Consumer complaint received 2024-01-21
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Information belongs to someone else
Company: CBC Companies, Inc. (CA)

My Only First & Last Name ( XXXX XXXX XXXX ) My Only Address XXXX XXXX  XXXX XXXX XXXXXXXX XXXX XXXX CA XXXX The last 4of my SSN XXXX XXXXXXXX My Only XX/XX/XXXX I have reached out to XXXX XXXX XXXX INNOVIS DATA SOLUTIONS XXXX XXXX via sign, certified letters and the debt collectors. I have also sent over a certified notarized affidavit of truth upon sending my letters, I spoke with representatives at XXXX  XXXX INNOVIS DATA SOLUTIONS XXXX XXXX about the fraudulent accounts and information that is consistently been on my consumer report, their investigation fixed nothing these are the accounts of the violations via FCRA and California consumer privacy act. I have reached out to the XXXX the FTC, the California and STATE ATTORNEY GENERAL AND California consumer protection and innovation 15 USC 1681| ( A ) ( 1 ) ( A ) ( a ) REINVESTIGATIONS OF DISPUTED INFORMATION ( 1 ) REINVESTIGATION REQUIRED ( A ) In general Subject to subsection ( f ) and except as provided in subsection ( g ), if the completeness or accuracy of any item of information contained in a consumer 's file at a consumer reporting agency is disputed by the consumer and the consumer notifies the agency directly, or indirectly through a reseller, of such dispute, the agency shall, free of charge, conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate and record the current status of the disputed information, or delete the item from the file in accordance with paragraph ( 5 ), before end of the 30-day period beginning on the date on which the agency receives the notice of the dispute from the consumer or reseller. According to 15 USC 1681e ( b ) it states this ( b ) Accuracy of report Whenever a consumer reporting agency prepares a consumer report it shall follow reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates. " So I then asked them to provide me a description of the investigation according to 15 USC 16811 ( 7 ) : ( 7 ) Description of reinvestigation procedure A consumer reporting agency shall provide to a consumer a description referred to in paragraph ( 6 ) ( B ) ( iii ) by not later than 15 days after receiving a request from the consumer for that description. But they did not do that as well either. I allege that XXXX XXXX INNOVIS DATA SOLUTIONS XXXX XXXX are in blatant violation of the following U.S. codes and legislation for the reasons specified : 15 USC 1692c ( b ) : Unauthorized communication with third parties about my debt. 15 U.S. Code 1681s-2 : Failure to correct and update inaccurate information in my consumer reports.XXXX XXXX INNOVIS DATA SOLUTIONS XXXX XXXX 15 U.S. Code 1681a ( 2 ) ( 1 ) : Misuse or misrepresentation of definitions and rules related to consumer reporting. 15 U.S. Code 1681 ( 3 ) ( e ) : Further misuse or misrepresentation of definitions and rules related to consumer reporting.XXXX  XXXX INNOVIS DATA SOLUTIONS XXXX XXXX 15 U.S. Code 1681i : Inadequate procedures for disputing the accuracy of my consumer reports. 15 U.S. Code 1681b : Unauthorized access or use of my consumer reports for impermissible purposesXXXX XXXX INNOVIS DATA SOLUTIONS XXXX XXXX. XXXX. XXXX Social Security Number Privacy and Identity Theft Prevention Act of XXXX : Unauthorized use or disclosure of my Social Security numbers. XXXX  XXXX INNOVIS DATA SOLUTIONS XXXX XXXX Section 326 of the USA PATRIOT Act : Failure to verify my identification by financial institutions.XXXX XXXXXXXX INNOVIS DATA SOLUTIONS XXXX XXXX Gramm-Leach-Bliley Act, Section 501 : Failure to ensure the security and confidentiality of my personal and financial information. XXXX XXXX INNOVIS DATA SOLUTIONS XXXX XXXX Gramm-Leach-Bliley Act, Section 502 : Unauthorized sharing of my non-public personal information with non-affiliated third parties. Gramm-Leach- Bliley Act, Section 504 : Non-compliance with federal regulations designed to enforce the act, thereby putting my personal and financial information at risk. Account Name XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX DEPT OF ED DEPT OF ED DEPT OF ED DEPT OFED DEPT OF ED XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Date Open Dollar Amount {$390.00} {$500.00} {$620.00} {$370.00} {$1000.00} {$100000.00} {$3500.00} {$6000.00} {$2300.00} {$2800.00} {$2000.00} {$9.00} XXXX {$2100.00} {$310.00} {$3100.00} {$44000.00} {$5000.00} {$1900.00} {$5300.00} XX/XX/XXXX, XX/XX/XXXX Account number XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX DATES XX/XX/XXXX, XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX, XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( Fraudulent address ) XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX XXXX XXXX CA XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX, CA XXXX 15USC 1681ad ) ( 2 ( A/i ) clearly states that transactions between the consumer and the Person/Corporation making the report is NOT included on the consumer reports. Yet XXXX is reporting this information.. The reporting of excluded information pursuant to 15USC 1681 a ( d ) ( 2 ) ( A ) ( i ) on a consumer report is a clear violation of Metro2 compliance. Provide me with the Metro2 compliance disclosure on reporting transactions to a consumer reporting agency. I need the transactions reporting as late, collection/charge-off status and any other derogatory information deleted from my consumer reports effective immediately. Before you think to reply that this account has been " validated '', let 's be clear that I am not asking you to validate or verify anything. So please do not respond by telling me that as a tactic to waste my valuable time. Some of the negative accounts have been placed in Collection/Charge-Off Status WITHOUT mailing me a copy of IRS form 1099-C Cancellation of Debt. XXXX XXXXXXXX INNOVIS DATA SOLUTIONS XXXX XXXX and the creditors reporting collections/Charge-Offs, late payments/other derogatory information in my consumer reports are in violation of 26 USC ss 6050P Returns Relating to the Cancellation of Indebtedness By Certain Entities. If this derogatory account information is not deleted from my consumer reports within 30 days, I will be forced to officially file IRS form 3949A : Information Referral AND IRS form 211 : Application For Award For Original Information Overview with the Internal RevenueService against ALL entities involved.XXXX XXXXXXXX INNOVIS DATA SOLUTIONS XXXX XXXX XXXX XXXX. -California Consumer Privacy -Act of XXXX [ 1798.100 - 1798.199.100 ] ( Title 1.81.5 added by Stats. 2018, Ch. 55, Sec. 3. ) -1798.106. Consumers Right to Correct Inaccurate Personal Information ( a ) A consumer shall have the right to request a business that maintains inaccurate personal information about the consumer to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. ( b ) A business that collects personal information about consumers shall disclose, pursuant to Section 1798.130, the consumers right to request correction of inaccurate personal information. ( c ) A business that receives a verifiable consumer request to correct inaccurate personal information shall use commercially reasonable efforts to correct the inaccurate personal information as directed by the consumer, pursuant to Section 1798.130 and regulations adopted pursuant to paragraph ( 8 ) of subdivision ( a ) of Section 1798.185. ( Added XX/XX/XXXX, by initiative Proposition 24, Sec. 6. Effective XX/XX/XXXX. XXXX XX/XX/XXXX, pursuant to Sec. 31 of Proposition 24. ) 1798.120. Consumers Right to Opt Out of Sale or Sharing of Personal Information ( a ) A consumer shall have the right, at any time, to direct a business that sells or shares personal information about the consumer to third parties not to sell or share the consumers personal information. This right may be referred to as the right to opt-out of sale or sharing. ( b ) A business that sells consumers personal information to, or shares it with, third parties shall provide notice to consumers, pursuant to subdivision ( a ) of Section 1798.135, that this information may be sold or shared and that consumers have the right to opt-out of the sale or sharing of their personal information** 1 See, e.g., 12 U.S.C. 5481 ( 12 ) ( F ), 5512 ( b ), 5514 ( c ), 5515 ( c ), and also Sub title E ( 12 U.S.C.5561 5567 ) ; 15 U.S.C. 1681s ( b ) ( 1 ) ( H ), ( e ). Authority over 15 U.S.C. 1681m ( e ) and 1681w are limited to the Federal banking agencies, the NCUA, the FTC, the CFTC, and SEC. 1. 