Consumer complaint received 2025-07-08 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Account information incorrect
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: IL

Complaint narrative:
I am writing to formally dispute the accuracy, legality, and handling of the student loan records associated with my name and Social Security number under the Family Educational Rights and Privacy Act ( FERPA ) and the Fair Credit Reporting Act ( FCRA ). This letter serves as both a formal dispute under 15 U.S.C. 1681i and a privacy complaint under 20 U.S.C. 1232g.

I. Background and Summary of Dispute I recently reviewed my credit reports from Equifax, TransUnion, and Experian and identified inaccurate or unlawfully reported student loan information for account number XXXX XXXX XXXX XXXX XXXX, XXXX XXXX that : XXXX. Was disclosed without my consent in violation of FERPA ; XXXX. Is inaccurate or unverifiable under the FCRA ; XXXX. Was furnished to credit reporting agencies without appropriate documentation or legal justification ; XXXX. Has caused financial, reputational, and emotional damage. 



XXXX. Violations Under FERPA ( 20 U.S.C. 1232g ) FERPA prohibits the unauthorized release of education records, which include financial aid and loan records maintained by an educational institution or third-party servicer acting on its behalf. 

Key Violations : Unlawful Disclosure : My student loan information was shared with credit reporting agencies without proper consent or opportunity for review. 
Lack of Prior Notification : I was not notified before such disclosures were made, as required under 34 CFR 99.31 ( a ) ( 4 ). 
Third-Party Violations : If your institution or servicer disclosed information to collection agencies or CRAs without written consent or legal basis, you may have violated FERPA. 

Relevant Case Law : Owasso Independent School District v. Falvo, 534 U.S. 426 ( 2002 ) : Clarified the scope of education records, which includes records maintained by third parties acting on behalf of schools.

Gonzaga Univ. v. Doe, 536 U.S. 273 ( 2002 ) : While it limited private rights under FERPA, it confirmed institutions are accountable for unauthorized disclosures.

III. Violations Under the FCRA ( 15 U.S.C. 1681 et seq. ) Under the FCRA, data furnishers ( like student loan servicers ) must provide complete and accurate information and must investigate disputes in a timely and thorough manner. 

Specific Violations : 1681s-2 ( a ) : You are required to report accurate information. Inaccurate reporting of default, balance, payment history, or duplicate accounts is a direct violation.

1681s-2 ( b ) : After being notified of a dispute, you are legally obligated to investigate, correct, or delete incorrect data.

1681c ( a ) : Negative information beyond seven years ( or ten for bankruptcy ) must be removed. 

Examples of Inaccuracy : Misreported balances or delinquencies Loans listed multiple times Accounts showing defaults during forbearance or deferment Reporting loans that were discharged or forgiven Relevant Case Law : Cushman v. Trans Union Corp., 115 F.3d 220 ( 3rd Cir. 1997 ) : A furnisher must conduct a reasonable investigation after receiving notice from a CRA.

Dennis v. BEH-1, LLC, 520 F.3d 1066 ( 9th Cir. 2008 ) : Furnishers are liable for willful violations.

Lang v. TCF National Bank, 249 F. Appx 464 ( 7th Cir. 2007 ) : Inaccurate reporting and failure to investigate result in FCRA liability.

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation