Consumer complaint received 2024-10-23
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Improper use of your report — Reporting company used your report improperly
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC. (PA)

On XX/XX/year>, I submitted my original complaint concerning this dispute, under Complaint ID XXXX. 

Dear CFPB Staff, I am writing to address XXXX XXXX XXXX recent response, as provided by XXXX XXXX XXXX, regarding my dispute. I believe the response from XXXX mischaracterizes the nature of my complaint, and I would like to provide clarification to assist in the resolution of this matter. 

Nature of My Complaint : My dispute concerns XXXX XXXX XXXXXXXX XXXX failure to comply with the Gramm-Leach-Bliley Act ( GLBA ), specifically under 15 U.S. Code 6802, which governs the disclosure of nonpublic personal information to nonaffiliated third parties. My claim asserts that XXXX XXXX XXXX disclosed my nonpublic personal information, namely my transaction experience with them, to a nonaffiliated third party without first providing me the required disclosures and opportunity to opt out.

Nonpublic personal information, as defined by the GLBA, includes : ( i ) Information provided by a consumer to a financial institution ; ( ii ) Information resulting from any transaction with the consumer or any service performed for the consumer; or ( iii ) Information otherwise obtained by the financial institution.

The information at issue in my dispute falls under these categories, specifically involving my transaction history with XXXX XXXX XXXX. 

Nonaffiliated third party, as defined by the GLBA, refers to any entity not related by common ownership or corporate control with the financial institution. This means any entity that does not share common ownership with XXXX XXXX XXXX. 

Mischaracterization in XXXX XXXX : XXXX XXXX response suggests that my complaint concerns an attempt to opt out of credit reporting, which is not accurate. My dispute is not about credit reporting as governed by the Fair Credit Reporting Act ( FCRA ). Rather, it is focused on my right under the GLBA to opt out of the disclosure of my nonpublic personal information to nonaffiliated third parties.

Specifically, 15 U.S. Code 6802 requires financial institutions to : Provide a clear and conspicuous notice informing consumers that their nonpublic personal information may be shared with nonaffiliated third parties ; Offer consumers the opportunity to opt out of such disclosures before the information is shared ; and Explain how the consumer can exercise this opt-out right. 

XXXX XXXX XXXX has not provided me with the required notices, nor did they offer me the chance to opt out before sharing my nonpublic personal information.

Request for Resolution : I respectfully request that the CFPB assist in addressing the following concerns : XXXX XXXX XXXX must explain how and when my nonpublic personal information was shared with nonaffiliated third parties. XXXX XXXX XXXX should provide proof that they complied with the disclosure and opt-out requirements set forth under 15 U.S. Code 6802 of the GLBA. If they did not provide these required notices, I ask that the CFPB require them to take corrective action and ensure my opt-out rights are upheld moving forward.

I hope this clarification helps resolve the confusion regarding my original complaint. I appreciate your attention to this matter and look forward to a response from both the CFPB and XXXX XXXX XXXX. 

Sincerely, XXXX XXXX