Consumer complaint received 2021-07-11
Company: Bread Financial Holdings, 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:
I am XXXX XXXX, and the author of this complaint. 

Please note that although this account has been disputed the tradeline is not marked as such with the CRAs, and as it should be. 

This is not and has never been, a request for Validation of Debt ( referred to as VOD ). I do not and have not asked for any VOD documents. Instead, this complaint has always been about FCRA and FCDPA and your responsibilities as a Data Furnisher and the ONLY Creditor tied to this tradeline, and as the Original Creditor ( owner of this record ). 

Please REPORT any clarity you would then like to draft a letter for, and this is what the complaint is about. 

This complaint includes the CRAs, for now XXXX  and XXXX. All I have access to is the result of whatever you all are doing/not doing, the gap in my space is that I neither produce the file, nor am I the end system/recipient of the data in the integration/file. 

This complaint is long detailed and tied specifically to the data elements existing within my credit report ( s ) and its compliance with Metro2 Guidelines and that of Data Accuracy with the CRAs, FCRA. 
I will say if it is happening to me, its systematic CFPB, and then happening to all customers with an adverse account. 

There is an Original Complaint with Comenity including XXXX, and the ID is XXXX. That complaint was created because of missing data on this tradeline, and inaccurate data. This current complaint is with XXXX ONLY. 

Each additional Comenity Creditor/Lender/Original Creditor/Credit Grantor Tradeline on my report, will be communicated distinctly and then with its own complaint. 

Your response to the original complaint is posted below. 
We're no longer the creditor on the accounts. Contact information for the new creditor is included in the uploaded response letter. We decline to delete the accounts from the credit report. Weve verified were reporting the accounts correctly to the credit reporting agencies. Were required to report factual information. 

Thank you for that response. 

You also attached responses, one of which is attached as XXXX XXXX-Final Response CB ( 1 ) Added XXXX CFPB, a section of it is pasted below. 

Were reporting the accounts correctly, as required by law. Weve verified that were reporting the correct information regarding account closure dates, first delinquency dates, account number, payment history, date of last activity, etc. Additionally, although the accounts are closed, we do advise the credit reporting agencies of the credit limit on the account. For more information on how the credit reporting agencies may reflect this information, or general questions about information in your credit report, please contact the credit reporting agencies by using the following information : Comenity ( Original/Only Creditor ) - I am relying on the FTC rules that govern you, as a both the Original Creditor/ Lender and Data Furnisher on this tradeline. 

FTC Site Definition of Debt Collector/Creditor https : //www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/fair-debt-collection-practices-act-text You will want to refer to section 803. Definitions ( 6 ) and ( 4 ) And then, ECFR, governance on your responsibilities are defined here. 

https : //www.ecfr.gov/cgi-bin/text-idx? c=ecfr & SID=89d50ede6e4072bde4d4a944a89bd200 & rgn=div5 & view=text & node=16:1.0.1.6.77 & idno=16 # se16.1.660_13 Few things of note with this complaint and then the response provided by Comenity. 
1. There is an absolute and then compliant difference between a Creditor/Lender/Credit Grantor and a Debt Collector 2. You Comenity, are both the Original Creditor and then, the only Creditor associated with the account. Your responsibilities as a Creditor, remain. 
3. Whoever you sold this account to becomes the Debt Buyer/Collector. See definition of a Debt Collector/Buyer 4. You are the Data Furnisher for this Tradeline and YOU are reporting data to this Tradeline and have created its current state. 
5. Your last reported date on my report is XX/XX/XXXX. 


I am attaching, as screen shots, and from many sources including raw credit reports from the CRAs themselves for your tradelines. 
Comenity, said in their original response : Weve verified were reporting the accounts correctly to the credit reporting agencies. Were required to report factual information. 

