Consumer complaint received 2021-03-24
Company: ENCORE CAPITAL GROUP 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. I am acting on my own behalf, and no one is acting on my behalf, through this portal XXXX - this is a complaint regarding your Credit Reporting/Metro2/Compliance - and with respect to FCRA and FDCPA mandates. Their rules/laws/mandates are clear. While this is my issue - what is occurring, is systematic and across all classes/people, and in full view as because of how consumer data is collected, entered into XXXX systems, stored and then reported/integrated to the CRAs. 

I am am a tech data integrator, a bit of a techie - and now I can see. 

The CFPB - should review this complaint, as any XXXX customer - is no doubt dealing with the same systematic/file FCRA/FDCPA incompliant issues. 

ALL Tradelines, on all reports are within the scope of this complaint. XXXX, XXXX, XXXX and XXXX and as applicable to the consumer, and their impacts, Those tradelines indicate you - XXXX, as the ACCOUNT NAME and owner. 

I believe they are in concert with you, your related companies and this industry. 

The request is simple - please fix all of them ( my accounts XXXX has reported ) and at each CRA so the tradelines are compliant - or delete each, at each CRA. 

If I know - you, XXXX et al, with a whole tech team, leaders and a whole IT QA team must. Your Metro2 files/integrations - to the CRAs, are historical and when/where applicable - discoverable. 

Your response to a XXXX complaint attached - XXXX ( I can spec to file, test and prove/fail ) - know this is not forensic - yet. 

This complaint is as follows : 1. XXXX, willingly and knowingly, is reporting to all CRA 's - as if they are a Creditor/Credit Grantor ( Factoring Company ). Attachment - Attachment - XXXX ( numbers 1 - 3 ) 2. XXXX, is NOT, in fact - Factoring company, by definition, law and then their own acknowledgements/statements. I rely on the FTCs definition of a CREDITOR/Debt Collector. 

3. Factoring Companies/Creditors - can send all data applicable, to a consumer account, as per the industry file standard - Metro2. Outside of a Header/Trailer record - and depending on the type of credit, and its duration - the fields that can be sent per tradeline- are in the 100s ( hundreds ). 

4. Debt Collectors - as per the industry file standard - Metro2 ( many sources ) are directed to populate approximately 19 fields. 

5. When reporting in XXXX ' fashion ( as if they are Factoring Company/Creditor ) - the tradeline egregiously/knowingly and illegally anchors a consumer report with a Creditor account, that has not been paid, starts with a C ( Collections ) and since the tradeline was opened, but forever erroneously with/by XXXX. Even when a consumer pays - the account then can never, ever be resolved and exists as it's intended to - unless it's deleted. 

6. Even though CRAs expressly define the SEGMENTS for COLLECTIONS, XXXX subverts the industry standard Metro2 - file specifications, and - lands in a space in the CRAs databases, where Creditors reside - and dutifully impacts consumers OPEN accounts, where calculations of scoring data is/are most impactful.

7. The impacts are broad - scores, CRAs calculation to display data - lenders assessing consumer worthiness and even with an orphaned/wholly inaccurate XXXX tradeline - that destroys scores, consumer worthiness and views of accurate information ( Your data as reported is used in High Data Usage/AmountPast Due/Payment History/etc ) 8. The views of this data - are actually quite magical - CLOSED is in the tradelines description, yet - no CLOSED DATE - intentionally confusing consumers on a report most don't even understand today. 

9. XXXX - is mandated to send their files/data in Metro2 Format, Attachment2 - from all major CRA 's demanding file/integration standards be of Metro2 Attachment 2 - CRA statements 10. Debt Collectors - are mandated through Metro2 - to send a header/footer and approximately 19 consumer fields ( see attachment 3 - exert from XXXX, know other sources reiterate the same details ) 11. Metro2 - and its usage is defined, and for Debt Collectors - and then Factoring Companies ( Attachment 3 - Tech Specs sample, there are more tech specs available ) - regardless of source, standards of usage of the file/ resulting integration is industry wide - First Name = First Name, Header/Footer Details, Account Name etc. 

12. Due diligence Mandated by FCRA - could resolve your technical reporting problems. The FILE SPECS are available - as are the rules. You also have your partnership with the CRA to test your requirements, to build, and as XXXX testing allows in standard XXXX, to ensure your data you send is accurate. Standard TECH QA methodology - would have caught your issues from inception, unless it was acceptable behavior. 

13. ALL CRAs have a section/segment for DEBT COLLECTORS 14. Why has yours, and why does your tradelines XXXX - fail to ever show up there? 


You are NOT a Factoring company. 

You are sending fields and file attributes, that can not apply to a Debt Collector There are no contracts/agreements with a debt collector for payment on reportable terms You are reporting Monthly Terms Original Creditor has a Field - you are using comments - or nothing at all Original Creditor Acct Number - is XXXX, when it must be retained and available for the consumer and the actual tradeline its reporting from, is never displayed FCRA.DOFD Dates are in fact made up by XXXX - and, worse inaccurate Balance - XXXX fluctuates Balances inside/outside of laws that govern them Terms - there are no such things as TERMS with a DEBT COLLECTOR Accounts have PAY HISTORIES - when they are never allowed, as per metro2 Accounts Rating/BALANCES Histories - when they are never allowed, as per metro2 Pay/Balances/Ratings, although never applicable - are always inaccurate You Reside in the OTHER ACCOUNTS Section/Segment of consumer reports, when its description says for Creditors ONLY Other accounts are those that are not already identified as Revolving, Mortgage or Installment Accounts such as child support obligations or rental agreements You intentionally - DO NOT REPORT in the COLLECTIONS Section of a consumer report - which is dedicated to you use, and its description 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. 
Your tradelines lack an ACCOUNT NUMBER Are Used to Calculate DEBT to CREDIT Ratio - when it is impossible to include this debt collection account Leverage a Creditor Classification field - of the alleged Original Creditors relationship - as a Retail Account, Installment Account etc. 
Description says CLOSED in the HEADER When it is NOT NO DATE CLOSED is supplied - to coincide with your description Original Creditor is WIPED OFF XXXX XXXX - Account Number is WIPED OFF XXXX XXXX XXXX responses are public/XXXX  - actually traceable. See attachment = Open Type - This is a summary of issues based on your reporting, and the assertion of a FCRA and FDCPA non compliance on many accounts, many times, and after complaints with the CRAs. 

This complaint also serves to you - XXXX, as a do not contact, and as allowed by law.

Company response to consumer: Closed with non-monetary relief