defaulted/underpaid six student loans repayment ( EXHIBIT 3. ). 

XXXX said knowing and willful false representations of {$120000.00} borrowers outstanding debt XXXX ( EXHIBIT 6. ) : ( i ) directly caused material harm to borrowers ability to obtain credit upon rational terms ; ( ii ) expressly placed borrowers professional ethics, re financial responsibility in question in official government records and CRAs credit reports used by financial institutions and prospective employers ; thereby ( iii ) XXXX knowingly and willingly actually putting borrowers professional license, in jeopardy ; and ( iv ) literally taking-by-fraud unpaid months of borrowers professional effort ( from profitable endeavor ) to challenge XXXX XXXX repeated per se libel for monetary per se extortion of about double repayment owed by MPNs contract ( s ). Borrower respectfully asserts XXXX knowing and repeated false representations published ( willfully disclosed to third parties ) in government records and credit reports meet the definition of libel for per se extortion. 28 U.S.C. 4101 ( 1 ) states : In this chapter : ( 1 ) Defamation. 
The term defamation means any action or other proceeding for defamation, libel [ written ], slander, or similar claim alleging that forms of speech are false, have caused damage to reputation or emotional distress, have presented any person in a false light, or have resulted in criticism, dishonor, or condemnation of any person. 
( https : XXXX, last viewed XXXX XX/XX/XXXX. ) 18 U.S.C. 872. Extortion by officers or employees of the United States. 
Whoever, being an officer, or employee of the United States or any department or agency thereof, or representing himself to be or assuming to act as such, under color or pretense of office or employment commits or attempts an act of extortion, shall be fined under this title or imprisoned not more than three years, or both ; but if the amount so extorted or demanded does not exceed {$1000.00}, he shall be fined under this title or imprisoned not more than one year, or both. 
( https : XXXX, last viewed XXXX XX/XX/XXXX ) To argue XXXX repeated false representations to collect double monetary repayment were good faith mistakes ( EXHIBIT 1. and EXHIBIT 2. XXXX ADMISSION of borrowers good standing repayment ) lacks modicum of rational credibility. 

REMEDY REQUESTED. 

In accordance with both federal and state law, XXXX XXXX XXXXstudent loan borrower respectfully requests that XXXX be required : ( i ) to permanently expunge extortionate/false current {$120000.00} outstanding debt, reported on or after XX/XX/XXXX-Present-XX/XX/XXXX to NSLDS, CRAs credit reports, and all other records of XXXX XXXXborrowers XXXX student loan account ; ( ii ) to permanently expunge all per se unlawful Forbearances and Deferment ( s ) dating from XX/XX/XXXX-Present-XX/XX/XXXX from borrowers NSLDS account, CRAs credit reports, and all other student loan repayment records that may exist for XXXX XXXX XXXX ; ( iii ) Per the Coronavirus Aid, Relief, and Economic Security Act ( H.R. 748 ), CARES Act 3513,  signed into law XXXX XX/XX/XXXX, XXXX credits 100 % borrowers payments XXXX XX/XX/XXXX through and including XXXX XX/XX/XXXX to payment of principal in accordance with Department of Education guidance : During the period of 0 % interest ( XX/XX/XXXX, through XXXX XXXX, XXXX ), the full amount of your payments will be applied to principal once all the interest that accrued prior to XX/XX/XXXX is paid ( https : //studentaid.gov/announcements-events/coronavirus, last viewed XXXX XX/XX/XXXX ) ; ( iv ) In accordance with federal and state law, XXXX make all monthly repayment representations accurately/factually/timely in NSLDS and in CRAs borrowers credit reports and all other student loan repayment records that may exist for borrower/XXXX  XXXX XXXX, specifically including correction of every monthly repayment misallocation ( XX/XX/XXXX-XX/XX/XXXX, and XX/XX/XXXX through XX/XX/XXXX, EXHIBIT 1. ) resulting in under- or overpayment of borrowers six loans in repayment ( EXHIBIT 4. XXXX Letter, Table, page 3, shows amount of fixed equal {$1000.00} monthly payment apportioned to each of six loans ) ; ( v ) Only one, the valid repayment start date, XXXX XX/XX/XXXX, be shown in NSLDS and CRAs borrowers credit reports and all other false representations of more recent repayment start date ( s ) be permanently expunged in NSLDS and CRAs debtors credit reports and any other existing repayment records for borrower ; ( vi ) Per XXXX Standard Loan Repayment express XXXX agreement ( EXHIBIT 4. XXXX letter. ) XXXX bills borrower timely ( lawfully, 20 days ahead of each payment due date, XXXX day of each month ) by U.S. mail for $ XXXX/month grouped-six-loans-account until paid-in-full. XXXX ADMITS borrowers grouped six-loans-account outstanding is about {$17000.00} ( approximately 17 months ) repayment remaining ( EXHIBIT 2. page 1, also including payment of  {$1000.00} XXXX received XXXX XX/XX/XXXX, page 4. ).

