I Santander reported a charged off account to the credit bureaus, XX/XX/XXXX. 

II As is my lawful right in accordance with the Fair Debt Collection Practices Act ( FDCPA ), I sent via United States Postal Service, a letter requesting formal debt validation. This letter was dated XX/XX/XXXX ( Exhibit A validation letter sent to Defendant ) III Santander sent confirmation of correspondence datedXX/XX/XXXX 

IV XXXX failed to respond with any type of requested validation and failed to note the account with the National Credit Reporting Agencies as being disputed by consumer as is required by the FCRA ( Fair Credit Reporting Act ). The failure to note the account as being disputed is in violation of the FCRA, FDCPA, and an FTC ( Federal Trade Commission ) staff opinion letter which clearly states that the furnisher of information may not report an account to the credit reporting agencies during the pendency of its verification of the account to the debtor. 

V On or aboutXX/XX/XXXX, I sent via United States Postal Service Certified Mail, with return receipt requested, a second letter requesting formal debt validation. Santander signed for this correspondence onXX/XX/XXXX. 


VI Santander again failed to respond with any type of requested validation, but began calling to attempt debt collection, and failed to note the account with the National Credit Reporting Agencies as being disputed by consumer as is required by the FCRA. The failure to note the account as being disputed is in direct violation of the FCRA, FDCPA, and an FTC staff opinion letter which clearly states that the furnisher of information may not report an account to the credit reporting agencies during the pendency of its verification of the account to the debtor. 

VII Collection calls were received weekly from XX/XX/XXXX toXX/XX/XXXX in violation of FDCPA-section 809 part b, VIII On or about XX/XX/XXXX, I sent via United States Postal Service Certified Mail, with return receipt requested, a third letter requesting formal debt validation. Santander received this correspondence on XX/XX/XXXX 

IX During the period of time, from XX/XX/XXXX to XX/XX/XXXX, Santander failed to note the account with the Credit Reporting Agencies as being disputed by consumer as is required by the FCRA. The failure to note the account as being disputed is in direct violation of the FCRA, FDCPA, and an FTC staff opinion letter which clearly states that the furnisher of information may not report an account to the credit reporting agencies during the pendency of its verification of the account to the debtor. 

X On or around XX/XX/XXXX this account was reported as a repossession to TransUnion in violation of the FCRA, FDCPA, and an FTC staff opinion letter which clearly states that the furnisher of information may not report an account to the credit reporting agencies during the pendency of its verification of the account to the debtor. 

XI On or around XX/XX/XXXX, this account was reported as a repossession to XXXX in violation of the FCRA, FDCPA, and an FTC staff opinion letter which clearly states that the furnisher of information may not report an account to the credit reporting agencies during the pendency of its verification of the account to the debtor. 

XII On or aroundXX/XX/XXXX, this account was reported to as a repossession to XXXX in violation of the FCRA, FDCPA, and an FTC staff opinion letter which clearly states that the furnisher of information may not report an account to the credit reporting agencies during the pendency of its verification of the account to the debtor. 

XIII As ofXX/XX/XXXX, Santander reports the debt as closed and charged off. Between XX/XX/XXXX and XX/XX/XXXX the reported balance owed for the CHARGED OFF debt was increased to {$14000.00} as verified by credit reports. The debt itself is past the statute of limitation of 3 years for the State of MS and is therefore uncollectible. Continuing to report this account is also considered collection activity according to the FTC opinion letter and is also a violation of the FDCPA. 

XIV It has also been noted that there are discrepancies in the reporting of monthly activity on the Plaintiffs account upon closer examination of their credit reports. These discrepancies constitute inaccurate reporting of information to the credit reporting agencies which is also a violation of the FCRA. 

XV Because of Santander 's blatant disregard for the XXXX rights as allowed by the FCRA, the XXXX have been denied credit. Santander has also hampered our ability to obtain a mortgage. 

XVI These actions on the part of Defendant demonstrate a willful non-compliance, as per FCRA and also constitute a blatant attempt to injure or ruin our credit rating since Santander has demonstrated an inability to validate the alleged debt in a timely manner ; reported inaccurate information ; changed the status of the account to repossession ; attempted to coerce payment by phone call and by continuous reporting of activity, after the XXXX Statute of Limitations ; and subsequently increased the debt to {$14000.00} after the XXXX Statute of Limitations.