Consumer complaint received 2018-05-31
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: MD
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: Their investigation did not fix an error on your report

Complaint:
Dear Sir/Madam of the Consumer Financial Protection Bureau, On XX/XX/XXXX and XX/XX/XXXX, I sent TransUnion correspondence requesting that they investigate several unknown accounts on my credit file, please see proof of the certified mail delivery. This request was in part related to the fact that I recently reviewed my credit report, and found several unauthorized accounts and have subsequently challenged the below alleged negative items and their right to publish such information without completeness of their summary record or providing verification proof of the below alleged items. 

Furthermore, it is important to note that they have simply stated The company that reported the information has certified to TransUnion that the information is accurate. The aforementioned statement does not fully comply with the regulations set forth in section 609 of the FCRA or the procedures set forth in in the Reinvestigation of Dispute [ 15 U.S.C. 1681i ].

Reinvestigation of Dispute [ 15 U.S.C. 1681i ], Section 611 ( a ) ( 1 ) ( A ) - In general. Subject to subsection ( f ), if the  completeness or accuracy of any item of information contained in a consumers file at a consumer reporting agency is disputed by the consumer and the consumer notifies the agency directly, or indirectly through a reseller, of such dispute, the agency shall, free of charge, conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate and record the current status of the disputed information, or delete the item from the file in accordance with paragraph ( 5 ), before the end of the 30-day period beginning on the date on which the agency receives the notice of the dispute from the consumer or reseller.

Moreover, they have failed to comply with Section 609 of the FCRA, as it states : Information on file ; sources ; report  recipients. Every consumer reporting agency shall, upon request, and subject to 610 ( a ) ( 1 ) [ 1681h ], clearly and accurately disclose to the consumer : ( 3 ) ( A ) Identification of each person ( including each end-user identified under section 607 ( e ) ( 1 ) [ 1681e ] ) that procured a consumer report. TransUnion has not provided relative information on my file, TransUnion has NOT reported the recipients, and most important they HAVE NOT clearly and accurately disclosed to XXXX XXXX XXXX the identification of each person ( including each end-user identified under section 607 ( e ) ( 1 ) [ 1681e ] ) that procured a consumer report. 

Due to their non-compliance to provide the above referenced items Im requesting they DELETE the following unknown accounts or I will be forced to follow through with my intent to file a civil lawsuit : XXXX XXXX XXXXT, Account XXXX {$16000.00} XXXX Account XXXX {$59000.00} XXXX, Account XXXX {$58000.00} XXXX, Account XXXX {$17000.00} XXXX Account XXXX {$49000.00} XXXX Account XXXX {$19000.00} Finally, I have tried repeatedly to contact TransUnion and each creditor directly and have not had any success. Therefore, I ask that the CFPB enforce TransUnions non-compliance with the FCRA. Moreover, simply responding to a consumer inquiry does not FULLY comply with the regulations stated in section 607, 609 or 610 of the FCRA. In fact, TransUnion has failed to provide the requested information on two separate occasions, which specifically asked their organization to clearly and accurately disclose to XXXX XXXX XXXX the identification of each person ( including each end-user identified under section 607 ( e ) ( 1 ) [ 1681e ] ) that procured a consumer report. Therefore, as a matter of law  and fact these items should be deleted immediately. 

Additionally, I contacted TransUnion via certified correspondence requesting that they remove unauthorized inquires on my credit file. Furthermore, I made a feeble attempt to contact the creditors before contacting TransUnion. 

As stated in my XX/XX/XXXX letter to TransUnion, the creditor has not been able to provide ANY PROOF that I have initiated the inquiries, by written or verbal communication and has failed to provide permissible purpose. As such, none of these inquiries are based on a : 1. Response to the order of a court having jurisdiction to issue such an order, or a subpoena issued in connection with proceedings before a Federal grand jury.

2. written instructions of the consumer to whom it relates.

3. credit transaction involving the consumer on whom the information is to be furnished and involving the extension of credit to, or review or collection of an account of, the consumer 4. Employment purpose 5. Underwriting of insurance involving the consumer 6. Or in general a requirement of ANY PART OF LAW contained in the FCRA or state statute. 

It is quite apparent that TransUnion has not fully investigated either one of my claims as required utilizing Section 604 of the FCRA, Permissible Purposes of Consumer Reports 15 U.S.C. 1681b ( a ). TransUnion has simply stated that I must contact each creditor, which I have, but please be reminded that it is TransUnions duty to fully substantiate the information they are reporting on my credit file. 
Once again, I am asking TransUnion to kindly DELETE these inquiries from my credit report IMMEDIATELY, as there is absolutely NO EVIDENCE of my authorization, nor permissible purpose. 

Moreover, subject to subsection ( c ), any consumer reporting agency may furnish a consumer report under the following circumstances and no other : ( F ) otherwise has a legitimate business need for the information ( i ) in connection with a business transaction that is initiated by the consumer.

It is my request that the CFPB remind TransUnion that under 15 U.S.C. 1681i, Paragraph ( 5 ) Treatment of Inaccurate or Unverifiable Information ( A ) In general. If, after any reinvestigation under paragraph ( 1 ) of any information disputed by a consumer, an item of the information is found to be inaccurate or incomplete or can not be verified, the consumer reporting agency shall ( i ) promptly delete. 

This correspondence to the regulatory body that oversees this organization FURTHER represents the demand to uphold TransUnions legal responsibility to provide Valid Proof of Verifications and Completeness of records for the above inquiries you have on my consumer credit profile of the items listed above. Moreover, simply utilizing eOCAR shall not be sufficient, per fact and law.

MEMORANDUM OF POINTS & AUTHORITY : FAIR CREDIT REPORTING ACT 604, 609 & 611 FAIR AND ACCURATE CREDIT TRANSACTION ACT CONSUMER FINANCIAL PROTECTION BUREAU STATE OF MARYLAND CONSUMER CREDIT REPORTING AGENCIES ACT The following inquiries are at issue : 1. XXXX XXXX, XXXX XXXX 2. XXXX XXXX, XX/XX/XXXX 3. XXXX, XX/XX/XXXX 4. XXXX XXXX, XX/XX/XXXX  5. XXXX XXXX, XX/XX/XXXX 6. XXXX XXXX, XX/XX/XXXX 7. XXXX XXXX, XX/XX/XXXX 8. XXXX, XX/XX/XXXX 9. XXXX XX/XX/XXXX 10. XXXX XXXX, XX/XX/XXXX 11. XXXX, XX/XX/XXXX, XXXX 12. XXXX, XX/XX/XXXX XXXX. XXXX, XX/XX/XXXX Regards, XXXX XXXX XXXX

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