Consumer complaint received 2023-09-21
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: MI
Product: Credit reporting or other personal consumer reports
Sub-product: Credit reporting
Issue: Improper use of your report
Sub-issue: Credit inquiries on your report that you don't recognize

Complaint:
NOTICE TO AGENT IS NOTICE TO PRINCIPAL NOTICE TO PRINCIPAL IS NOTICE TO AGENT To : TransUnion You are in Violation of furnishing my consumer reports to person/s that do not have any permissible purpose or any legitimate business reason to receive those reports which is a clear violation of my right to privacy. 
XXXX On { XX/XX/XXXX } you furnished my consumer reports to { XXXX XXXX XXXX XXXX } without a permissible purpose as per 15 USC 1681b ( 2 ) or knowingly without a legitimate business reason pursuant [ 15 U.S.C 1681b ( a ) 3 ( f ) ( i ).

The Fair Credit Reporting Act ( FCRA ), [ 15 U.S.C 1681b ( a ) 3 ( f ) ( i )., for unlawfully furnishing my TransUnion consumer report on { XX/XX/XXXX } without my authorization or a permissible purpose under the 15 USC 1681b ( 2 ) Fair Credit Reporting Act ( FCRA } and its guidelines for permissible purpose.

A person shall not use or obtain a consumer report for any purpose unless ; 1. The consumer report is obtained for a purpose for which the consumer report is authorized to be furnished under this section.

2. The purpose is certified in accordance with section 1681b ( f ). Chester v. Purvis, 260 F. Supp 2d 711 ( S.D. Ind. 2003 ).

I hereby request pursuant rule 1002 the permissible purpose or legitimate business reason certification that authorized the furnish of my consumer report on { insert date } to { Insert company name that made the inquiry } Be advised the advisory opinion of BUREAU OF CONSUMER FINANCIAL PROTECTION 12 CFR Part 1022 Fair Credit Reporting ; Permissible Purposes for Furnishing, Using, and Obtaining Consumer Reports explains that the permissible purposes listed in FCRA section 604 ( a ) ( 3 ) are consumer specific, and it affirms that a consumer reporting agency may not provide a consumer report to a user under FCRA section 604 ( a ) ( 3 ) unless it has reason to believe that all of the consumer report information it includes pertains to the consumer who is the subject of the users request.

This advisory opinion also reminds consumer report users that FCRA section 604 ( f ) strictly prohibits a person who uses or obtains a consumer report from doing so without a permissible purpose.

The Bureau notes that disclaimers will not cure a failure to have a reason to believe that a user has a permissible purpose for a consumer report provided pursuant to FCRA section 604 ( a ) ( 3 ).

15 USC 1681b ( c ) Furnishing reports in connection with credit or insurance transactions that are not initiated by consumer ( 3 ) Information regarding inquiries ; Except as provided in section 1681g ( a ) ( 5 ) of this title, a consumer reporting agency shall not furnish to any person a record of inquiries in connection with a credit or insurance transaction that is not initiated by a consumer. 

I have not initiated any transaction with { XXXX XXXX }. 

616. Civil liability for willful noncompliance [ 15 U.S.C. 1681n ] ( a ) In general. Any person who willfully fails to comply with any requirement imposed under this title with respect to any consumer is liable to that consumer in an amount equal to the sum of ( 1 ) ( A ) or or damages of not less than {$100.00} and not more than {$1000.00} ; any actual damages sustained by the consumer I have been damaged as a result of your failure to follow the law I am requesting the DELETION of the inquiry that was placed on my TransUnion consumer report on { XX/XX/XXXX } by { XXXX XXXX } be removed immediately.

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 explanation