Consumer complaint received 2023-09-20
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. (TX)

Consumer Financial Protection Bureau ( CFPB ) Re : Formal Complaint Against TransUnion I. Introduction : I am submitting this formal complaint against TransUnion, a major credit reporting agency, for multiple violations of the Fair Credit Reporting Act ( FCRA ) and other federal laws. This complaint is further supported by the recent data breach, which serves as a testament to TransUnion 's negligence and disregard for consumer rights. 
XXXX. Background : TransUnion has consistently demonstrated negligence in their duty to provide accurate credit reporting. Their recent data breach further underscores their lack of commitment to safeguarding consumer data. Despite this breach, they failed to notify affected consumers promptly, exacerbating the potential harm. 

I. XXXX XXXX and Implications on XXXX XXXX XXXX 's recent data breach is a glaring testament to their negligence in safeguarding consumer data. This breach not only exposes sensitive consumer information but also casts significant doubt on their ability to verify and validate information accurately. Given this breach, how can consumers, like myself, trust TransUnion to maintain the integrity of our data? 
* FCRA XXXX ( c ) ( XXXX ) ( B ) : This section mandates agencies to disclose all information in the consumer 's file at the time of the request. Given the breach, it's unclear if TransUnion can provide accurate data, especially when they have repeatedly failed to verify the accuracy of my accounts. 
* XXXX XXXX : This act requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. The breach indicates a clear violation of this act, further eroding trust in TransUnion 's practices. 
XXXX. Specific Account Discrepancies and Violations Highlighting Address Discrepancy
A recurring theme in my disputes with TransUnion is XXXX address discrepancy WHICH THEY REFUSE TO UPDATE. My current XXXX address is XXXX XXXX XXXX, XXXX XXXX, TX XXXX. None of the creditors in question have this address on file, making it impossible for them to have verified any information related to these accounts. This is a clear violation of the FCRA 's mandate for accurate reporting. 
* XXXX XXXX XXXX - A collection of {$380.00} was previously removed from my credit report. However, TransUnion has allowed it to be reported again post-dispute, violating FCRA XXXX ( a ) ( XXXX ). How can this account be verified when the creditor doesn't have my correct address TO ALLOW ME TO BE NOTIFIED OF THIS COLLECTION? NO ADVERSE ACTION WAS SENT TO ME VIOLATING MY RIGHTS! 
* XXXX XXXX XXXX - This account, reporting a balance of {$23000.00}, was opened fraudulently on XXXX. They do not have my current address on file, making their claim of verification baseless. This is a direct violation of FCRA XXXX ( a ) ( XXXX ) ( A ), which mandates accurate reporting of information. NO ADVERSE ACTION WAS SENT TO ME VIOLATING MY RIGHTS! 
* XXXX XXXX XXXX Bank - Similarly, this account is fraudulent and can not be verified. TransUnion 's claim of verification is false, especially given the address discrepancy. This again violates FCRA XXXX ( a ) ( XXXX ) ( A ). NO ADVERSE ACTION WAS SENT TO ME VIOLATING MY RIGHTS! 
* XXXX XXXX - This account is illegally reporting with an open CFPB complaint - XXXX. TransUnion reported a repossession despite no late payments. The address discrepancy further emphasizes their inability to verify this information, violating FCRA XXXX ( a ) ( XXXX ) ( C ). NO ADVERSE ACTION WAS SENT TO ME VIOLATING MY RIGHTS! 

XXXX. Absence of Adverse Action Notices and Truth in Lending Act XXXX significant concern is the absence of adverse action notices for all the disputed accounts. The creditors do not have my correct address, XXXX XXXX XXXX, XXXX XXXX, TX XXXX, which means I never received any adverse action notices. This is a clear violation of the Fair Credit Reporting Act ( FCRA ) XXXX ( a ), which mandates that users be notified in the event of an adverse action based on information from a credit report. 
NO PROOF OF A PROCESS SERVER FROM THE XXXX WHICH IS REQUIRED BY LAW TO COLLECT DEBT!!!!!!!!!!!!!!!!!!! AND IN ADDITION TO THAT NONE OF THESE CREDITORS CAN PROVIDE A RECEIPT OF DELIVERY OF FIRST CLASS MAIL WITH OR WITHOUT SIGNATURE PROVING THAT THEY ACTUALLY SENT THESE ADVERSE ACTIONS TO ME!!!!!!!!! 