( vii ) If these reasonable and lawful remedies, permanently to expunge all false/inaccurate, per se unlawful student loan repayment and credit report ( s ) representations, are not completed with express proof of all corrections completion provided XXXX XXXXborrower within 15 calendar days of herein CFPB Complaint, borrower will initiate formal state and federal proceedings against all parties involved in said per se libel-for-extortion scheme to include, but be not limited to : XXXX XXXX XXXX XXXX XXXX   XXXX XXXX XXXX, XXXX President and Chief Executive Officer, CEO,  et al. ; Department of Education ; Department of Education Secretary, XXXX XXXX XXXX ; Experian, XXXX, XXXX  and others propagating said false representations. Allegations will include but not be limited to : U.S. mail fraud ( 18 U.S.C.1341 ), U.S. wire fraud ( 18 U.S.C.1343 ) ; violation of False Statements Accountability Act ( 18 U.S.C. 1001 ) ; Racketeer Influenced and Corrupt Organizations/RICO ( 18 U.S.C. 1961-1968 ) ; and violations of : MD Code Com Law 3 & 4 ; Electronic Funds Transfer Act ( 15 U.S.C. 1693-1693r, implemented through Regulation E, 12 CFR Part 1005 ) ; Fair Credit Reporting Act ( 15 U.S.C. 1681 et seq., implemented through Regulation V, 12 CFR 1022 ) ; Consumer Financial Protection Act of 2010 ( 12 U.S.C. 5511 et seq. ) ; Gramm-Leach-Bliley Act, Pub. L. No. 106-102, 113 Stat. 1338, codified in relevant part primarily at 15 U.S.C. 6801-6809 [ Regulation P, privacy violations ], 6821-6827, prohibiting obtaining customer  information of a financial institution by false pretenses ; 28 U.S.C. 4101 ( 1 ) ; 18 U.S.C. 872 ; 18 U.S.C. 242 ; and 42 U.S.C. 1983.

Borrower will through litigation by a law firm experienced in libel re student loan repayment representation ( s ) and student loan servicer repayment reporting fraud to gain money not due or owing, request all court costs, all attorneys fees, treble damages plus such punitive damages the Consumer Financial Protection Bureau, Federal Trade Commission and/or court shall deem  appropriate for XXXX pattern-of-practice scheme per se to extort about {$120000.00}, thereby knowingly and willfully causing foreseeable material harm to borrowers finances, credit, professional reputation as licensed attorney, and professional time unpaid spent to challenge XXXX repeated per se unlawful/extortionate acts. 

LIST OF SEVEN ( 7 ) EXHIBITS ATTACHED AS .pdf. 

EXHIBIT 1. XXXX Account Review, dated XXXX XX/XX/XXXX, for Borrowers Grouped-Six-Loans Account. Borrowers repayment history for six loans in repayment from repayment start date, XXXX XX/XX/XXXX, uninterrupted timely repayment to XX/XX/XXXX. [ Thirty ( 30 ) pages. ] EXHIBIT 2. XXXX Monthly Billing Showing Borrowers Account Status from XX/XX/XXXX through and including XX/XX/XXXX Payment-XXXX  XXXX Bill, Includes Three ( 3 ) Bank Statements,XX/XX/XXXXXX/XX/XXXX ( last 3 pages, one example time period when XXXX misallocated payments among six loans ). XXXX expressly ADMITS in every monthly billing statement, XX/XX/XXXX-XX/XX/XXXX timely, full-amount-due ( $ XXXX/month six loans grouped account payment ), repayment receipt : Total paid since your last statement {$1000.00}, i.e. amount paid the month prior to month date billed. ( See, lower left box of each billing statement XX/XX/XXXX through XX/XX/XXXX ). [ Thirty ( 30 ) pages. ] EXHIBIT 3.  TABLE 1. Summarizes XXXX Per Se Unlawful Forbearances and One Deferment ( EXHIBIT 5. ) From XXXX 2020-Present. XXXX EXPRESSLY ADMITS in EXHIBIT 1. and EXHIBIT 2. borrower paid uninterrupted XXXX XXXX/month, timely, throughout all four said per se unlawful Forbearances and per se unlawful Deferment. 