15 U.S.C. 1681s. States can directly bring actions under FCRA. See 12 U.S.C. 1681s ( c ) .States can al so bring actions under the Consumer Financial Protection Act ( CFPA ) against covered persons and service providers based upon violations of federal consumer financial laws, including the FCRA . See Authority of States to Enforce the Consumer Financial Protection Act of 2010, 87 FR 31940 ( XX/XX/XXXX ). 2. 15 U.S.C. 1681n, 1681o. 3. See, e.g., Consumer Financial Protection Bureau, XXXX XXXX  ( Spring XXXX ), at XXXX, XXXX XXXX XXXX XXXX. XXXX. See, e.g., Complaint at XXXX, CFPB XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX  XXXX ( XXXX XXXX XXXX, XXXX ). 5. With respect to furnisherdirect disputes, see XXXX XXXX XXXX, XXXX ( XX/XX/XXXX ) ( Some industry commenters also suggested that the Agencies issue a model direct dispute complaint form, with some advocating that consumers be required to use the model complaint form. The Agencies decline to adopt these suggestions because such requirements would cause otherwise valid disputes to b e rejected as frivolous or irrelevant due solely to the consumer 's failure to meet a technical requirement that probably would be unknown to the consumer. ) 6. 15 U.S.C. 1681i ( a ) ( 3 ) ( A ) ( identifying which disputes the consumer reporting agency can determine to be frivolous or irrelevant ) ; 12 CFR 1022.43 ( f ) ( 1 ) ( identifying which disputes the furnisher can determine to be frivolous or irrelevant ). 7. 15 U.S.C. 1681i ( a ) ( 3 ) ( Consumer reporting agency frivolous or irrelevant determination ) ; 12 CFR 1022.43 ( f ) ( furnisher direct dispute frivolous or irrelevant determination ).

8. 15 U.S.C. 1681s-2 ( b ). See Brief for Consumer Financial Protection Bureau and Federal Trade Commission as XXXX XXXX Supporting Plaintiff-Appellant, XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX XXXX XXXX. XXXX XXXX ). XXXX. XXXX XXXX. XXXX ( a ) ( XXXX ) ( A ). XXXX. Consumer Financial Protection Bureau, Bulletin XXXX ( XXXX XXXX, XXXX ), at 1, XXXX XXXX XXXX ( alerting furnishers to the fact that consumer reporting agencies have begun forwarding images of relevant documentation to furnishers as part of the reasonable investigation of disputes ). 11. For example, a copy of a bill supporting the consumers dispute conveys information regarding the persuasiveness of a consumers dispute that data about the bill would not. 12. Federal Trade Commission, 40 Years of Experience with the Fair Credit Reporting Act : An FTC Staff Report with Summary of Interpretations ( XXXX. XXXX ), at XXXX, https : XXXX XXXX XXXX  ( XXXX does not comply with this provision if it merely indicates the nature of the dispute, without communicating to the furnisher the specific relevant information received from the consumer. For example, if the consumer claimed never late and submitted documentation ( such as cancelled checks ) to support his/her dispute, a CRA does not comply with the requirement that is provide all relevant information if it simply notifies the furnisher that the consumer disputes the payment history without communicating the evidence received. ). 13. 2115 U.S.C. 1681s-2 ( b ) ( 1 ) ( B ) Account Name NOTICE TO PRINCIPAL IS NOTICE TO AGENT IS NOTICE TO PRINCIPAL XXXX XXXX INNOVIS DATA SOLUTIONS XXXX XXXX ( XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX DEPT OF ED DEPT OF ED DEPT OF EDDEPT OFED DEPT OF ED XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Date Open Dollar Amount {$390.00} {$500.00} {$620.00} {$370.00} {$1000.00} {$100000.00} {$3500.00} {$6000.00} {$2300.00} {$2800.00} {$2000.00} {$9.00} XXXX {$2100.00} {$310.00} {$3100.00} {$44000.00} {$5000.00} {$1900.00} {$5300.00} XX/XX/XXXX, XX/XX/XXXX Account number XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX DATES XX/XX/XXXX, XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX, XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( Fraudulent address ) XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX  XXXX, CA XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX, CA XXXX : This is a notice to CEASE and DESIST of all illegal activities, including reporting which constitutes collection activities . This is also a NOTICE exercising my rights to prevent the processing of my personal data According