And Weve verified that were reporting the correct information regarding account closure dates, first delinquency dates, account number, payment history, date of last activity, etc. Additionally, although the accounts are closed, we do advise the credit reporting agencies of the credit limit on the account Thank you for providing and then acknowledging your commitment to accuracy, and then the data you sent/send to the CRAs. 
Comenity/Creditor/Original Creditor, is reporting this Tradeline To XXXX, sourced from a XXXX  as a raw Credit Report ( directly from the CRA, not online report ) XXXX, that results in this, see attached as : XXXX  Comenity XXXX  In Comments, Comenity reported Purchased buy another Lender - Paid in FULL Was Charge OFF, Question is it Paid Off? If so, how was {$0.00} sold? 
No account can exist with a Pay Status of Charge OFF, if it has been Paid off, as per Metro2 guidelines. Yours- does, and then contradicts itself. 
Your Pay History is now NULL/Blank ( XXXX communicated they sent/send it ) Its filled with X from the accounts inception. 
X is UNKNOWN Attached as XXXX Pay Rating That 30, 60,90 day late etc is not reported. 
Last Payment made XX/XX/XXXX, How much? What then became the balance? 
What accrued from that date? 
There is no Pay History/Rating There is no Balance History Your last reported date is XXXX 2 years of all were within your systems to report its history. 
Lacking a complete and accurate Tradeline what is the Date of First Delinquency ( DOFD ), you Comenity REPORTED? 

I then, dispute the FCRA DOFD and based on your reporting in this incomplete and inaccurate Tradeline. I also assert this tradeline is both incomplete and inaccurate. 

Then another source, You, Comenity/Creditor are reporting this Tradeline at XXXX  XXXX attached as : XXXX  XXXX XXXX 2 XXXX, and XXXX  XXXX XXXX XXXX XXXX 1. Last Payment made XX/XX/XXXX 2. For what charges? 
3. Where is the Balance History?

4. Where is the Pay History/Pay Rating?

5. Remarks/Comments do not match whats on XXXX raw report. 
6. Because there is absolutely no history XXXX  is saying that there is no Late Payment History XXXX  Raw credit report from XXXX Attached as XXXX Comenity XXXX  1 and XXXX XXXX XXXX  2 1. The Account Number is NULL, or Blank on the raw credit report, XXXX from XXXX 2. This Account Name states that this account is CLOSED 3. This account then lacks a Closed Date? 
4. What is then Reported, as the Date Closed? 
5. This Tradeline is then also reporting Available Credit, when this value is diverted, to a field called High Credit when an account is CLOSED as per Metro2 definition 6. The Pay/Ratings History is BLANK 7. The Balance History BLANK 8. Please ensure the Balance History is complete and then accurate on this tradeline leaving these values NULL/Blank, makes this inaccurate and incomplete 9. Please ensure the Pay History, is complete and then accurate on this tradeline leaving these values NULL/Blank, makes this inaccurate and incomplete 10. Because this account is charged off/closed, I do not believe there are applicable TERMS that can be reported, for repayment and on a closed account. 
11. Creditor Classification is Unknown and should not be, please assign a valid value. 
12. Date of First Delinquency neither is not supported by the PAY/Rating history nor the Balance History. 
13. I therefore dispute the FCRA/DOFD Date 14. There is then no Charge OFF Amount 15. Again DATE CLOSED is Blank XXXX XXXX XXXX XXXX XXXX  Comenity XXXX  2 XXXX  Online credit report from XXXX Attached as XXXX  XXXX XXXX XXXX Comenity XXXX  2 and XXXX  - XXXX XXXX  Comenity XXXX  This Account Name states, and then stores the account as CLOSED This account then lacks a Closed Date? 
What is then Reported, as the Date Closed? 
This Tradeline is then also reporting Available Credit, when this value is diverted, to a field called High Credit when an account is CLOSED as per Metro2 definition The Pay/Ratings History is BLANK The Balance History BLANK Please ensure the Balance History is complete and then accurate on this tradeline leaving these values NULL/Blank, makes this inaccurate and incomplete Please ensure the Pay History, is complete and then accurate on this tradeline leaving these values NULL/Blank, makes this inaccurate and incomplete Because this account is charged off/closed, I do not believe there are applicable TERMS that can be reported, for repayment and on a closed account Creditor Classification is Unknown and should not be, please assign a valid value. 
Date of First Delinquency neither is not supported by the PAY/Rating history nor the Balance History. 
I therefore dispute the FCRA/DOFD Date There is then no Charge OFF Amount Again DATE CLOSED is Blank This complaint demonstrates the data issues between Comenity and then the CRAs. 

This is not my battle, unless it goes to court. 

The Data exchange between the OC and the CRA with due diligence, and or discovery can and will flush this out. XXXX in theory verifies the true expected results Comenity is saying is acceptable. 

Fix the tradeline, to ensure Comenitys goal is attained or delete it.

Company response to consumer: Closed with non-monetary relief