Consumer complaint received 2021-07-09
Company: EQUIFAX, INC.
State: NJ
Product: Credit reporting, credit repair services, or other personal consumer reports
Sub-product: Credit reporting
Issue: Incorrect information on your report
Sub-issue: Account information incorrect

Complaint:
I am XXXX XXXX, and I am the author of this complaint. This complaint is a FCRA based. Supporting docs/screenshots/account details are provided to me, as PII data validation / access has been provided to me - through myequifax.com and XXXX. 

This issue is with more than one account on my credit profile, and then as a result of Tradelines within my own reports, but this complaint will be constrained and initiated on just one Tradeline. 
There are a Total of 4 accounts with XXXX. 

Because my report lacks any identifying information such as an Account Number OR Original Creditor, please refer to account at XXXX, and Opened XX/XX/21, then in the screen shot with a Reported Balance of XXXX. 

It is attached as XXXX XXXX. 

Because of how this data is reporting, I feel/know/have realized that it is important to point out what FICO scoring relies on to produce a consumer score. FICO Score Calculations are based on 5 elements of a Tradeline, or Tradelines existing in/on a consumers profile/report. I have supplied the description from XXXX  as XXXX  FICO Ingredients, the source. FICO Scoring calculations are not different for each CRA. Payment History, Amount of Debt, Length of Credit History, Amount of New Credit, Credit mix.

I have attached screen shots from my credit report and, from myequifax.com and then XXXX. The screen shots of the Tradelines, are from Debt Collectors ( DC ). I have also attached the Metro2 file specification with the defined, inventory of FIELDS a DC is instructed to send. 

Its is attached as Metro2 - DC Section.

Finally I have provided a link to Equifax 's site - the directives from Equifax that says, Data Furnishers must send their the data in Metro2 format.

Its is attached as Metro2 - DC Section.

Top of Page 3 - Data Reporting Requirements All new Equifax data furnishers are required to comply with certain basic requirements : Data furnisher must be a credentialed Equifax data furnisher whose account is in good standing. 
Submissions must be formatted in accordance with current Metro 2 standards. 

https : //assets.equifax.com/assets/usis/data_furnisher_guidebook.pdf Understanding the Metro2 File - and specifically, the Debt Collector/Buyer section of this File Specification, It Clearly says - says send EQ approximately 19 fields on a consumer, and DO NOT SEND specific fields the result of what is currently allowed and being stored and reported becomes inaccurate data and with forethought and intent.

Please see DO NOT SEND Metro2 and DC Section Metro2.

Equifax itself, defines 12 sections of a consumer report. The sections have definitions, and intent.

Equifax says Accounts, Section 2. Revolving Accounts, 3. Mortgage Accounts, 4. Installment Accounts and 5. Other Accounts are for Creditors, Credit Grantors ( CG ).

These sections are : 2. Revolving Accounts Revolving accounts are those that generally include a credit limit and require a minimum monthly payment, such as credit cards 3. Mortgage Accounts Mortgage accounts are real estate loans that require payment on a monthly basis until the loan is paid off. You currently do not have any Mortgage Accounts in your file.

4. Installment Accounts Installment accounts are loans that require payment on a monthly basis until the loan is paid off, such as auto or student loans 5. Other Accounts Other accounts are those that are not already identified as Revolving, Mortgage or Installment Accounts such as child support obligations or rental agreements. 


Then there is a Section Called COLLECTIONS Equifax says this is for Debt Collectors.

10. Collections : Collections are accounts with outstanding debt that have been placed by a creditor with a collection agency. Collections stay on your credit report for up to 7 years from the date the account first became past due. They generally have a negative impact on your credit score.

Shouldnt then, all Debt Collectors ( definition from FTC ) be in this section of a consumer file/profile/report?

Then for Equifax, what DC Tradeline is reporting correctly? The Bureaus or XXXX? 

Both can not be accurate, as per your own definitions, technical standards and defined expected results. If you have examples of what it should look like be so kind as to supply it in your response to this complaint. 

Attached as EQ - Collections 10.0 ( The Bureaus ' tradeline ) The Bureaus fields, and all others in 10. COLLECTIONS, CAN be mapped to Metro2. 

The XXXX XXXX Fields Can not all others you allow in this section, CAN NOT be mapped to Metro2 Because of Equifax allowing them to report in a creditor/Credit Grantor Section, as an OTHER ACCOUNT, your SUMMARY section, then takes this data and calculates or derives values from its existence in fields that are inaccurate the data you are producing become wholly, knowingly, and willfully inaccurate. 

Date Assigned to Collections is <> ( not equal ) to Date opened.

EQ is allowing this to be true, fraudulently. This value date - is actually allowing this tradeline to show up in the " Most Recent Account Field ''. 

Please see attachment EQ Summary Details.

Must be noted all OTHER ACCOUNTS have CLOSED in their description, but they are not closed. 

XXXX XXXX XXXX XXXX ( CLOSED ) In Fact, they do not even have a closed date. 
This alone is wholly deceiving, and if I can see this you must know, as this is your application/database. 

When a Debt Collector is then reporting Closed in the Description, where there is a reported Debt To Credit Ratio it escapes your calculations for SUMMARY - CREDIT ACCOUNTS, amongst other calculations. 

All Tradelines in this XXXX. Other Accounts Sections fall into this issue.

Please see attachment EQ Summary Details.

1. There are sections, with details illustrated to the consumer and any other Credit Grantor/Lender or Employer, that describe - what should be in the inventory of Tradelines that you - EQ own, and expect to display 2. That Inventory - distinctly - separates a Creditor and a Debt Collector 3. My descriptive of each type of Data Furnisher ( CG vs. DC ) is - the FTC description 4. Other Accounts ( Section 5. ) are For Credit Grantors 5. XXXX XXXX XXXX is a Debt Collector 6. You are allowing and then reporting, Debt Collectors, in Section 5.0 7. Section 5., is used in your Summary Details, and as such is creating skewed view of Credit Accounts and Scores 8. You do not report XXXX  in section 10.0 9. You do, Report a Debt Collector, like The Bureaus in this section 10. When a Debt Collector is in Section 10., the data can be mapped to Metro2.

11. When not in that section it is visibly incompliant.

12. Metro 2 says, do not sent Pay History, see attached where you are allowing it 13. EQs Description of this tradelines Account Details ( Right above the High Credit Owner Fields are Account Details View detailed information about this account. Contact the creditor or lender if you have any questions about it See attached Account Details section 14. In my view/report, there is no Account Number, making this incomplete 15. Account Status = Collection, I believe Metro 2 allows this value for CGs reporting a Tradeline not DCs.

16. Available Credit never applicable to a DC 17. Reported Balance High Credit, remarkably is used to create the Debt to Credit Ratio which is applicable to a Creditor/Lender and by your own definition- why is this allowed? 18. Months Reviewed by your own definition, never applicable
to a DC 19. Loan Type never applicable to a Debt Collector Eqs definition and Metro2s 20

. Date Opened can not, and can never = Date assigned, you are allowing this 21. Then = Delinquency First Reported can NEVER, ever be true, it is 8 months before the account was even opened 22. Creditor Classification is hijacked, allowing the DC to act as if it was the Original Creditor, and Creditor/Lender 23. Where is the Original Creditor? 24. There is a Dedicated
Field for Orig Cred, but its never reported when a DC is allowed to report in this uncompliant manner 23. Equifax is allowing this wholly inaccurate, and malicious account.

24. There is more I will save it for next steps as allowed by law.

This has been and is, in front of all the consumers eyes with a cloak and a dagger. Once you see it through you can never unsee it.

Company response to consumer: Closed with explanation