Consumer complaint received 2021-08-19
Product: Credit reporting, credit repair services, or other personal consumer reports — Credit reporting
Issue: Problem with a credit reporting company's investigation into an existing problem — Investigation took more than 30 days
Company: Experian Information Solutions Inc. (MI)

XXXX XXXX has repeatedly supplied inaccurate information to the CRAs regarding these accounts and has demonstrated the information supplied is unverifiable. The CRAs have removed certain portions of the unverifiable information, specifically regarding payment history. However, statuses for both loan accounts continue to have negative derogatory indicators tied to the unverifiable data, such as reported CO, 90 day, 60-day, and 30-day indicators. This has been a consistent issue for nearly one ( 1 ) year. The billing history has been demonstrated to be in violation of CFPB interpretation of Regulation Z. Specifically XXXX XXXX EFS has failed to generate statements with the minimum duration between periodic statement dates as established by the first bill upon entering repayment, failed to generate statements at all, failed to cease billing activities during periods of deferment, failed to correct inaccurate information in credit files with the three ( 3 ) major CRAs : Experian, XXXX XXXX. 

For example, CRAs report one subgroup in the account as being ninety ( 90 ) days past-due in XX/XX/XXXX, and sixty ( 60 ) days past-due in XX/XX/XXXX. Yet, the CRAs were unable to establish the payment history for the months directly preceding XX/XX/XXXX and as such no payment information is reported. If the months directly preceding the derogatory indicator for XX/XX/XXXX could not be verified per the data-furnisher, XXXX, then the derogatory indicators for all successive months, inclusive of XX/XX/XXXX can not be proven as accurate because a jump-discontinuity from NR to sixty ( 60 ) days past-due because the period for which the derogatory indicators first started would be within the period for which the CRAs were unable to verify the accuracy of information supplied by XXXX. Likewise, the CRAs report the other subgroup in the account as being in a CO status as of XX/XX/XXXX and that status continues thru present. Yet, the CRAs were unable to establish the payment history for the months directly preceding XX/XX/XXXX and as such no payment information is reported. If the months directly preceding the derogatory indicator for XX/XX/XXXX could not be verified per the data-furnisher, XXXX, then the derogatory indicators for all successive months, inclusive of XX/XX/XXXX can not be proven as accurate, as a jump-discontinuity from NR to sixty ( 60 ) days past-due can not occur. Such a jump constitutes an arbitrary and capricious reporting of data in my credit files. Thus, the CRAs systems have already demonstrated the information supplied by XXXX for the two ( 2 ) subgroups in the loan account contain information that is patently incohate. 

Now, the CRAs have been aware of these issues for nearly a year. The majority of the time the CRAs have allegedly conducted an investigation using the e-OSCAR system. That automated system has allowed XXXX to continue to supply the CRAs with the inaccurate/unverifiable information. That is, the CRAs have received evidence demonstrating illegal business practices of XXXX EFS, they have been supplied with the findings of XXXX showing that these issues with XXXX reporting were exposed as far back as XXXX. Yet, the CRAs have enabled XXXX to continue to supply the inaccurate/unverifiable information. At this point the CRAs are complicit in XXXX poor business practices within the now defunct XXXX XXXX XXXX and are knowingly and willfully violating consumer protections outlined in the FCRA as currently amended.