Product: Credit reporting or other personal consumer reports

UNITED STATES XXXX XXXX FOR THE [ District ] XXXX XXXX, Plaintiff, v. 
BANK OF AMERICA, Defendant. 
COMPLAINT PARTIES AND JURISDICTION Plaintiff : XXXX XXXX, an individual residing at XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX, FL XXXX ; Date of Birth : XXXX. 
Defendant : Bank of America, a banking institution with its principal place of business in XXXX, NC, engaged in consumer credit reporting, debt collection, and lending activities within the state. 
Jurisdiction : This Court has jurisdiction under 28 U.S.C. 1331, as this action arises under the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692c ( c ), and the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681. 
FACTUAL BACKGROUND Cease Communication Request : On [ Date of Written Notification ], Plaintiff sent a written request to Bank of America, explicitly instructing Defendant to cease all communication regarding a disputed debt, as authorized by 15 U.S.C. 1692c ( c ). 
Continued Communication : Following Plaintiffs cease-communication request, Defendant continued to attempt to collect the debt by contacting Plaintiff directly, violating the FDCPAs prohibition on continued communication after a cease-communication request. 
Inaccurate Credit Reporting : Bank of America inaccurately reported Plaintiffs account status and payment history to consumer reporting agencies, including [ e.g., XXXX, XXXX, XXXX ]. This inaccurate information included false delinquency reports and an improper charge-off that did not reflect the actual status or history of Plaintiffs account and persisted despite dispute notifications. 
CLAIM I : VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1692c ( c ) Elements Satisfied : Debt Collection Attempt : Defendant engaged in activities aimed at collecting a debt Plaintiff allegedly owed, falling under the definition of a debt collector. 
Written Cease-Communication Request : Plaintiff provided Defendant with a written notice, specifically instructing Defendant to cease all communications as per 15 U.S.C. 1692c ( c ). 
Continued Collection Efforts : Defendants communications following this request were neither a notification of termination of collection efforts nor legally permitted under the statutes limited exceptions. 
Damages : Defendants actions caused Plaintiff harm, including emotional distress, anxiety, and frustration. Plaintiff seeks statutory damages under 15 U.S.C. 1692k, as well as compensation for actual damages, along with reasonable attorneys fees and costs. 
CLAIM II : VIOLATION OF THE FAIR CREDIT REPORTING ACT, 15 U.S.C. 1681e ( b ) AND 1681s-2 ( b ) Elements Satisfied : Inaccurate Information Reported : Defendant reported incorrect information regarding Plaintiffs payment history, status, and delinquency, including erroneous late payments and an inaccurate charge-off date. 
Failure to Correct Information : Despite Plaintiffs dispute and notifications sent to Defendant and reporting agencies, Defendant failed to correct the inaccuracies or conduct a proper investigation as required under 15 U.S.C. 1681s-2 ( b ). 
Damages : Plaintiff suffered harm to his credit rating, financial losses, and emotional distress as a result of Defendants failure to ensure accurate reporting and correct misinformation. Plaintiff seeks statutory damages, actual damages, punitive damages, and reasonable attorneys fees and costs. 
RELIEF REQUESTED WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in favor of Plaintiff and against Defendant as follows : a. Statutory damages pursuant to 15 U.S.C. 1692k ( a ) ( 2 ) ( A ) for FDCPA violations. 
b. Actual damages for Plaintiffs emotional distress and financial harm caused by Defendants actions. 
c. Punitive damages under the FCRA for willful non-compliance. 
d. Reasonable attorneys fees and costs incurred in bringing this action. 
e. Any other relief the Court deems just and proper.