Product: Credit card

Re : Wells Fargo Bank , N.A . 's Willful Fraudulent Misreporting, Misrepresentation, Defamation, and Unlawful Activity in Violation of Law To Whom It May Concern : I am writing to formally and unequivocally address Wells Fargo Bank , N.A . 's continued willful misconduct, fraud, misrepresentation, and defamatory reporting practices regarding my charged-off credit card account ending in XXXX. 

Despite having charged-off this account as of XX/XX/XXXX, Wells Fargo continues to knowingly and maliciously report the account as a charged-off, past-due balance to consumer reporting agencies XXXX XXXX, XXXX XXXX XXXXXXXX, XXXX ) XXXX This ongoing false reporting constitutes defamation of character, invasion of privacy, and a direct and proximate cause of personal injury, including but not limited to, harm to my creditworthiness, denial of credit opportunities, emotional distress, and deprivation of rights to life, liberty, and the pursuit of happiness. 

Further, XXXX XXXX own public filings to the Securities and Exchange Commission specifically, Exhibit XXXX, Receivables Purchase Agreement dated XX/XX/XXXX ( Link : https : XXXX ) conclusively admit and confirm that Wells Fargo Bank , N.A . does not retain any right, title, or interest in their credit card receivables. 

Under the terms of the Receivables Purchase Agreement, Wells Fargo expressly sells, assigns, and transfers " all right, title, and interest '' in and to the credit card receivables to WF Funding, LLC, who then sells and assigns those same receivables to WF Card Issuance Trust.

Accordingly, Wells Fargo is not the holder in due course, not the real party in interest, and legally lacks standing to enforce or report the alleged debt as owed to them.

Wells Fargos Actions Constitute Willful Fraud and Misrepresentation : Wells Fargo is knowingly and intentionally furnishing false information to consumer reporting agencies in violation of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681s-2 ( a ) ( 1 ) ( A ), which prohibits a furnisher from reporting inaccurate information.

By falsely portraying themselves as still owning and collecting on an account they divested, Wells Fargo commits common law fraud, defamation, and intentional infliction of emotional distress. 

Misrepresentation to state courts in pending actions by collaborating with third-party law firm XXXX & XXXX XXXX XXXX. further constitutes fraud upon the court and conspiracy to defraud, actionable under federal and state law. 

Supporting Case Law : XXXX, XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) Furnishing false information to credit reporting agencies that harms a consumers creditworthiness constitutes concrete and particularized injury sufficient to confer standing. 

XXXX v. XXXX & XXXX, XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) Furnishers of information to credit reporting agencies have a duty to investigate and correct inaccurate reporting under the FCRA. 

XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) Entities who purchase debts for their own account are not considered " debt collectors '' under the FDCPA, reinforcing the point that Wells Fargo is not acting properly if they have transferred the debt and still misrepresent ownership. 

XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX, XXXX XXXX XXXX ( XXXXXXXX XXXX XXXXXXXX ) Knowingly making false claims constitutes fraud under federal law. 

Wells Fargos Attempted Defense Is Without Merit : The " Resolution Letter '' dated XX/XX/XXXX from Wells Fargo regarding a previous CFPB complaint regarding WFBNA 's non-transparent and deceitful actions, is nothing but a bad-faith, boilerplate attempt to evade liability. Wells Fargos arguments about consumer authorization for credit reporting during the original account application are irrelevant and legally insufficient because : Any prior consent was terminated once the receivables were assigned and Wells Fargo divested ownership.

Wells Fargo can not report on an asset they no longer lawfully own. 

Wells Fargo 's continuing reporting constitutes furnishing knowingly false information under the FCRA, which mandates correction or deletion. 

Their attempts to smear me by referencing fraudulent debt elimination schemes is a baseless, defamatory attack, designed to distract from their own unlawful behavior. Such reckless accusations without evidence will be deemed slanderous per XXXX and will give rise to further claims for punitive damages. 

XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX. : Wells Fargo and XXXX & XXXX, XXXX. are acting in concert to deceive courts and pursue unlawful collection actions based on rights and interests that Wells Fargo no longer possesses. Their actions are a classic case of : Misrepresentation and fraud upon the court ( XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX XXXX ) Abuse of Process Conspiracy to commit fraud I have accordingly filed a counterclaim asserting these allegations in the state court action. 

Demands : Immediate cessation and deletion in perpetuity to any and all consumer reporting agencies of the reporting trade-line by Wells Fargo relating to the account ending in XXXX. 

Formal retraction of all defamatory statements made to credit reporting agencies.

Disclosure of all assignment documents and proofs of sale regarding my account from Wells Fargo to WF Funding, LLC, and subsequently to WF Card Issuance Trust.

Immediate dismissal of any pending collection actions brought by XXXX & XXXX, XXXX. acting under Wells Fargo 's name. 

Monetary compensation of XXXX for damages already suffered, including but not limited to credit denials, XXXX XXXX XXXX XXXX XXXX 

Punitive damages for Wells Fargos and its agents willful, malicious, and fraudulent misconduct.

Notice of Further Action : If Wells Fargo fails to fully comply within ten ( 10 ) days of receipt of this notice, I will escalate this matter by filing formal complaints with : Consumer Financial Protection Bureau ( CFPB ) Office of the Comptroller of the Currency ( OCC ) Federal Trade Commission ( FTC ) State Attorney Generals Office Additionally, I reserve the right to initiate a civil lawsuit seeking actual, statutory, and punitive damages under the Fair Credit Reporting Act ( 15 U.S.C. 1681n and 1681o ) and common law fraud statutes, without further notice.

Govern yourself accordingly.