Consumer complaint received 2024-03-04
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. (NJ)

I am writing to file a formal complaint against XXXX XXXX, underscoring significant concerns related to potential violations of privacy laws, particularly emphasizing the lack of adequate disclosures regarding opt-out rights, and drawing attention to the provisions of The Privacy Act of 1974, 15 USC 6805, 16 CFR Part 313, 16 CFR 433.2, 5 USC 522a , and FCRA Sec 603 ( d ) ( 2 ) ( a ) ( I ). As a responsible credit cardholder, I expect financial institutions, such as XXXX XXXX, to uphold the highest standards of transparency, fairness, and compliance with pertinent regulations. Recent observations have raised serious concerns, necessitating a thorough investigation into the practices of XXXX XXXX. My primary concern revolves around the apparent lack of disclosure regarding consumers ' right to opt out of information sharing, a critical aspect of consumer privacy. Section 15 USC 6802 ( b ) ( c ) mandates financial institutions to provide clear explanations on how consumers can exercise their opt-out rights. However, it appears that XXXX XXXX XXXX may not be effectively communicating this crucial information to its cardholders. Furthermore, the absence of information regarding the option to opt out, a right afforded to consumers under 12 CFR 1016.7, is deeply troubling. This omission not only hinders consumers from making informed decisions but also raises questions about compliance with regulatory requirements mandating the provision of clear and accessible information regarding opting out. In addition to the lack of opt-out disclosures, my concerns extend to potential violations of the Fair Credit Reporting Act ( 15 USC 1681 ). Section 602a of this act underscores the importance of financial institutions exercising their responsibilities with fairness, impartiality, and utmost respect for consumer privacy. XXXX XXXX XXXX may not be fully compliant with these provisions. Moreover, the apparent lack of information regarding opt-out options may indicate a broader issue of insufficient privacy disclosures. Section 15 USC 1681C ( a ) ( 5 ), which explicitly prohibits financial institutions from disclosing certain adverse information without proper authorization, underscores the necessity for clear and explicit privacy disclosures, particularly in light of the provisions of The Privacy Act of 1974. Additionally, under 15 USC 6805, I note that the privacy notice included in the terms and conditions reveals the involvement of third-party companies, including XXXX XXXX  and transunion. This implies that my privacy rights may have been violated by XXXX XXXXXXXX under both The Privacy Act and the terms and conditions. I am also aware that 16 CFR Part 313 outlines requirements for financial institutions to inform consumers about their privacy practices and rights, and 16 CFR 433.2 further delineates specific requirements related to creditors and consumer leases. Furthermore, I emphasize the critical importance of 5 USC 522a, particularly in relation to identity theft. Protecting personal information is paramount in preventing identity theft, and XXXX XXXX must adhere to the highest standards in safeguarding consumers ' sensitive data. I suspect that XXXX XXXXXXXX may have falsely used my identity, and I draw attention to 5 USC 522a, which prohibits the unauthorized use of personal information. Adding to these concerns, XXXX XXXX appears to have violated FCRA Sec 603 ( d ) ( 2 ) ( a ) ( I ), as the law states that it is illegal to have a consumer report containing information solely as to transactions or experiences between the consumer and the person making the report. Any such violation contributes to a breach of consumer trust and a failure to adhere to the fundamental principles of consumer protection. Finally, I draw attention to 15 U.S. Code 1681s2 ( A ) ( 1 ) A, emphasizing the importance of furnishing accurate information to consumer reporting agencies. Any failure to ensure the accuracy of shared information may potentially contravene this stipulation. In light of these grave concerns, I urgently request that the Consumer Financial Protection Bureau conducts a thorough investigation into the practices and procedures employed by XXXX XXXX. Additionally, I implore the Bureau to address the lack of opt-out and privacy disclosures, considering The Privacy Act of 1974, 15 USC 6805, 16 CFR Part 313, 16 CFR 433.2, 5 USC 522a , and FCRA Sec 603 ( d ) ( 2 ) ( a ) ( I ), and take appropriate measures to ensure compliance with privacy laws and consumer protection statutes. I appreciate your attention to this matter and trust that the Consumer Financial Protection Bureau will take the necessary steps to safeguard consumer rights.