EXHIBIT 4. XXXX Letterhead Letter Dated XXXX XX/XX/XXXX. XXXX responds to borrowers repeated requests ( XX/XX/XXXX-XX/XX/XXXX ) for XXXX to bill borrower via Standard Loan Repayment, i.e. equal, fixed, payments 120 months to paid-in-full using US mail billing. XXXX affirms XXXX XXXX XXXX XXXX XXXX XXXXmonth with tabular distribution ( page 3 ) shown among six-loans in borrowers grouped-account. Further, XXXX explains different amounts/month billed borrower XX/XX/XXXX-XX/XX/XXXX, which bills borrower paid timely as billed. 
[ Four ( 4 ) pages. ] EXHIBIT 5. Borrowers Experian XXXX CRAS, Example ) Credit Report Dated XXXX XX/XX/XXXX. Experian report showing XXXX : ( i ) false representation of six loans repayment term ( s ), here 132-147 months from XXXX XX/XX/XXXX, payment extension of 8-10 years, to total of 18-20 years repayment, after borrower already paid about 70/120 months to paid-in-full ; ( ii ) Forbearance [ in effect ], per se unlawful, neither requested nor assented to by borrower ; ( iii ) Deferment [ in effect ], per se unlawful, absent legal notice required by law, and neither requested- nor assented by borrower. Thereby, said repayment term false representation XXXX reports to NSLDS and CRAs both : ( a ) about eight ( 8 ) years  of nonpayment ( directly contradicted by EXHIBIT 1. and EXHIBIT 2. XXXX express good standing borrowers account admissions ) ; and ( b ) falsely represents borrower has substantive, over {$100000.00}, outstanding debt ( directly contradicted by EXHIBIT 2.,  page 1. XXXX  admission Current Balance,  {$17000.00} after XXXX XXXX payment {$1000.00} credited ). [ Five ( 5 ) pages. ] EXHIBIT 6. NSLDS Borrowers XXXX  Six-loans- [ grouped-account ] Report ( s ), on  XXXX XX/XX/XXXX. As shown in EXHIBIT 5, XXXX in NSLDS falsely represents said grouped-six-loans-account repayment start date of XXXX XX/XX/XXXX. Contrast EXHIBIT 1 and EXHIBIT 4, XXXX ADMITTED repayment start date of XXXX XX/XX/XXXX. Please note EXHIBIT 6. NSLDS, Repayment Details for each of six loans. While each loan shows between 82 % -94 % repaid, the Amount Remaining for each of the six loans is greater than the amount paid off ; summed, the six loans Amount Remaining is {$120000.00}. Contrast XXXX express ADMITTED amount remaining in EXHIBIT 2, XX/XX/XXXX bill, about {$17000.00} outstanding after borrowers XX/XX/XXXX payment {$1000.00} is credited. XXXX unquestionably repeated ( EXHIBIT 5. 2017 ) willful and knowing per se extortion of over {$100000.00} not owed XXXX. [ Six ( 6 ) pages. ] EXHIBIT 7. Borrowers XXXX Credit Report ( CRAS, Example ) Dated XXXX XX/XX/XXXX. XXXX High Balance line item report for each of borrowers six loans gives the unpaid original balance of each loan as equal the high balance from XX/XX/XXXX to XX/XX/XXXX. Thereby, in said CRAs borrowers credit reports XXXX expressly denies borrower made continuous monthly payments from XXXX XX/XX/XXXX through XXXX XX/XX/XXXX of about {$100000.00} ( total six-loans-grouped-account current outstanding, about {$17000.00}, ( XXXX ADMITS in EXHIBIT 2. page 1 ). Borrowers prior ( XXXX ) 100-word dispute statement is included at the bottom of the last page.