Complaint sub-issue: Account status incorrect

XXXX ) XXXX Statement on XXXX XX/XX/XXXX explaining WHY they do not have to provide billing statements and are not subject to FCBA per XXXX XXXX : " XXXX XXXX is not subject to the Fair Credit Billing Act ( FCBA ) because private student loans are repaid on a fixed schedule. " ; The FCBA was not a part of any complaint submitted to the CFPB to-date. Any billing error claimed is a result of breach of contract under the provisions XXXX entered into under the XXXX. The XXXX is quite clear on page XXXX section E ( 2 ) and page XXXX in that I am not required to make payments during periods of deferment/forbearance. However, XXXX XXXX XXXX by contractual agreement under the XXXX was to have provided me with periodic statements on a monthly basis during periods of deferment. The XXXX XXXX letter on XXXX letterhead makes clear that a deferment was applied to both subaccounts between XXXX XX/XX/XXXX and XX/XX/XXXX. XXXX ) While my XXXX student loans may not be subjected to the FCBA, they are subjected to the periodic statement regulations under XXXX XXXX XXXX - Definitions and Rules of Construction AND, per the XXXX statement of XXXX XXXX on XXXX XX/XX/XXXX, XXXX XXXX policy is to provide a minimum of twenty ( 20 ) days between statement generation and due-date. 

Zero statements were provided bwteen XXXX XX/XX/XXXX and XXXX XX/XX/XXXX, yet XXXX XXXX continued to mark the payments as delinquent for XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX, leading one ( 1 ) account to reflect as CO immediately after exiting the deferment noted in XXXX XX/XX/XXXX letter, and the other to be marked as ninety ( 90 ) days past-due. Furthermore, XXXX XXXX system did not generate statements over those aformentioned periods and upon login to the online system during that time no payment was indicated as due. That is the systems collectively registered that my accounts were in a disaster forbearance from XX/XX/XXXX through XX/XX/XXXX, and deferment between XX/XX/XXXX and XX/XX/XXXX, but the billing system continued to mark such periods as periods of deliquency. 

As XXXX XXXX XXXX wrote in his latest response on XXXX XX/XX/XXXX, XXXX XXXX is required to provide accuracy and fairness with ALL of its consumer accounts. That includes minimum periods between statements per XXXX XXXX own policy. The policy as stated by XXXX XXXX XXXX is a twenty ( 20 ) day minimum between statement generation date and due date. The duration between statement generation was constistently less than the minimum twenty ( 20 ) days beginning XX/XX/XXXX forward. Moreover, the inconsistency in billing, payment allocation/payment aggregation, and forbearance time allocation, and deferment time allocation, led to a divergence in behavior between billing, data ffurnished to the CRAs, and the wrongful CO for one subaccount, and wrongful payment behavior of ninety ( 90 ) days past-due for another. 

The " non-monetary relief '' that XXXX XXXX XXXX " provided '' along with his XXXX XX/XX/XXXX response was to conduct an off-cycle update to all three ( 3 ) CRAs, effectively supplying the CRAs with the same invalid/unverifiable information as has been supplied in prior periods. This is not accetable behavior and is indicative of the same haphazard processes, and systemic failures within XXXX XXXX as identified in XXXX.