Consumer complaint received 2021-07-22
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 status incorrect

Complaint:
Please ensure that you, XXXX REPORT to the CRAs any details that need to be communicated, corrected or resolved. 

The DO NOT CONTACT remains in place, and as per communications acknowledged by you XXXX. An attachment, that only I can see is not the expected result. If you can substantiate it you are then required to report it. 

XXXX account number is missing from Equifax, when derived from XXXX XXXX XXXXXXXX ( spaces intended ). The complaint, is regarding what XXXX reported as - Opened Date XX/XX/2017, Balance XXXX. 

For this complaint, and then as allowed I would like both the method of investigation, and then a printed report, mailed to my address of record ( Equifax and XXXX ), and with the results. 

This is not a validation of debt. Please do not respond as if it is, your IT departments can help translate the issues outlined in this complaint, logically laid out and for 1 account ( you have 4, and I will do one by one with each CRA ) you - XXXX reported, and Equifax and XXXXXXXX then loads, displays and reports. 

This Complaint is about your DATA, XXXX how you chose/design/elect to report it, and specific to FDCPA/FCRA mandates. 

This is also about the CRAs. how they accept/load/report the Data XXXX sends. Logical, and as demonstrated, the impact of this activity is the premise of this complaint. Technical reliance on METRO2, and the related FDCPA and FCRA compliance issues, then become the issue. 

*****This is MY intellectual/data, including all the attachments and they should be treated in this fashion, proprietary or/and otherwise. I do NOT, authorize any usage outside of this complaint. 

I am XXXX XXXX, and I am the author of this dispute. This is NOT a Duplicate complaint, please do not flag it as such. I am not a Credit Repair Organization, nor am I using one I just love the data. 

The screenshots/attachments/data within this complaint - are pulled directly from XXXX, MyEquifax.com and XXXX with my PII data validated and ensured, for verification and for access to my own, Credit Reports. As such this experience has allowed me to explore Metro2, its intent, requirements, technical specifications, field definitions and usage and in Credit Reporting, and specific to Debt Collectors and the CRAs. 

This complaint is a bit long, and detailed, with some technical details within it. But you are provided with logical, discoverable details and steps to see your data, its end state and its whole state of inaccuracy. 

All the companies within this complaint have an IT team, and developers that created/manage the integrations, built/build or maintain the systems, or load the files from Data Furnishers. It is advised that IT assist in your response. 

There is an existing complaint against XXXX and the complaint number is XXXX. 

That complaint - if read, is/was not a simple request of Validation of Debt, it was detailed, and specific to a complaint to XXXX. and its compliance with Metro2, and its standards - and, then FCRA/FDCPA. While XXXX did make traceable changes in my records at the CRA, they also said that there was nothing wrong, and that they believed that everything was correct. Thank you for that and changing your ( XXXX ) Loan Type from : Factoring Company to Debt Buyer, as it assisted in the decision to dive deep, into the data - it was eye opening. 

That data creation, storage, file production and load/reporting stream of activity that occurs, is in fact that of XXXX and EquifaxXXXX. When there is an error in data or a system at least in standard XXXX, the rules that govern Consumer Data/Data Furnishers/CRAs Requirements through to Expected Results, the tasks to resolve are in fact defined. When they are defined, they are the rules. Defects are Traceable and, remedied or not. 

I am attaching a few documents that will assist everyone, Legal, IT and the CFPB - with understanding entrance into this complaint. This complaint is segmented, but it is also extremely logical, using the systems of the CRA to demonstrate its data, and what it is is appearing as, and the impact to the algorithms that are used for scoring, summarizing and reporting Midlands data. 
1. Attached as CFPB Metro2 - Required by all 3 - Metro2, Directives from XXXX, EQ and XXXX to ONLY send Metro2 Compliant integrations/files 2. Attached then, is Metro 2 - DC Section ( Tech Specification for Metro2 ) defined for Debt Collectors, which specifies the Segments and then Fields or Valid Values that can be sent in compliance with Metro2 3. *****Header and/or Footer is neither keyed, nor specific, to a consumer excluded. 
4. Records for Debt Collectors and then identified for consumers are in Segments called/named/labeled Base and K segments, ONLY 5. Do Not Send Metro2 Specifies the Fields or Valid Values that Should NOT ever, be sent to a CRA in compliance with Metro2 6. There is a logical reason why a technical specification, used industry wide would call this out 7. There are a total of 17 ( or so ) identifiers/fields of values, address may extend the fields populated as an example but the record is not extended for the Consumer Debt Collectors record 8. I have mapped the to a TRUE Collection Account EQ and XXXX ( See XXXX Attachment - Tab in attachment XXXX XXXXEquifax Collection ) 9. Both are using the CRAs Verbiage/Directive/Instructions 10. Sample Debt Collectors exist in EQs reports. 
11. XXXX says it but, well. Either the documentation is all wrong or, the system is. 
12. XXXX  is sending fields Do NOT sen

