Product: Credit reporting or other personal consumer reports

Consumer Financial Protection Bureau Complaint Complaint Against : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX, XXXX XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX File Number : XXXX To whom it may concern : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Demand for Immediate Compliance Debt Validation, Removal of Unauthorized Reporting, and Compensation for Rights Violations Nature of Complaint : I, XXXX XXXX XXXX file this second complaint against Portfolio Recovery Associates , PRA Group and its subsidiaries for their ongoing violations of federal and state laws. They continue to report an alleged debt that they purchased in XXXX but originated in XXXX, despite failing to validate it and acting outside the statute of limitations for collection in Maryland. 

Violations 1. Failure to Validate Debt Portfolio Recovery Associates has failed to validate the alleged debt despite my lawful requests. They have not provided a wet ink signature to substantiate their claim, which is essential for validating the debt. Additionally, they continue to report this unverifiable debt to consumer reporting agencies, violating 15 U.S.C. 1681s-2 ( a ) ( 1 ) ( A ), which prohibits furnishing inaccurate or unverified information. Furthermore, the absence of mutual consent or consideration related to this alleged debt renders any claims by Portfolio Recovery Associates wholly unenforceable.

2. Reporting Outside Maryland 's Statute of Limitations Portfolio Recovery Associates continues to report an alleged debt that is time-barred, violating both federal and state consumer protection laws. In Maryland, the statute of limitations for debt collection is three years, as outlined in Maryland Code, Courts and Judicial Proceedings 5-101. The alleged account originated in XXXX, and the time to collect expired in XXXX. Despite this, Portfolio Recovery Associates persists in reporting the debt, violating Md. Code, Cts. & Jud. Proc. 5-1202 ( b ) ( 1 ), which protects consumers from unfair collection practices. Furthermore, PRAs reporting of time-barred debts is a deceptive practice that violates both the Fair Debt Collection Practices Act ( FDCPA ) and the Fair Credit Reporting Act ( FCRA ). I remind you that debts barred by the statute of limitations can not legally be reported as collectible obligations, as outlined in Maryland Commercial Law Article 14-202. Such conduct constitutes a willful misrepresentation of my credit status in violation of FCRA 602 ( 15 U.S.C. 1681 ) and amounts to unlawful collection practices, which infringes upon my rights as a consumer. 
3. Unlawful Reporting of XXXX Without Consent For 38 months, Portfolio Recovery Associates has unlawfully reported my nonpublic personal information ( XXXX ) to consumer reporting agencies without my expressed consent.

This violates : 15 U.S.C. 6802 ( b ) ( c ) : Prohibits financial institutions from sharing XXXX  without informing the consumer of their right to opt out. 

12 CFR 1016.7 : Consumers may opt out of NPPI sharing at any time.

15 U.S.C. 1681b ( 2 ) ( a ) : Requires written instructions from the consumer before reporting information. 



4. Adverse Reporting Beyond Legal Time frames The debt is being reported as an adverse account, despite originating more than 5 years ago in XXXX. This violates 15 U.S.C. 1681c ( a ) ( 5 ), which generally restricts the reporting of adverse information to a period of seven years, unless related to criminal activity. I have not committed any crime, and therefore, the reporting of this adverse account is unjustified and should be excluded from my credit report.

5. Failure to Maintain Reasonable Procedures Portfolio Recovery Associates has failed to comply with their obligation under 15 U.S.C. 1681e ( b ) to maintain reasonable procedures to ensure compliance with the FCRA. Their actions demonstrate negligence in reporting unverified, outdated, and unauthorized information.

6. Failure to Inform of Nondisclosure Rights Portfolio Recovery Associates failed to notify me of my right to opt out of NPPI sharing, as required by 15 U.S.C. 6802 ( b ) ( c ).

7. Impermissible Reporting of Non-Public Personal Information Under 15 U.S.C. 1681b of the Fair Credit Reporting Act ( FCRA ), you are required to have a permissible purpose for accessing or sharing my non-public personal information. Reporting my private data to credit bureaus without proper authorization is in violation of this statute, given my explicit opt-out under the Gramm-Leach-Bliley Act, 15 U.S.C. 6802. You have neither my consent nor any permissible reason to share or report my information.

Key Legal Citations 15 U.S.C. 1681s-2 ( a ) ( 1 ) ( A ) : Prohibits furnishing unverifiable information.

15 U.S.C. 1681c ( a ) ( 5 ) : Restricts adverse information older than seven years, unless related to criminal activity.

15 U.S.C. 1681b ( a ) ( 2 ) : Requires written consent for reporting.

15 U.S.C. 6801-6802 : Establishes privacy protections and opt-out rights.

Maryland Code, Courts and Judicial Proceedings 5-101 : Sets a three-year statute of limitations on debt collection. 


Fee Schedule Portfolio Recovery Associates has unlawfully reported my NPPI for 38 months. Based on the following fee structure : {$1000.00} per instance of unauthorized reporting = {$38000.00} {$1500.00} per instance of XXXX disclosure without consent = {$57000.00} {$500.00} per day of failure to cease unauthorized reporting = XXXX XXXXXXXX, for 38 months = {$720000.00} Total Damages Claimed : {$810000.00} Relief Sought I demand the following : 1. Immediate removal of all unverified, unauthorized, and outdated information from my credit reports. 
2. Cessation of any further reporting of this account or my NPPI.

3. Damages for the harm caused to my credit worthiness and privacy rights, totaling {$810000.00}.

Payment Terms All fees are due upon receipt of this fee schedule unless otherwise negotiated.

In the event of continued non-compliance or inadequate response, additional fees may incur for further legal consultations and actions. 


Acknowledgment By acknowledging receipt of this fee schedule, you agree to these terms and conditions. I request you to address this matter promptly to avoid further fees and complications.

Closing Statement Portfolio Recovery Associates ' continued reporting of this debt, despite its unverified status, expiration under Maryland 's statute of limitations, and my expressed opt-out requests, demonstrates willful noncompliance with federal and state laws. Their actions are a blatant violation of the Fair Credit Reporting Act ( 15 U.S.C. 1681 ) and the Gramm-Leach-Bliley Act ( 15 U.S.C. 6801-6809 ). This behavior must be addressed immediately to protect my rights as a consumer. 

Failure to comply will result in formal escalation through legal channels, including filing complaints with the Federal Trade Commission ( FTC ) and taking any necessary civil actions for your willful violations of federal and state law. 

I trust you understand the gravity of your obligations and expect a prompt resolution to this matter. 




Sincerely, /s/ XXXX XXXX