Consumer complaint received 2023-12-26
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: TN
Product: Credit reporting or other personal consumer reports
Sub-product: Credit reporting
Issue: Improper use of your report
Sub-issue: Reporting company used your report improperly

Complaint:
On XX/XX/XXXX, I utilized my rights under various federal laws ( including 5 USC 6802 ) to send an opt-out request to the three major credit reporting agencies : XXXX, XXXX, and TransUnion. The purpose of this request was to withdraw any consent, previously given in any form ( written, unwritten, verbal, and nonverbal ), for using and sharing my personal and financial information in relation to specific accounts on my consumer report. The accounts are as followed : XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Detailed Legal Framework : 1. 15 USC 6802 ( Gramm-Leach-Bliley Act ) : This statute is a key provision of the Financial Services Modernization Act, which requires financial institutions to provide customers with a privacy notice that explains the information collected, where it is shared, and how it is used. Importantly, it provides consumers the right to opt-out of their information being shared with nonaffiliated third parties. My request to XXXX, XXXX, and TransUnion was based on this right. 

2. Privacy Act of 1974 : This act establishes a code of fair information practices that govern the collection, maintenance, use, and dissemination of personal information about individuals that is maintained in systems of records by federal agencies. While primarily applicable to federal agencies, its principles are echoed in the consumer rights afforded under the FCRA, particularly regarding individuals ' control over their own personal information.

3. 16 CFR 313.7 ( Regulation P - Privacy of Consumer Financial Information ) : This part of the Code of Federal Regulations requires financial institutions to provide clear and conspicuous notice to consumers about their privacy policies and practices, describe the conditions under which a financial institution may disclose nonpublic personal information about consumers to nonaffiliated third parties, and provide a method for consumers to prevent such disclosures by " opting out. '' 4. 15 USC 1605 ( Consumer Financial Protection Bureau portion of the Truth in Lending Act, also known as Regulation Z ) : This section of the Truth in Lending Act is enforced by the CFPB and governs the transparency of consumer credit transactions. The CFPB 's portion includes rules for fair handling of credit reports and ensuring accurate and fair credit billing and credit card practices. It also includes the enforcement of penalties for non-compliance with these provisions. My complaint relates to this law 's provision for enforcing fair and accurate credit reporting practices.

Issues Encountered : Despite referencing these legal provisions in my opt-out letter and the ample time provided for the credit reporting agencies to respond and comply with my request, there has been no satisfactory acknowledgment or action. My personal and financial information continues to be handled in a manner that I believe is inconsistent with these legal provisions.

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 non-monetary relief