d Metro2 13. Metro2 offers NO Defaults. 14. If you see it in Equifax and XXXX and you are told NEVER to send it 15. XXXX/XXXX/Equifax - You have failed to remedy the end result, that you know is invalid. 

I am pasting below, a link to the responsibilities as a Data Furnisher - I am relying on ( XXXX ) XXXX XXXX XXXX? XXXX & XXXX For Federal Law - Definition of a Creditor and then a Debt Collector, I am relying on - 803 ( 4 ) and ( 6 ) XXXX XXXX XXXX  Equifax XXXX XXXX. Any algorithm using this data as it is reporting itself - is no doubt producing inaccurate data/results/reports to anyone who has access to this data. 
2. Your views demonstrate it ( Equifax/XXXX  ) 3. XXXX - is not a Creditor/Lender. 
4. XXXX is a Debt Collector 5. The result of all of this - is that XXXX is reporting as a Creditor/Lender, with attributes they are directed NOT to send. 
6. XXXX Data sent on their files, are outside of Metro2 Standard ( See Metro2 Mapped DC Tab ). 
7. Equifax/XXXX  BOTH, have Dedicated Section, for COLLECTION ( See 5. Collections vs. 10. Portfolio Tab and ) 8. That Section Labeled, Described and Published, by Equifax/XXXX - defines it usage for Debt Collectors. 
XXXX. That Section is 10. In Equifax published standards fail to be demonstrated by XXXX, in any consumer report/view/profile. 
10. XXXX  you say there is a Collection Section even with the fields map/match Metro2, but, have deleted/masked/removed it, if it exists somewhere please share it in your response. 
11. Those fields are consistent with Metro2 Guidelines when mapped to the accounts details and data you, XXXX have published. 
12. I have mapped it its attached, on the Metro Mapped DC Tab 13. Equifax has a Dedicated Section, for Accounts, Tradelines of Creditors and Lenders 14. That Section Labeled, Described and Published, by Equifax -defines it usage for Creditors/Lenders, that section is 5. 
15. In that section - 5.2, says 5.2 XXXX ( CLOSED ) 16. The Account is not CLOSED 17. Should XXXXEquifax say it is, where is the Date Closed/Activity Designator that is Required of this TYPE of Account? If its not correct this? 
18. Then There is no Account Number EQ Equifax 19. It actually has a Debt to Credit ratio, and at 100 %? It can not because it is not a Creditor. 
20. It escapes the Summary views with the CLOSED actually and literally, impossible 21. Account Status as per Metro2 this is an INVALID Value for Debt Collectors 22. Pay History Can not apply to a Debt Collector as there is no contract, and Metro2 forbids this from being sent. 
XXXX3. Balance History Can not apply to a Debt Collector as there is no contract, and Metro2 forbids this from being sent. But you, XXXX, send it. 
24. Rating History - Can not apply to a Debt Collector as there is no contract, and Metro2 forbids this from being sent. But you, XXXX, send it. Debt to Credit Ratio, Available Credit, Balance, Pay and Rating History - Can not apply to a Debt Collector as Per Metro2 25. Almost every field in the Account Details, can never Apply to a Debt Collector a. Loan Type Can not Apply as Per Metro 2 b. When reporting in this section Creditor Classification is allowing this XXXX XXXX  record, to report as a Bank Card -, from a Creditor c. Equifax because you are allowing it its then so impactful, even when paid- the damage is for the duration of the tradeline. 
d. Your algorithms pick this up it can be demonstrated. 

There is so much more to what is occurring, I will/can demonstrate it, as it is needed. 
If it is happening to me it is happening to all and is systematic. 
This took me a while to figure out but now I get it. 
I hope/know everyone else does/will get it too.

Company response to consumer: Closed with explanation