Consumer complaint received 2023-03-16
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: TX
Product: Credit reporting, credit repair services, or other personal consumer reports
Sub-product: Credit reporting
Issue: Problem with a credit reporting company's investigation into an existing problem
Sub-issue: Investigation took more than 30 days

Complaint:
Executed on ( XX/XX/XXXX ). 
XXXX, Executed on ( XX/XX/XXXX ). 
XXXX and Executed ( XX/XX/XXXX ) Transunion were fowarded ..AFFIDAVIT OF VERIFICATION & DISPUTE AS UNSWORN DECLARATION to remove the Reported Consumer Report Debt Collections from their records being in direct violation of the Consumers Privacy Rights. XXXX, Transunion XXXX XXXX are " financial Institutions '' Section 6809 of title 15 defines financial institution as. any institution the business of which is engaging in financial activities as described in section 1843 ( k ) ( 4 ) of title 12 in turn defines activities that are financial in nature to include [ e ] ngaging in any activity that the [ Federal Reserve ] Board has determined, by order or regulation that is in effect on XXXX XXXX, to be so closely related to banking or managing or controlling banks as to be a proper incident thereto ( subject to the same terms and conditions contained in such order or regulation, unless modified by the Board ). On XXXX XXXX, the Federal Reserve Board promulgated a regulation, still in effect on XXXX XXXX, which expressly identifies as among activities..so closely related to banking or managing or controlling banks to be a proper incident thereto those activities that are usual in connection with making, acquiring, brokering or servicing loans or other extensions of credit, including : Credit reporting services. Maintaining information related to the credit history of consumers and providing the information to a credit grantor who is considering a borrowers application for credit or who has extended credit to the borrower. 

Banking holding Companies and Change in Bank Control ( Regulation Y ), 62 Fed.Reg. 9290,9329 ( 1997 ) ( codified at 12 C.F.R. sec. 225.28 ( b ) ( 2 ) ( v ) ). Because the Federal Reserve Boards regulation characterizes credit bureau services as so closely related to banking or managing or controlling banks as to be a proper incident thereto, FTC permissibly determines that XXXX, XXXX XXXX TRANSUNION provides such services and comes within the Gramm-Leach-Bliley Act GLBAs definition of a financial institution and is therefore subject to its rulemaking authority under 15 U.S.C. 6804 ( a ) ( 1 ). See Transunion LLC v. Federal Trade Commision 295 F.3d 42 ( D.C. Cir. 2002 ). 





XXXX, XXXX XXXX Transunion were informed and became aware that the information provided within the consumers report is inaccurate and false information and by XXXX, XXXX XXXX Transunion inactions rendered to violating The Gramm-Leach-Bliley Act by XXXX being a financial institution of not having provide the consumer a CLEAR & CONSPICUOUS disclosure to such consumer, in writing or in electronic form or other form disclosing nonpublic personal information to affiliates and nonaffiliated third parties, consistent with section 6802 therefore must permanently delete any and all data related to the Consumer to avoid liability and criminal charges with prejudice.

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