Consumer complaint received 2024-01-26
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: PA
Product: Credit reporting or other personal consumer reports
Sub-product: Credit reporting
Issue: Problem with a company's investigation into an existing problem
Sub-issue: Their investigation did not fix an error on your report

Complaint:
1022.142 Prohibition On Inclusion Of Adverse Information In Consumer Reporting In Cases Of Human Trafficking As discussed below under 1022.142 ( c ) of the final rule, the Bureau is not adopting any exceptions to the requirement that consumer reporting agencies block adverse information that resulted from trafficking., A CRA, has refused my requests to block adverse information.Company 's Response : In respone to your request as a victim of trafficking, we sent a letter requesting additional documentation or information to complete your request and provided instructions on where to send them. A phone number was also provided for additional questions. Perversely, The final rule will require consumer reporting agencies to accept trafficking and other documentation from consumers, process the submissions, and block any adverse item of information identified by the consumer that resulted from a severe form of trafficking in persons or XXXX trafficking under 1022.142 ( d ) ( e ). 
I Do hereby Self-Attest that I am a Victim ( See 142 ( b ) ( 7 ) Victim of Trafficking for the Purposes of 605C of the Fair Debt Reporting Act. A consumer reporting agency may only request additional information where the consumer reporting agency can not reasonably confirm the appropriate proof of identity under paragraph ( b ) ( 1 ) of this section for the consumer or, if applicable, the consumers representative, the consumer did not provide victim determination documentation under paragraph ( b ) ( 6 ) ( i ) of this section, or the consumer reporting agency can not properly identify the adverse items of information under paragraph ( b ) ( 6 ) ( ii ) of this section. 
A consumer reporting agency may not, however, ask for information on the validity of the facts or circumstances detailed in the contents of the submitted trafficking documentation establishing the consumer is a victim of trafficking or whether the identified adverse information resulted from a severe form of trafficking in persons or XXXX trafficking under paragraph ( b ) ( 6 ) of this section. 
( ii ) Timing of final determination. A consumer reporting agency must make a final determination on the consumers submission no later than 25 business days after receiving the submission provided in paragraph ( d ) ( 1 ) of this section. The final rule also does not require consumer reporting agencies to delete adverse items of information identified by the victim of trafficking from the consumers credit file. The Bureau has determined that requiring consumer reporting agencies to delete that information would be counterproductive because, as explained above, the final rule does not require a consumer reporting agency to notify the furnisher of adverse information that a consumer has submitted the required documentation. If the information is deleted, but the furnisher is not provided with a reason, there is a substantial risk that the information will be reinserted into the report, whereas a block without deletion makes it more likely that the consumer reporting agency will not include the adverse information in future reports after the information is confirmed to remain blocked in 1022.142 ( e ) ( 3 ). 
New 1022.142 ( e ) ( 4 ) provides that a consumer reporting agency may only decline or rescind a block only if the consumer reporting agency can not reasonably confirm the appropriate proof of identity for the consumer and, if applicable, the consumers representative under 1022.142 ( b ) ( 1 ), the consumer can not provide documentation consisting of a victim determination under 1022.142 ( b ) ( 6 ) ( i ), Similar to the section- by-section analysis of 1022.142 ( e ) in the proposed rule, the Bureau does not interpret section 605C as giving the consumer reporting agency the discretion to contest the merits of the submitted trafficking documentation, if it meets the definition in section 605C ( a ) and in 1022.142 ( b ) ( 6 ) ( i ), nor does it interpret the statute as giving a consumer reporting agency the discretion to challenge a consumers determination that an adverse item of information resulted from a severe form of trafficking in persons or XXXX trafficking under 1022.142 ( b ) ( 6 ) ( ii ).

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with non-monetary relief