Furthermore, TransUnion can not shift the responsibility to me for not updating the creditors. The Truth in Lending Act ( XXXX ) ensures that consumers are provided with clear and accurate terms of credit. If creditors do not have the correct address, it indicates a failure in their due diligence, which is protected under XXXX. 

IV. XXXX XXXX XXXX and Reporting
It has come to my attention that TransUnion XXXX have received a financial charge from the creditors to report this information on their platform. this was done without my knowledge or without providing me an adverse action notice, it's a clear violation. TransUnion accepted financial incentives to report potentially inaccurate or unverified information, it further undermines their credibility and could be deemed illegal. 

XXXX XXXX. XXXX ( a ) ( XXXX ) 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. 

" The term 'person ' means any individual, partnership, corporation, trust, estate, cooperative, association, government or governmental subdivision or agency, or other entity. '' - XXXX U.S.C. XXXX ( b ) This definition clearly encompasses a wide range of entities, including corporations like TransUnion. Therefore, TransUnion, being a corporation, falls under the definition of a " person '' as per the FCRA and is subject to its provisions. 


TransUnion, despite its status as a " global company, '' is bound by XXXX federal laws, including the Fair Credit Reporting Act ( FCRA ), when operating within the United States and dealing with XXXX consumers. The FCRA was enacted to protect the rights of XXXX consumers regarding the collection, dissemination, and use of their credit information. As XXXX of the major credit reporting agencies in the XXXX, TransUnion plays a significant role in this process and must adhere to the FCRA to ensure the rights and privacy of XXXX consumers are upheld. Numerous global or multinational corporations have faced legal actions in the XXXX for not complying with XXXX laws. Being a " global company '' does not provide immunity from the legal and regulatory requirements of the countries in which a company operates. For a XXXX XXXX XXXX, trust is paramount. Suggesting that they are not bound by XXXX laws because of their global status can erode trust and harm their reputation among XXXX consumers and regulatory bodies. In summary, TransUnion 's global status does not exempt them from the obligations and responsibilities set forth by the FCRA or any other XXXX federal law. They are obligated to ensure accurate, fair, and lawful handling of credit information for XXXX consumers. 

Jurisdiction of XXXX : Any company, regardless of its global presence, must comply with the laws of the countries in which it operates. TransUnion operates within the United States and deals with XXXX consumers, it is bound by XXXX federal laws, including the FCRA. 

XXXX of XXXX : The FCRA was enacted to protect the rights of XXXX consumers regarding the collection, dissemination, and use of their credit information. TransUnion, as XXXX of the major credit reporting agencies in the XXXX, plays a significant role in this process. Thus, it is imperative for them to adhere to the FCRA to ensure the rights and privacy of XXXX consumers are upheld. 

Legal Precedents : There have been numerous instances where global or multinational corporations have faced legal actions in the XXXX for not complying with XXXX laws. Being a " global company '' does not provide immunity from the legal and regulatory requirements of the countries in which a company operates. 


