Consumer complaint received 2024-09-06
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: Experian Information Solutions Inc. (MI)

" We determined a payment extension for the Accounts was approved by XXXX on XX/XX/XXXX, which was retroactively applied for the months of XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX. However, an inadvertent error resulted in the extension not being communicated to the servicer of the Accounts until XX/XX/XXXX. " ( XXXX XXXX. to CFPB XXXX, XXXX XX/XX/XXXX ). 1. Account was in a " payment extension '' from XX/XX/XXXX thru XX/XX/XXXX. 
2. All accounts/tradelines XXXX XXXX  report on " on record until '' date of XX/XX/XXXX. 
3. Subtracting seven ( 7 ) years from that date yields the Date of First Delinquency ( " DoFD '' ), which would be XX/XX/XXXX. 
4. The DoFD, which is crucial in accurately and completely reporting any alleged charge-off of an account must fall within a 6 ( six ) month period, ie 180 day period that precedes the first " CO '' annotation in the payment history.

6. The DoFD reported if therefore facially inaccurate, ( via the " on record until '' date ) because it implies the initial default leading to charge-off, ie the first thirty ( 30 ) day past-due annotation in paymentt history in a sequence of late payment annotations, falls outside the six ( 6 ) month period preceding the CO annotations.

At minimum the " before '' and " after '' snapshots of the account/tradeline show that the accounts in the loan group were padded by one or two months by Experian and or XXXX, such that the purported DoFD and initial CO pmt rating would be within the required 6 months/180 days of one another. However, when this data was manipulated for many of the accounts the individual ( s ) manipulating the data miscounted by one ( 1 ) month, leaving even the manipulated data in contradiction with the DoFD as XX/XX/XXXX, vis a vis the " on record until '' date of XX/XX/XXXX, left seven ( 7 ) months between the DoFD and the first reported CO pmt rating for the affected accts, which reported the CO as XX/XX/XXXX. Other accounts left XXXX months, reporting the first CO annotation in XX/XX/XXXX, leaving six ( 6 ) months between the purported XXXX of XX/XX/XXXX and first CO annotation of XX/XX/XXXX. Several of the accounts affected by this were " updated '' to reflect a CO in XX/XX/XXXX, which while coinciding with the month XXXX alleges the accounts were charged-off, still is inaccurate given a CO relies upon a valid DoFD. 
The DoFD for all accounts still show report a DoFD of XX/XX/XXXX, which is patently false because the account payments were deferred per XXXX 's own acknowledgement in their XXXX XXXX response to CFPB XXXX. These are a string of serious errors which XXXX has repeatedly failed to detect and modify and delete under its 1681s-2 obligations, and errors Experian is required to detect and remove under its 1681e obligations. That neither XXXX nor Experian have deleted these accounts at the XXXX 's request after multiple direct and indirect disputes shows neither XXXX nor Experian have the policies and procedures in place to meet their respective obligations under 1681s-2, 1681e ( b ) and 1681i.