to the fair Credit Reporting Act, Section 609 ( a ) ( 1 ) ( A ), you are requiredby federal law to verify through the physical verification of the original signed consumer contract- any all accounts you post on a credit report. Otherwise, anyone paying for your reporting service could fax, mail or email in a fraudulent account. I demand to see Verifiable proof ( an Original Consumer Contract with my Signature on it ) vou have on file of the account listed below. Your failure to positively verify these accounts hurt my ability to obtain credit. Under the FCRA, Unverified accounts must be removed and if you are unable to provide me with a copy of verifiable proof, you must remove the accounts listed Data Removal : Immediate removal of all my existing personal and financial information from your website, databases, and any affiliated entities. This request pertains to all data currently held by your organization. 2. Data Security for Future Interactions : Implement robust security measures to prevent unauthorized access to any new information that may be collected. This request applies to any future interactions I may have with your organization and is not in conflict with my request for the removal of existing data. 3. Transparency : Full disclosure of any third parties with whom my information has been shared, along with immediate cessation of such sharing. 4. Notification : Prompt notification to me of all actions taken to secure my information and prevent further violations. 5. Legal Compliance : Immediate review and adherence to all relevant U.S. codes and legislation cited in this affidavit to ensure full compliance. Non-Consent and Settlement : Final Warning and Unambiguous Clarification 1as you can see here again, they blatantly violate the ( FCRA15 U.S. Code 1681s2 - ) Responsibilities of furnishers of information to consumer reporting agencies U.S. Code Notes prev | next ( a ) Duty of furnishers of information to provide accurate information ( 1 ) Prohibition ( A ) Reporting information with actual knowledge of errors A person shall not furnish any information relating to a consumer to any consumer reporting agency if the person knows or has reasonable cause to believe that the information is inaccurate. ( B ) Reporting information after notice and confirmation of errors A person shall not furnish information relating to a consumer to any consumer reporting agency if ( i ) the person has been notified by the consumer, at the address specified by the person for such notices, that specific information is inaccurate ; and ( ii ) the information is, in fact, inaccurate XXXX XXXX INNOVIS DATA SOLUTIONS XXXX XXXX CONTINUE TO REPORT FRAUDULENT ACCOUNTS THIS makes you guilty and in violation of the False Claims Act ( FCA ) 31 U.S.C 3729- 3733. ( Debt Collector name is also in violation of 18 U.S.C 894 for using my consumer report with extortionate means as a way to coerce and swindle me into making payments on alleged debt not owed. I DID NOT AND DO NOT CONSENT these companies XXXX XXXX INNOVIS DATA SOLUTIONS XXXX XXXX furnishing this information to my consumer report. I did not give you authorization or permission to have my personal identifying information, which you have obtained by aggravated identity theft in accordance with 18 U.S.C 1028A. This is a notice to CEASE and DESIST of all illegal activities, including reporting which constitutes collection activities. This is also a NOTICE exercising my rights to prevent the processing of my personal data According to the fair Credit Reporting Act, Section 609 ( a ) ( 1 ) ( A ), you are requiredby federal law to verify through the physical verification of the original signed consumer contract-any all accounts you post on a credit reportXXXX XXXX XXXX INNOVIS DATA SOLUTIONS XXXX XXXX Otherwise, anyone paying for your reporting service could fax, mail or email in a fraudulent account. I demand to see Verifiable proof ( an Original Consumer Contract with my Signature on it ) vou have on file of the account listed below. Your failure to positively verify these accounts hurt my ability to obtain credit. Under the FCRA, Unverified accounts must be removed and if you are unable to provide me with a copy of verifiable proof, you must remove the accounts listed You are required to do what I am asking and block these transactions from being reported to my consumer report within 4 days from the date of the receipt of this notice. I look forward to your response. 15 U.S. Code 1681n - Civil liability for willful noncompliance U.S. Code Notes prev | next ( a ) In general Any person who willfully fails to comply with any requirement imposed under this subchapter with respect to any consumer is liable to that consumer in an amount equal to the sum of- ( 1 ) ( A ) any actual damages sustained by the consumer as a result of the failure or damages of not less than {$100.00} and not more than {$1000.00}. 15 U.S.C 1681 section 602 A. States I have the right to privacy. 15 U.S. C 1681 section 604 A. Section 2 : It also states a consumer given reporting agency can not furnish an account without my written instruction. 15 U.S.C 1692c Without the prior consent of the consumer given directly to the debt collector or the express permission of a court of competent jurisdiction, a debt collector may not communicate with a consumer in connection with the collection of any debt. A debt collector may not use unfair or unconscionable means to collect or attempt to collect any debt. Without limiting the general application of the foregoing, the following conduct is a violation. A debt collector may not use any false, deceptive, or misleading representation or means in connection with the collection of any debt. ( Account Name ) XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX DEPT OF ED DEPT OF ED DEPT OF ED DEPT OFED DEPT OF ED XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Date Open Dollar Amount {$390.00} {$500.00} {$620.00} {$370.00} {$1000.00} {$100000.00} {$3500.00} {$6000.00} {$2300.00} {$2800.00} {$2000.00} {$9.00} XXXX {$2100.00} {$310.00} {$3100.00} {$44000.00} {$5000.00} {$1900.00} {$5300.00} XX/XX/XXXX, XX/XX/XXXX Account number XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX XXXX XX/XX/XXXX DATES XX/XX/XXXX, XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX, XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( Fraudulent address ) XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XX/XX/XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX XXXX XXXX CA XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX XXXX CA XXXX XXXX cfpb XXXX. XXXX ( b ). 
XXXXXXXX XXXX XXXX XXXX XXXXXXXX, XXXX XXXX XXXX, XXXX ( XXXX XXXX. XXXX ). 
XXXX Consent Order at  XXXX XXXX, In re XXXX XXXX XXXX XXXX, XXXX ( XXXX XXXX, XXXX ) ( " Respondent also reported in approximately 250,000 instances that accounts had a current balance and simultaneously furnished contradictory information, suchas also furnishing information indicating that the accounts were paid in full. " ), XXXX XXXX XXXXXXXX XXXX  XXXX consent order, a long with other CFPB consent orders cited herein, relate to furnisher obligations under section 623 of the FCRA, but the underlying logical inconsistencies involved, a sdescribed here in, are illustrative examples of the types of inconsistencies that a credit reporting a gency 's reasonable policies and procedures to a ssure maximum possible accuracy should be designed to detect. 
XXXX XXXX Consent Order XXXX XXXX XXXX, In re XXXX XXXX XXXX, XXXX ( XX/XX/XXXX ) ( XXXX XXXX XXXX XXXX XXXX : XXXX XXXX XXXX ) XXXX XXXX XXXXXXXX increased hadntaly taken out. " ), XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX. XXXX, XXXX ( XXXX XXXX XXXXXXXX ) ( refusing to set aside a jury verdict finding that a consumer reporting a gency failed to follow reasonable procedures under FCRA section 607 ( b ) for failing to detect inconsistencies between a XXXX report containing derogatory information and an earlier May report on which such ate insidinaenare houses to east de finidergar teorida a the yarumisher that. 
purportedly reflects the month and year on which the delinquency being reported in connection with a consumer 's account commenced. 
21 15 U.S.C. 1681c ( a ).

22 15 U.S.C. 1681c ( a ) ( 4 ), ( c ) ./23 15 U.S.C. 1681s-2 ( a ) ( 5 ) ( A ). Under the FCRA, furnishers mustreport a Date of First Delinquency within 90 days of furnishing information regarding delinquent accounts being placed for collection, charged to profit or loss, or subjected to any similar action. Id. 
