Consumer complaint received 2024-01-29
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: TRANSUNION INTERMEDIATE HOLDINGS, INC. (PA)

Respondent research into the consumers complaint determined the following : A consumer dispute investigation was previously started on XX/XX/XXXX and did not include proof of identity and trafficking victim determination documentation from the consumer. As of XX/XX/XXXX a letter has been mailed to XXXX XXXX requesting additional information for proof of identity and trafficking victim determination documentation. Adverse Items still appear on my report. 

On XX/XX/XXXX, the Respondent has asked for additional information in order to make a victim determination and they have failed to remove the adverse items from my credit profile. They respondent has made an exception. This is in contradiction to the rules of the Bureau. Respondent has continued to evade being treated as Credit Reporting Agency. 
XXXX ( c ) of the final rule, the Bureau is not adopting any exceptions to the requirement that consumer reporting agencies block adverse information that resulted from trafficking. 
The Bureau does not believe that this provision of the TVPA conflicts with section 605C or the final rule since section 605C, among other things, does not require an official certification from the Department of Health and Human Services ( HHS ) in order to block adverse items of information from a consumer report that resulted from having been trafficked. Respondent Assigns continue to assert that Victim must get a Certification Letter. This is confusing. 
I did not provide any written documentation providing consent for my information to be sold. Specifically, my personal information is currently under a security freeze under all XXXX CRAs and has been reported to the FTC as stolen. 
Identifying information means any name or number that XXXXay be used, alone or in conjunction with any other information, to identify a specific person, including any : ( 1 ) Name, social security number, date of birth, official state or government issued driver 's license or identification number, alien registration number, government passport number, employer or taxpayer identification number ; ( 2 ) Unique biometric data, such as fingerprint, voice print, retina or iris image, or other unique physical representation ; ( 3 ) Unique electronic identification number, address, or routing code; or ( 4 ) Telecommunication identifying information or access device ( as defined in 18 U.S.C. 1029 ( e ) ).

- [ ] Consumer reporting agencies could, for example, require consumers to provide a social security number or card issued by the Social Security Administration, a certified or official copy of a birth certificate issued by the entity authorized to issue the birth certificate, or a copy of a driver 's license, an identification card issued by the motor vehicle administration, or any other government issued identification.

- [ ] 1022.142 ( b ) ( 6 ) ( i ) ( A ) is moved to 1022.142 ( b ) ( 6 ) ( i ) ( B ). The Bureau believes these court documents could include criminal record relief orders ( sealing, expungement, or vacatur of records ), civil suit decisions involving human trafficking, and restitution orders. Due to the sensitive nature involving victims of trafficking and because the Bureau does not believe the details surrounding ones victimization must be provided to consumer reporting agencies, consumer reporting agencies must accept these documents with redactions that omit any details that exceed what is sufficient to confirm an individual has been identified as a victim of trafficking.

- [ ] The Bureau believes this could include instances where victims of trafficking sue their traffickers using private right of action provisions under Federal or State victim protection laws where the court has conducted an initial review of the victims claim for purposes of a motion to dismiss or motion for summary judgment and the result is in favor of the victim. This approach could also allow more victims the opportunity to obtain a victim determination even in instances where the civil suit was dismissed without prejudice or not pursued because of intimidation by the trafficker against the victim.