Consumer complaint received 2024-11-08
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Problem with a company's investigation into an existing problem — Their investigation did not fix an error on your report
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC. (FL)

XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, FL XXXX XX/XX/XXXX To : Consumer Financial Protection Bureau ( CFPB XXXX XXXX XXXX TransUnion Subject : Follow-up Complaint : Credit Reporting Agencies Neglect of Federal Duty in Blocking FTC-Reported Information To Whom It May Concern , This formal complaint is a follow-up regarding the appearance of unauthorized accounts on my credit reports following data breaches involving XXXX, XXXX, and XXXX  XXXX. These breaches exposed my sensitive information, which has been subsequently used to open unauthorized accounts without my consent. The affected accounts are unlawfully reported on my credit file by XXXX, XXXX, and TransUnion, in clear contravention of federal law and obligations to block unauthorized information following an FTC identity theft report. 

Background on Unauthorized Accounts and Current Status On XX/XX/XXXX, I submitted an FTC identity theft report accompanied by proper identification and supporting documentation, with instructions for the credit bureaus to block all unauthorized accounts. Under 15 U.S.C. 1681c-2, consumer reporting agencies are required to block reporting of unauthorized information within four business days of receiving such a report. Despite this, the credit bureaus have failed to fully comply : TransUnion responded on XX/XX/XXXX but continues to report unauthorized accounts, specifically XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX XXXX XXXX, and XXXX XXXX XXXX. 
XXXX responded on XX/XX/XXXX yet continues to report all disputed accounts listed in my FTC report with no removals made. 
XXXX responded on XX/XX/XXXX but still reports XXXX XXXX XXXX and other unauthorized accounts listed in the FTC report. 

These omissions violate federal obligations and further enable deceptive practices by allowing unauthorized entries to continue appearing on my credit reports. 

Violations of the Fair Credit Reporting Act ( FCRA ) and Federal Deceptive Practices Under FCRA 15 U.S.C. 1681b, consumer reporting agencies and furnishers must have a permissible purpose to report an individuals credit information. As established in XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ), permissible purpose requires explicit consumer consent or legal justification. No such consent exists for the accounts in question, and their continued reporting by the credit bureaus facilitates an unauthorized and misleading representation of my financial profile. 

Moreover, as the FTC guidelines mandate prompt blocking of unauthorized accounts, the credit bureaus refusal to take appropriate action constitutes a deceptive practice. This omission not only misrepresents my creditworthiness but also directly contravenes the consumer protections set forth in FTC XXXX XXXXXXXX XXXX, XXXX XXXX XXXX. XXXX, where the FTC emphasized the bureaus responsibility to secure and correct consumer data following breaches. 

Case Law Supporting Compliance Obligations XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX. XXXX. XXXX ) highlights the requirement for accurate reporting and emphasizes agencies obligations to prevent inaccuracies, especially post-data breach. 
XXXX XXXX. XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) : The Supreme Court confirmed that agencies are liable for negligence if they fail to adopt reasonable procedures to maintain accurate consumer reports. 
XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX ( XXXX. XXXX. XXXX ) stresses that reporting inaccuracies can lead to liability under the FCRA, reinforcing the necessity of upholding accurate consumer data. 

Deceptive Reporting Implications of the XXXX, XXXX, and XXXX XXXX Breaches The XXXX, XXXX, and XXXX  XXXX breaches have exposed my personal information, enabling unauthorized account openings that remain unaddressed. In re XXXX XXXX XXXX XXXX, XXXX. XXXX ( XXXX XXXX. ) emphasized XXXX duty to secure consumer data, while the FTC XXXX XXXX XXXX case specifically required XXXX to improve its data security and consumer response protocols to prevent the misuse of breached information. These failures by the credit bureaus only exacerbate the consequences of data breaches, compromising consumer rights and enabling deceptive reporting practices. 

Demand for Immediate Corrective Action Due to the credit bureaus inaction, I am formally requesting : 1. Immediate removal of all unauthorized accounts on my credit reports from XXXX, XXXX, and TransUnion in full compliance with FCRA guidelines and FTC regulations. 
2. Written confirmation from each credit bureau, acknowledging the unauthorized nature of these accounts and affirming their permanent removal. 
3. Verification of compliance improvements to prevent unauthorized access, use, or reporting of my information in the future. 

This letter will also be submitted as a public record to highlight the continued importance of transparency, accountability, and adherence to consumer protection laws by the credit bureaus. I expect compliance with these requests and a timely resolution. 

Sincerely, XXXX XXXX XXXX