XXXXXXXX XXXX Consent Order XXXX  XXXX XXXX, In re XXXX XXXX XXXX, XXXX ( XX/XX/XXXX ) ( " Respondent furnished account data showing that the consumer account was current, such as reporting {$0.00} amount overdue or full payments madetimely each month, but then a lso furnished a [ Dateof First Delinquency ], a field that inaccurately indicated " internally inconsistent '' data, including reporting " [ Date of First Delinquencies ] for accounts that were current, paid in full ( and not delinquent immediately beforehand ), or previously delinquent but subsequently became current '' ).! 23 15 U.S.C. 1681s-2 ( a ) ( 5 ) ( A ). Under the FCRA, furnishers mustreport a Date of First Delinquency within 90 days of furnishing information regarding delinquent accounts being placed for collection, charged to profit or loss, or subjected to any similar action. Id. 
XXXX XXXX Consent Order at XXXX XXXX, In re XXXX XXXX XXXX, XXXX ( XX/XX/XXXX ) ( " Respondent furnished account data showing that the consumer account was current, such as reporting {$0.00} amount overdue or full payments madetimely each month, but then a lso furnished a [ Dateof First Delinquency ], a field that inaccurately indicated " internally inconsistent '' data, including reporting " [ Date of First Delinquencies ] for accounts that were current, paid in full ( and not delinquent immediately beforehand ), or previously delinquent but subsequently became current '' ).! FCRA. 
available atXXXX XXXX XXXXXXXX XXXXXXXX XXXX, XXXX XXXX, comment 8 ( " A [ consumer reporting agency ] must maintain procedures to a void reporting information with obvious lo gical inconsistencies, such as a credit account opened when the consumer was knownto be a minor. " ). FTC staffpublished the 40 Years Report, an updated compilation of past FTC interpretations of the FCRA, to coincide with the transfer of authority to the Bureau. Effective XXXX XXXX, the Dodd-Frank Act transferred rulemaking authority related to most of the FCRA to the Bureau, giving the Bureau the primary regula tory and interpretive roles under the FCRA. 
1.See, e.g., XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX CHILD IDENTITY THEFT : NEW EVIDENCE INDICATES IDENTITY THIEVES ARE TARGETING CHILDREN FOR UNUSED SOCIAL SECURITY NUMBERs ( XXXX ), available at XXXX : XXXX XXXX Consumer Fin. XXXX. XXXX, " CFPB Releases Tools to Protect Foster Care Children from Credit Reporting Problems '' ( XX/XX/XXXX ), available at XXXX : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX 31 15 U.S.C. 1681 ( b )XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX, XXXX XXXX XXXX. at XXXX. See also XXXXXXXX XXXX XXXXXXXX XXXX XXXX XXXX, XXXX XXXX XXXX. XXXX XXXX, XXXX ( XXXX. XXXX XXXX ) ( * [ R jeceiving a pparently inconsistent credit reports may trigger an obligation to investigate on the part ofthe credit reporting a gency .... [ because ] a llo wing credit reporting a gencies to act as nothing more than mere conduits of information would eviscerate the act 's em phasis on reasonable compilation procedures. '' ) ( citing XXXX, XXXX XXXX  at XXXX ) ; XXXXXXXX XXXX XXXX XXXX. XXXX, XXXX XXXX XXXX XXXX XXXX, XXXX ( XXXX Cir. XXXX ) ( " Courts have held [ consumer reporting agencies ] must look beyond information furnished to them when it is inconsistent with the [ consumer reporting agencies ' ] own records, contains a facial inaccuracy, or comes from an unreliable source. '' ).! See XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX  XXXX ; XXXX, XXXX XXXX XXXX, at XXXX. 
XXXX XXXX XXXX. XXXX ( b ) ; see also XXXX, XXXX XXXX at XXXX. 
XXXX FTC 40 Years Report, at XXXX, comment XXXX. 
XXXX XXXX XXXX. XXXX. 
XXXX XXXX XXXX. XXXX ( emphasis added ) .XXXX  XXXX INNOVIS DATA SOLUTIONS XXXX XXXX