I am submitting a complaint to the Consumer Financial Protection Bureau ( CFPB ) for resolution of my current status in the XXXX XXXX XXXX XXXX XXXX ( XXXX ). In XXXX, XXXX, I filed a complaint with CFPB which resulted in a partial but inadequate update to the number of Qualifying Payments towards XXXX  by XXXX XXXX ( XXXX ). XXXX continues to demonstrate a lack of ability to provide accurate data and has made no effort to rectify the situation or to act in good faith. 

Eligibility for XXXX is very straightforward, and has 3 components : XXXX. Correct type of loan and qualifying repayment status ; 2. Employment with eligible employer demonstrating XXXX XXXX ; and 3. 120 Qualifying Payments : on-time monthly payment satisfying monthly payment amount while employed full time at a qualifying employer starting XX/XX/XXXX. 

XXXX has determined that I am compliant with 2 of the 3 XXXX   components : 1. Correct type of loan and repayment status : All correspondence from XXXX has stated that my loan is both the correct type and has been in the same repayment status ( IBR ) since XXXX. 
2. Employment with eligible employer : XXXX has verified that my employment with XXXX qualifies as eligible. I have been in continual employment with XXXX since XXXX, XXXX. 
3. 120 Qualifying Payments : This is the point where XXXX is either using erroneous data or is deliberately obfuscating the data. When I initially requested eligibility analysis for their program, XXXX took 9 months to determine that I had 8 Qualifying Payments. Two months later, after I filed a complaint with CFPB, XXXX amended their analysis that I had made 8 payments, setting forth that I had made 98 Qualifying Payments, which is closer to accurate but remains erroneous. 

The following list summarizes XXXX incorrect calculations of Qualifying Payments in three correspondences showing : Date of Letter from XXXX ; Qualifying Payments ( as set forth by XXXX ) ; Estimated Eligibility Date ( as set forth by XXXX ) : XX/XX/XXXX ; 8 ; XX/XX/XXXX : XX/XX/XXXX ; 98 ; XXXX/XXXX/XXXX : XX/XX/XXXX ; 104 ; XX/XX/XXXX XXXX has consistently underestimated the number of payments I have made, changing their calculation only after I challenged their findings via CFPB complaint. XXXX has been unable or unwilling to disclose the source of their data. Additionally, the analysis XXXX provides in their correspondence of XX/XX/XXXX shows deliberately confusing data that misrepresents my employment with XXXX as 4 overlapping periods. 

Furthermore, XXXX has clearly ignored the clear data from US Department of Education showing I have been making monthly payments during the entire period of eligibility, from XX/XX/XXXX through present. 

My record from XXXX Department of Education, exported from MyStudentLoans.gov for myself, XXXX XXXX, shows active, regular payment status since XXXX. Data clearly shows deferral for a total of 5 months since XX/XX/XXXX : XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX & XX/XX/XXXX. These 5 months are subtracted from the calculation of my payment history, corroborated by the attached MyStudentLoans.gov data export. 
As of XX/XX/XXXX ( date of last application with qualifying employer verification ), I have made 124 Qualifying Payments. Start XXXX  Program ; XX/XX/XXXX ; Current Date of Verified Continual XXXX Employment through XX/XX/XXXX : Number of Months Total Months Deferred ( XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX & XX/XX/XXXX ) ; 5 ; Total Qualifying Payments Made to Date ; 124. 

Additionally, I am in continuing employment with the qualified employer, XXXX, and continue to make qualified monthly payments to date, bringing my number of Qualified Payments to 126 as of the date of this letter. 

In XX/XX/XXXX, I submitted an additional request for PSLF to XXXX to give them the opportunity to rectify their error, with no change in results. 

In conclusion, I request that CFPB investigate the deliberate use of incorrect and deliberately confusing data by XXXX. Based on the correspondence and data presented, XXXX is showing deliberate maleficence or neglect in its administration of the XXXX program. Authoritative data exported from the US Department of Education for my loans show that I have exceeded the number of Qualified Payments, I qualify for immediate forgiveness under the XXXX  program. 

Additionally, I expect refund of the payments ( which were, in fact, overpayments ) made since XXXX, XXXX, the month where I made my 120th Qualified Payment. This is clearly stated in the XXXX Application for Forgiveness, Form OMB No. 1845-0110, page 1, number 5.

I thank you for your time and attention to this matter.