Product: Credit reporting or other personal consumer reports

COMPLAINT FOR VIOLATIONS OF THE FAIR CREDIT REPORTING ACT INTRODUCTION Plaintiff, XXXX XXXX XXXX ( " Plaintiff '' ), brings this action under the Fair Credit Reporting Act ( " FCRA '' ), 15 U.S.C. 1681 et seq., against Defendant US Bank Home Mortgage ( " Defendant '' or " US Bank '' ) for its willful and negligent violations of the FCRA, specifically 15 U.S.C. 1681s-2 ( b ). 
Defendant failed to conduct a reasonable investigation of Plaintiffs disputes, resulting in continued inaccurate and misleading reporting of Plaintiff 's account, causing substantial harm to Plaintiffs creditworthiness and financial reputation. 
PARTIES Plaintiff XXXX XXXX XXXX is a natural person and a " consumer '' as defined by the FCRA, residing at XXXX XXXX XXXX XXXX, XXXX, MN XXXX. 
XXXX US Bank Home Mortgage is a financial institution headquartered at XXXX XXXX XXXX, XXXX, MN XXXX, and a " furnisher '' of information as defined by the FCRA. 
JURISDICTION AND VENUE This Court has jurisdiction over this action pursuant to 15 U.S.C. 1681p and 28 U.S.C. 1331.

Venue is proper in this judicial district under 28 U.S.C. 1391 ( b ) because Defendant conducts business here, and a substantial part of the events giving rise to Plaintiffs claims occurred in this district. 
FACTUAL BACKGROUND Plaintiff held a mortgage account with Defendant, identified as Account XXXX XXXX ( " the Account '' ). 
Defendant has reported the Account inaccurately on Plaintiff 's consumer reports with XXXX, XXXX, and XXXX, showing incorrect dates of first delinquency, date of last payment, and varying delinquency periods across the credit reporting agencies. 
Specifically, the Account is reported with discrepancies among the credit bureaus as follows : Incorrect Date of First Delinquency : XXXX reports the date as XX/XX/XXXX, while XXXX lists it as XX/XX/XXXX. 
Incorrect Date of Last Late Payment : XXXX lists the last late payment as occurring in XX/XX/XXXX, while XXXX shows it as XX/XX/XXXX. 
Payment History Discrepancies : XXXX reflects delinquency starting in XXXX with a foreclosure in XX/XX/XXXX, whereas XXXX indicates the foreclosure process began in XX/XX/XXXX. 
Plaintiff disputed these inaccuracies with each credit reporting agency, which in turn notified Defendant of the dispute. 
Under 15 U.S.C. 1681s-2 ( b ), upon receiving notice of Plaintiff 's dispute, Defendant was required to conduct a reasonable investigation, correct any inaccuracies, and report the results to each credit reporting agency. 
Defendant failed to conduct a reasonable investigation into the dispute and continued to report inaccurate information, including materially misleading dates and payment histories, resulting in ongoing harm to Plaintiffs credit profile. 
COUNT I VIOLATION OF THE FAIR CREDIT REPORTING ACT, 15 U.S.C. 1681s-2 ( b ) Plaintiff incorporates all preceding paragraphs as if fully stated herein. 
The FCRA imposes a duty upon furnishers of information, such as Defendant, to ensure the accuracy and completeness of information provided to consumer reporting agencies. 
Defendant received notification from one or more credit reporting agencies regarding Plaintiffs dispute over the accuracy of information reported about the Account.

Upon receiving notice of the dispute, Defendant had a duty under 15 U.S.C. 1681s-2 ( b ) to : Conduct a reasonable investigation into the disputed information ; Review all relevant information provided by the credit reporting agencies ; Correct or delete any inaccurate or incomplete information ; and Report the results of the investigation to the credit reporting agencies. 
Defendant failed to conduct a reasonable investigation into Plaintiffs dispute as required by 15 U.S.C. 1681s-2 ( b ). Specifically : Defendant continued to report inaccurate and materially misleading information regarding the Accounts payment history and delinquency status without correcting or updating the information across all credit bureaus.

Defendants investigation was cursory and failed to adequately address the underlying inaccuracies of the Account as Plaintiff had detailed in the dispute.

By failing to properly investigate and correct the inaccurate information on Plaintiffs consumer reports, Defendant violated Plaintiffs rights under the FCRA. 
DAMAGES As a result of Defendants negligent and/or willful conduct, Plaintiff has suffered actual damages, including but not limited to, emotional distress, reputational damage, denial of credit, loss of financial opportunities, and other economic and non-economic harm. 
Plaintiff is entitled to actual damages, statutory damages, and punitive damages pursuant to 15 U.S.C. 1681n and 1681o for Defendant 's willful and negligent noncompliance with the FCRA.

PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in Plaintiffs favor and against Defendant, and award the following relief : A. Actual damages pursuant to 15 U.S.C. 1681o ( a ) ( 1 ) ; B. Statutory damages and punitive damages pursuant to 15 U.S.C. 1681n ( a ) ; C. Costs and reasonable attorneys fees pursuant to 15 U.S.C. 1681n and 1681o ; D. Preliminary and permanent injunctive relief enjoining Defendant from reporting inaccurate and incomplete information on Plaintiffs consumer reports ; and E. Such other and further relief as the Court may deem just and proper.

DEMAND FOR JURY TRIAL Plaintiff hereby demands a trial by jury on all issues so triable.