This complaint is based on violations of the FCRA, the FDCPA and the MDCPA ( including 940 CMR sec. 7 and MGL Chapter 93A sec. 2 ) by Diversified Consultants ( hereinafter DIVERSIFIED ). 

___ On XX/XX/2018, I reviewed my credit reports and saw a collection account reported by DIVERSIFIED on behalf of XXXX. 

___ On or around XX/XX/2018, I mailed to DIVERSIFIED a demand letter pursuant to Chapter 93A of the Massachusetts Consumer Protection Act. My demand letter advised DIVERSIFIED that they violated the MDCPA because they reported the account in a name other than that of the creditor in violation of 940 CMR 7.07 ( 21 ).  My demand letter sought the removal of the wrongly reported account from my credit reports ( a copy of my letter is attached to this complaint ). 

___ DIVERSIFIED received my letter on XX/XX/2018 via certified mail receipt number XXXX XXXX XXXX XXXX XXXX. 

___ My letter dated XX/XX/2018 also included a request for validation of debt. I requested all of the required materials under the Mass AG Debt Collection Regulations 940 CMR 7.08 ( 2 ). These materials include ( a ) all documents, including electronic records or images, which bear the signature of the debtor and which concern the debt being collected, and XXXX b ) a complete transaction history which reflects the date and amount of payments, balances, and charges concerning the debt. My letter also included the very same form letter provided on the website of the Bureau of Consumer Financial Protection ( BCFP ) for consumers to request validation of an alleged debt. 

___ At no time did DIVERSIFIED reply to my Chapter 93A demand letter nor did they validate the debt by providing the answers and materials listed in the BCFP form letter. 

___ On XX/XX/2018, I disputed the account thru the credit reporting agencies. My dispute included that I had no knowledge of the debt, and that DIVERSIFIED failed to validate the debt as required by the FDCPA, the MDCPA, the requirements set forth in the form letter provided by the BCFP, and that they reported the account in their own name, in violation of 940 CMR 7.07 ( 21 ). 

___ On and/or after XX/XX/2018, I received the results of the investigations from the credit reporting agencies, where they advised me that DIVERSIFIED had falsely verified the account ( while failing to validate the debt as required by state and federal law ), and where they continued to report the account while identifying the name of their company, in violation of the MDCPA 940 CMR 7.07 ( 21 ). 

___Based on the aforementioned facts ( and supported by the attached certified letter ), DIVERSIFIED engaged on the following wrongful conduct : ___ ( a ) Violation of the FCRA 15 USC 1681s-2 ( b ) ( 1 ) ( A ) in that they failed to conduct a reasonable investigation of my dispute thru the credit reporting agencies. 

___ ( b ) Violation of the FCRA 15 USC 1681s-2 ( b ) ( 1 ) ( B ) in that they failed to review all relevant information provided in my dispute to the credit reporting agencies. 

___ ( c ) Violation of the FCRA 15 USC 1681s-2 ( b ) ( 1 ) ( E ) in that they failed to modify, delete, and/or permanently block the reporting of inaccurate or unverifiable information on my credit reports. 

___ ( d ) Violation of the FDCPA 15 USC 1692g in that they failed to validate the debt and have continued collection activity thru use of the credit reporting system.

___ ( e ) Violation of the MDCPA 940 CMR 7.08 ( 2 ) and MGL c.93A sec . 2 for continuing collection activity while failing to provide all of the required materials that would validate the debt under Massachusetts law.

___ ( f ) Violation of the MDCPA 940 CMR 7.07 ( 21 ) and MGL c.93A sec . 2 in that they reported the account in a name other than that of the creditor ___ ( g ) Violation of the FDCPA 15 USC 1692 ( e ) in that they have taken action that can not legally be taken.

___ ( h ) Violation of the FDCPA 15 USC 1692e ( 10 ) in that they employed false or deceptive means to collect a debt.

___ ( i ) Violation of the FDCPA 15 USC 1692e ( 2 ) ( A ) in that they misrepresented the character, amount of legal status of the debt.