Product: Credit reporting or other personal consumer reports

Consumer Financial Protection Bureau ( CFPB ) Complaint Filed by : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, NY XXXX Date : [ Insert Date ] To : Consumer Financial Protection Bureau ( CFPB ) XXXX XXXX XXXX Washington, D.C. XXXX Subject : Formal Complaint for FCRA Violations Unlawful Reinsertion, Failure to Provide Notice, and Reporting of Fraudulent Accounts Dear CFPB Representative, I am filing this formal complaint against the U.S. Department of Education ( DOE ), Experian, Equifax, and TransUnion for multiple violations of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., including : XXXX. Unlawful reinsertion of previously deleted accounts without proper notice ( FCRA 1681i ( a ) ( 5 ) ( B ) ). 
XXXX. Failure to properly investigate and remove fraudulent accounts ( FCRA 1681s-2 ( b ) ). 
XXXX. Failure to notify all credit bureaus of investigation results ( FCRA 1681s-2 ( a ) ( XXXX ) ). 
XXXX. Inconsistent and deceptive reporting of XXXX XXXX XXXX XXXX and Discover Bank accounts ( FCRA 1681e ( b ) ). 

These violations have caused severe damage to my credit profile, financial opportunities, and overall creditworthiness. The U.S. Department of Education, acting as a furnisher, and the consumer reporting agencies ( CRAs ) have engaged in unlawful and deceptive practices that must be addressed immediately. 

XXXX. Unlawful Reinsertion of Previously Deleted Accounts ( FCRA 1681i ( a ) ( 5 ) ( B ) ) The U.S. Department of Education illegally reinserted the following accounts into my credit reports : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Under FCRA 1681i ( a ) ( 5 ) ( B ), a credit reporting agency ( CRA ) can not reinsert a previously deleted item unless : XXXX. The furnisher certifies the accuracy of the information at the time of reinsertion. 
XXXX. The CRA notifies the consumer within five business days of the reinsertion.

Violation : I never received any written notice from Experian, Equifax, or TransUnion regarding these reinserted accounts, making this a clear and direct violation of FCRA 1681i ( a ) ( 5 ) ( B ). 

Legal Impact : Since the Department of Education and CRAs failed to follow proper reinsertion procedures, these accounts must be immediately and permanently deleted from my credit reports. 

XXXX. Failure to Properly Investigate and Remove Fraudulent Accounts ( FCRA 1681s-2 ( b ) ) In addition to the illegal reinsertion, XXXX XXXX XXXX XXXX and XXXXXXXX XXXX accounts are still being reported inaccurately, despite clear evidence that these accounts are fraudulent and unauthorized. 

XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ) This account was removed from Equifax but remains verified on TransUnion and Experian, which is inconsistent and a direct violation of FCRA 1681s-2 ( b ). 
If Equifax removed the account due to errors, then TransUnion and Experian must remove it as well, or the furnisher must provide documentation proving its validity. 

XXXXXXXX XXXX XXXX XXXX XXXX XXXXXXXX ) This account is unauthorized and fraudulent. 
Despite my dispute, XXXX failed to provide proof of authorization, a signed contract, or validation of the debt. 

Legal Violation : Under FCRA 1681s-2 ( b ), when a consumer disputes an account, the furnisher must conduct a proper reinvestigation and : XXXX. Provide verification that the account belongs to the consumer and is accurately reported. 
XXXX. Notify all other credit bureaus of the investigation results and correct the record across all reporting agencies. 
XXXX. If an account is found to be inaccurate, unverifiable, or incomplete, it must be modified or permanently deleted. 

Failure to Notify All Credit Bureaus ( FCRA 1681s-2 ( a ) ( 3 ) ) XXXX XXXX XXXX XXXX XXXX XXXX XXXX failed to notify all three credit bureaus of the investigation results. 
If Equifax removed XXXX XXXX XXXX XXXX, then Experian and TransUnion were legally required to update their records. 
Since they did not, they are in violation of FCRA 1681s-2 ( a ) ( 3 ), which mandates furnishers to correct errors with all credit bureaus. 

XXXX. Inconsistent and Deceptive Reporting Violations of FCRA 1681e ( b ) The CRAs and furnishers are also violating FCRA 1681e ( b ) by failing to ensure maximum accuracy and consistency in reporting. 
XXXX XXXX XXXX XXXX being removed from Equifax but still appearing on Experian and TransUnion is a textbook example of inaccurate and deceptive credit reporting. 
If a furnisher finds an account to be inaccurate with XXXX bureau, they are legally required to update it with all three bureaus. 
By failing to do so, they are knowingly allowing false information to harm my credit profile. 

Legal Impact : Since XXXX XXXX XXXX XXXX and XXXX XXXX accounts were not properly verified across all CRAs, all three agencies must delete these accounts immediately. 



XXXX. Legal Consequences & Damages Sought Under FCRA 1681n ( for willful violations ) and FCRA 1681o ( for negligent violations ), the responsible parties are subject to : Statutory damages of {$1000.00} per violation. 
Actual damages for financial harm caused by inaccurate credit reporting. 
Punitive damages for reckless disregard of consumer rights. 
Full reimbursement of legal fees and court costs. 

Since these violations are repeated and deliberate, I am seeking full statutory damages exceeding {$50000.00} in addition to punitive damages for willful misconduct. 

Actions & Resolution Demand To resolve this matter without litigation, I demand the following within 10 business days : XXXX. Permanent removal of all four U.S. Department of Education accounts from my credit reports. 
XXXX. Immediate deletion of the XXXX XXXX XXXX XXXX and XXXX XXXX accounts across ALL THREE credit bureaus. 
XXXX. Full disclosure of investigation records from Experian, Equifax, and TransUnion, including : How these accounts were verified. 
Who at the Department of Education, XXXX XXXX, and XXXX provided certification of accuracy. 
Proof that the required notices were sent to me regarding reinsertion. 

Failure to comply within 10 days will result in legal escalation, including : Formal complaints with the FTC and my XXXX Attorney General. 
A lawsuit against the Department of Education, XXXX XXXX, XXXX, and all three credit bureaus for willful violations of the FCRA. 

This is my final attempt to resolve this matter before legal action. I expect a prompt and complete resolution. 

Sincerely, XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, NY XXXX