This complaint is based on violations of the FCRA, the FDCPA and the Massachusetts Consumer Protection Act ( hereinafter the MCA ), which includes 940 CMR sec. 7 and MGL Chapter 93A sec. 2, by XXXX XXXX ( XXXX ). 

___ On XX/XX/2018, I reviewed my credit reports and saw a collection account reported by XXXX XXXX claiming they purchased a debt from XXXX XXXX XXXX. I was never aware of this account and had no opportunity to dispute the debt prior to this period. 

___ On XX/XX/2018, I mailed to XXXX  a demand letter pursuant to M.G.L. Chapter 93A and a request for validation of debt. I requested all of the required materials under Mass. law 940 CMR 7.08 ( 2 ) and 209 CMR 18.18 ( 3 ). 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 ( 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 CFPB for consumers to request validation of an alleged debt. 

___ On XX/XX/2018, XXXX received my letter via certified mail. 

___ At no time did XXXX validate the debt by providing the required materials under Massachusetts law, nor did they provide the answers and documents as prescribed by the form letter issued from the website of the CFPB. 

___ On XX/XX/2018, I disputed the account thru the credit reporting agencies. My dispute included that ( a ) I had no knowledge of the account and ( b ) that XXXX failed to validate the debt as required by [ Massachusetts law ] and the Consumer Financial Protection Bureau. 

___ Between the dates of XX/XX/XXXX and XX/XX/2018, I received the results of the investigations from the credit reporting agencies, where XXXX had falsely verified the account, despite their failure to validate the debt as required by Massachusetts law and the FDCPA. 

___ XXXX  failure to validate the debt as required by state and federal law can only be construed that they do not possess the required materials to support its claims that they are owed this debt, including the accuracy thereof. 

___ In a recent decision against another debt buyer that verified information to a credit reporting agency without records to rely upon and where a consumer contested its ownership of, the court ruled as follows : [ a ] reasonable jury could find that the documentation reviewed was insufficient to prove that the [ two accounts ] belonged to [ plaintiff ] and that [ the buyer ] therefore had a duty to report the account as can not be verified. A jury could also find that because [ the buyer ] retained the right to seek account-level documentation through its agreements with [ the sellers ] [ it ] behaved unreasonably when it reported the accounts as verified without first exercising those rights. XXXX v. XXXX XXXX XXXX XXXX XXXX, XXXX al XXXX. XXXX ( XXXX. XXXX XXXX ) ___Based on the aforementioned facts ( and supported by the attached letter to XXXX ), XXXX  conduct includes the following : ___ ( a )  Violation of the FDCPA 15 USC 1692g in that they failed to cease collection of a debt that was timely disputed but not validated in that they verified a debt thru the credit reporting agencies. 

___ ( b ) Violation of the FDCPA 15 USC 1692 ( e ) in that they have taken action that can not legally be taken. 

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

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

___ ( e ) 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. 

___ ( f ) 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. 

___ ( g ) 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 to the credit reporting agencies. 

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

___ ( i ) Violation of 940 CMR 7.07 ( 8 ) and MGL c.93A, 2 in that they engaged in false, deceptive, or misleading representation, communication, or means in connection with the collection of a debt.