Consumer complaint received 2023-12-27
Product: Credit reporting or other personal consumer reports — Other personal consumer report
Issue: Improper use of your report — Reporting company used your report improperly
Company: Early Warning Services, LLC (CA)

I hope this communication finds you well. I am writing to follow up on my previous correspondence with Early Warning regarding the violation of my rights under the Gramm-Leach-Bliley Act ( GLBA ) as well as the resulting financial injuries I have sustained. 

I have carefully reviewed Early Warning 's response dated XX/XX/, asserting that they do not offer direct-to-consumer products and citing the Fair Credit Reporting Act ( FCRA ) section 603 ( x ) as an exemption. While I appreciate their clarification, it is crucial to emphasize that the exemption under 15 U.S. Code 6802 ( e ) ( 6 ) is applicable only when the reporting is in accordance with the FCRA. Early Warning 's actions, as outlined in my previous communication, are in direct violation of the GLBA, and their reliance on inaccurate FCRA exemptions does not absolve them of their obligations under the GLBA. 

I wish to reiterate the specific violations and damages for which I seek resolution : Violation of GLBA Rights : Early Warning failed to provide the required disclosure and instructions for opting out of sharing my personally identifiable financial information with consumer reporting agencies, as mandated by 15 U.S. Code 6802. Violation of 16 CFR 313.3 ( o ) ( 2 ) ( B ) : Early Warning 's non-compliance with 16 CFR 313.3 ( o ) ( 2 ) ( B ) resulted in the improper sharing of perso
nally identifiable financial information without a clear and reasonably understandable notice being provided to the consumer. 

Violation of California Penal Code 530.5 : Pursuant to California Penal Code 530.5, Early Warning 's actions may constitute identity theft, as they obtained and used my personal identifying information without my consent, potentially violating the California Unfair Practices Act. 

Financial Injury : Early Warning 's failure to adhere to GLBA provisions and 16 CFR 313.3 ( o ) ( 2 ) ( B ) has caused significant financial injuries, including loss of opportunity, wages, and damage to my creditworthiness. 

Given the seriousness of these violations and the impact on my financial well-being, I have initiated a complaint with you, the Consumer Financial Protection Bureau XXXX CFPB ) to seek your intervention in this matter. I believe that your help is necessary to ensure a fair and just resolution. 

I kindly request your prompt attention to this matter, including : a. Immediate Removal of Financial Information : I demand the immediate removal of my financial information from consumer reporting agencies, as it was furnished without my consent in violation of the GLBA. 

b. Compensation for Damages : I reiterate my demand for compensation for the damages I have incurred due to the GLBA and California Penal Code 530.5 violations. 

I am filing this complaint against Early Warning for this egregious violation of privacy rights. This declaration serves as a testament to the intentional disregard for my explicit request and the ensuing harm caused by the unauthorized sharing of my nonpublic personal information. 

I trust that the CFPB will thoroughly investigate this matter and take appropriate action to ensure that my rights under the GLBA are upheld, and such unwarranted disclosures are rectified promptly. I appreciate your understanding of the gravity of this situation and your cooperation in resolving these issues expediently.