Consumer complaint received 2018-08-17
Product: Credit reporting, credit repair services, or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Account information incorrect
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC. (NY)

While reviewing my credit reports, I noticed some inaccuracies on my student loan account. I called XXXX and requested copies of all forbearance requests for the lifetime of my loan. Once received, I confirmed that the information that had been reported was incorrect. On or around XX/XX/XXXX, I submitted mailed correspondence to XXXX regarding multiple late payments showing on 4 of my student loan accounts. As best as I could remember and now with the paperwork that I received from them, I was covered under forbearance during the dates that late payments were reported. I filled out all of the paperwork ( per their website ) required along with an explanation that the late payments should be removed. I also asked them to update the consolidation of my student loans as it currently showed that I owed double because the loans that were consolidated weren't updated to reflect a {$0.00} balance and closed. While checking my reports today, I saw that the individual loans have now been set to a {$0.00} balance and closed but the late payments were not removed. I called and spoke to a rep ( I do not recall his name ) that told me the only thing I could do is write another letter because they if they updated those accounts and didn't remove the late payments, they weren't going to at all. 

Here is what I sent to XXXX : According to my credit report, there were 6 late payments reported on 4 different accounts. The disbursement dates of these accounts are XX/XX/XXXX ( 2 accounts with that date ) and XX/XX/XXXX ( 2 accounts with that date ). Under Section 623 ( a ) ( 2 ) of the FCRA, I am requesting that these late payments be removed, and the record be reflected to an " on-time '' status for those months when the late payments were reported, the same as it does for any other forbearance or deferment period. I am making this request because my account was indeed protected under a General Forbearance during these dates. I've also enclosed documents from XXXX stating that these accounts were in Forbearance during the time these late payments were assessed. 

My credit reports states : XX/XX/XXXX - Late XX/XX/XXXX - Late XX/XX/XXXX - Late XX/XX/XXXX - Late XX/XX/XXXX - Late XX/XX/XXXX - Late Document from XXXX states : Sequences 001 through 004 were on General Forbearance from XX/XX/XXXX to XX/XX/XXXX. ( See enclosed. ) This clearly covers these dates. 

I have attached an FTC advisory opinion which interprets Section 623 ( a ) ( 2 ) of the  FCRA. The issue posed in the advisory opinion is how a lender is to handle a situation when subsequent information updates a report that was allegedly accurate when it was made but no longer is accurate in the present time. 

The advisory opinion states that the Section 623 ( a ) ( 2 ) of the FCRA addresses the duty to correct and update information by furnishers, or persons who furnish information to consumer reporting agencies ( CRA ) such as credit bureaus. In particular, this section requires a person that has furnished to a consumer reporting agency information that the person determines is not complete or accurate to promptly notify the consumer reporting agency of that determination and provide any information needed to make it complete and accurate. Thus, on its face, this provision requires a furnisher to provide corrected or updated information to the consumer reporting agency that it had reported to originally. This duty extends to all student loan accounts reported to CRAs, regardless of whether they were accurate at one point, because the section requires the furnisher both to update accounts as well as to correct. 

Additionally, since my loans have been consolidated, the balance on all previous loan that were included in the consolidation should reflect a {$0.00} balance. However, they are not, and it looks like I owe twice as much in student loans. Please update the correct balance information promptly to the credit bureaus.