Criminal Activities Committed by TransUnion XXXX in Safeguarding Consumer Data : TransUnion 's data breach exposed sensitive consumer information. 
Violation : XXXX XXXX - This act requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. 
Failure to Notify Affected Consumers : TransUnion did not promptly notify consumers about the data breach. 
Violation : Fair Credit Reporting Act ( FCRA ) XXXX ( c ) ( XXXX ) ( B ) - This section mandates agencies to disclose all information in the consumer 's file at the time of the request. 
XXXX of XXXX Incentives for XXXX : TransUnion accepted financial charges from creditors to report certain information on their platform without proper verification. 
Violation : XXXX XXXX. XXXX ( a ) ( XXXX ) Prohibition : ( A ) Reporting information with actual knowledge of errors. 
( B ) Reporting information after notice and confirmation of errors. 
Inaccurate XXXX of XXXX XXXX : TransUnion violated the FCRA by inaccurately reporting consumer accounts. 
Violation : FCRA XXXX ( a ) ( XXXX ) - 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. 
Bank XXXX : TransUnion knowingly engaged in deceptive practices to defraud a bank or another financial institution. 
Violation : XXXX XXXX. XXXX - Whoever knowingly executes a scheme to defraud a financial institution. 
XXXX XXXX : TransUnion used interstate wire communications to defraud consumers. 
Violation : XXXX XXXX. XXXX - Whoever, having devised a scheme to defraud, transmits by means of wire communication in interstate or foreign commerce, any writings for the purpose of executing such scheme. 
XXXX XXXX Violations : TransUnion engaged in a pattern of racketeering activity, such as accepting financial incentives for reporting, they could be in violation of the XXXX XXXX and Corrupt Organizations ( XXXX ) XXXX. 
Violation : XXXX XXXX. XXXX - It is unlawful for anyone employed by or associated with any enterprise engaged in, or the activities of which affect, interstate or foreign commerce, to conduct or participate in the conduct of such enterprise 's affairs through a pattern of racketeering activity. 


TransUnion 's inability or unwillingness to verify or admit to a data breach is a significant concern, especially given the stringent requirements of federal laws that mandate the protection of consumer data. 

Lack of XXXX Measures : TransUnion 's potential data breach suggests a lack of adequate security measures to protect sensitive consumer information. Such negligence not only exposes consumers to potential harm but also undermines the trust that consumers place in credit reporting agencies. 
Violation of the XXXX XXXX ( XXXX ) : The GLBA requires financial institutions, which includes credit reporting agencies like TransUnion, to ensure XXXX security and confidentiality of customer records and information. A data breach, especially XXXX that is not promptly addressed, is a clear violation of the XXXX 's Safeguards XXXX. 
FCRA Implications : The Fair Credit Reporting Act ( FCRA ) mandates that credit reporting agencies must use reasonable procedures to ensure the maximum possible accuracy of the information they collect and disseminate. A data breach can compromise the integrity of this data, leading to potential inaccuracies in credit reports. This not only violates the FCRA but also can have severe consequences for consumers, affecting their creditworthiness and financial opportunities. 
Erosion of XXXX : Credit reporting agencies play a crucial role in the financial ecosystem. Consumers, lenders, and various other entities rely on them for accurate credit information. A data breach, coupled with an inability or unwillingness to verify or admit to it, erodes this trust. It suggests that the agency might be more concerned about its reputation than about the consumers it serves. 
XXXX XXXX for XXXX XXXX : Beyond specific laws like the XXXX and FCRA, there's a broader federal mandate for companies to protect consumer data. Data breaches can lead to identity theft, financial fraud, and other forms of consumer harm. By failing to prevent a breach or address it adequately, TransUnion is not upholding its responsibility to protect consumers. 
In summary, TransUnion 's actions, or lack thereof, in the face of a potential data breach go against the very essence of federal laws designed to protect consumers. Their inability to verify or admit to the breach suggests a deeper systemic issue, potentially indicating a disregard for the very laws and standards that govern their operations. 


XXXX and XXXX : For a XXXX XXXX XXXX, trust is paramount. Suggesting that they are not bound by XXXX laws because of their global status can erode trust and harm their reputation among XXXX consumers and regulatory bodies WHICH CONTRAVENES THE FCRA XXXX XXXX TransUnion should be aware that all of these concerns, discrepancies, and violations of the Fair Credit Reporting Act ( FCRA ) and other XXXX federal laws are meticulously documented and on record. If these issues are not addressed and rectified immediately, the intention is to escalate this matter to the XXXX XXXX XXXX for the XXXX XXXX XXXX Texas, located at XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX, TX XXXX, by XXXX. This escalation will be for both civil and criminal action, seeking remedies for the harm caused.