Product: Debt collection

PDF Uploaded with complaint in easier to read format. 

Date : XX/XX/year> Dear Consumer Financial Protection Bureau, I am writing to formally lodge a complaint regarding actions taken by America First Credit Union, which I believe may not comply with applicable laws and regulations governing debt collection, credit reporting, and consumer protection. The purpose of this letter is to request an investigation into this matter and ensure compliance with all relevant statutes and regulations. 
2 INTRODUCTION I am a consumer who submitted a dispute to a credit bureau regarding a debt reported by America First Credit Union. The debt in question pertains to Auto Installment Loan For Vehicle. I am deeply concerned about the lenders subsequent response to my dispute, which I believe raises potential compliance issues. 
3 SUMMARY OF THE ISSUE 1. Timeline of Dispute : On XX/XX/year>, I submitted a dispute to XXXX regarding the accuracy or validity of a debt reported by America First Credit Union. 
2. Lenders Response : In response, the lender sent me a correspondence containing the first page of my loan agreement. This document includes details such as the interest rate, finance charge, monthly payment, and total amount financed. However, the letter did not provide any explanatory context or disclaimers, such as " This is not an attempt to collect a debt '' or " For informational purposes only. '' 3. Lack of Explanation : Unlike other creditors who responded to my dispute, America First Credit Union provided no explanation of their response or its intent, leaving the purpose of the correspondence unclear.

4 CONCERNS I am concerned that America First Credit Union may not have adhered to the procedures and transparency requirements mandated by the following laws and regulations : 4.1 FAIR CREDIT REPORTING ACT ( FCRA ) : o Section 611 ( a ) ( 15 U.S.C. 1681i ) : The FCRA requires furnishers of information to conduct a reasonable investigation into disputes and provide a response that addresses the substance of the dispute. The lack of explanation in the lenders response raises questions about compliance with this provision.

o Section 605 ( 15 U.S.C. 1681c ) : Accuracy and completeness of information in consumer reports are essential, and vague or unclear responses may not meet this standard.

4.2 FAIR DEBT COLLECTION PRACTICES ACT ( FDCPA ) : o Section 807 ( 15 U.S.C. 1692e ) : Prohibits the use of false, deceptive, or misleading representations in connection with debt collection. The failure to include disclaimers or context may mislead consumers regarding the purpose of the communication.

o Section 809 ( 15 U.S.C. 1692g ) : Addresses validation of debts and the requirement to provide sufficient information to the consumer. The lenders response may not meet this requirement.

4.3 GRAMM-LEACH-BLILEY ACT ( GLBA ) : o Section 502 ( 15 U.S.C. 6802 ) : Requires financial institutions to protect the privacy of consumers and provide clear notices regarding the handling of nonpublic personal information. The lack of clarity in the lenders communication may violate these privacy requirements.

4.4 EQUAL CREDIT OPPORTUNITY ACT ( ECOA ) : o Adverse Action Notices ( 12 CFR 1002.9 ) : If the lenders response could be interpreted as denying my dispute without proper explanation, this might trigger requirements for an adverse action notice.

4.5 REGULATION Z - TRUTH IN LENDING ACT ( TILA ) : o Accuracy and Transparency in Disclosures ( 12 CFR 1026 ) : If the lenders response includes financial details but fails to disclose the purpose of sharing this information, it may conflict with Regulation Zs requirements for clear, meaningful disclosure of information related to consumer credit.

4.6 TILA-RESPA INTEGRATED DISCLOSURE RULE ( TRID ) : o If the lender included details like the loan agreement without accompanying necessary disclosure information, this could potentially be a TRID issue related to ensuring consumers receive comprehensive and understandable information in communications about their loans.

4.7 UNFAIR, DECEPTIVE, OR ABUSIVE ACTS OR PRACTICES ( UDAAP ) : o Sections 1031 and 1036 of the Dodd-Frank Act prohibit practices that are unfair, deceptive, or abusive. The unclear intent and lack of context in the lenders communication could be construed as an unfair or deceptive practice, causing confusion or potential harm to consumers.

4.8 STATE-SPECIFIC CONSUMER PROTECTION LAWS : o Nevada Deceptive Trade Practices Act ( NRS 598 ) : Under Nevada law , vague or misleading communication in consumer financial matters could be deemed a deceptive trade practice, especially if it causes confusion regarding the consumers rights or obligations.

5 REQUEST FOR INVESTIGATION Given the above concerns, I respectfully request the CFPB to : 1. Investigate whether Americas First Credit Union has complied with the FCRA, FDCP

A, GLBA, ECOA, TILA, TRID, UDAAP, and relevant state consumer protection laws in their handling of my dispute.

2. Determine whether the lenders correspondence meets the standards for transparency, clarity, and compliance under these laws.

3. Provide guidance or take appropriate action to ensure that the rights of consumers are upheld in similar cases.

6 CONCLUSION I trust that the CFPB will carefully review this matter and take the necessary steps to address any non-compliance. I am willing to provide further documentation or information upon request to assist in your investigation. Please feel free to contact me at XXXX or XXXX if additional details are required. 
Thank you for your attention to this matter. I look forward to your response. 
Sincerely,