Consumer complaint received 2025-09-12 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Problem with a company's investigation into an existing problem — Investigation took more than 30 days
Company: TD BANK US HOLDING COMPANY
State: FL

Complaint narrative:
Willful FCRA furnishing violations by TD Bank ; CRAs complicit via unreasonable reinvestigations and re-aging of Target card tradeline For nearly XXXX years, TD Bank has continued furnishing inaccurate and unverified information about my XXXX  credit card tradeline to XXXX XXXX XXXX XXXX Despite timely disputes and deletion demands, TD Banks reporting still shows re-aging, serial charge-off coding after the initial CO XXXX XXXX dispute flags, and missing Date of First Delinquency ( DOFD ) violations that the CRAs have accepted and propagated. 

XXXX & prior CFPB filing ( with attachments ) : XX/XX/XXXX : I disputed the TD Bank/Target tradeline with the CRAs. The XXXX FCRA 1681i window lapsed with no competent verification, yet the item remained. I subsequently sent formal deletion demands to XXXX XXXX XXXX XXXX ( each demand recites the XX/XX/XXXX dispute date and requests deletion for non-verification ). 



XX/XX/XXXX : I opened CFPB Complaint XXXX regarding TD Banks re-aging and continued negative furnishing ; TD Bank XXXX XXXX with explanation and refused to correct the tradeline. 

XXXX : My XXXX variance exhibit documents ongoing violations across all three CRAs ( missing XB dispute code, stale status updates, missing XXXX, over-limit reporting without suppression, and charge-off without validation ), totaling XXXX XXXX defects during XXXX XXXX XXXX XXXX XXXX 

Why this is UNLAWFUL ( specific provisions ) : ( Ongoing and Blatant Violations of Consumer Laws ) As Furnisher ( TD Bank ) : 15 U.S.C. 1681s-2 ( b ) ( FCRA ) : After CRA notice , TD Bank must reasonably investigate and correct or delete inaccurate data. Persisting with re-aged, unverified, and metadata-defective furnishing violates 1681s-2 ( b ). The absence of XXXX, XXXX CO coding post-closure, and failure to provide competent verification shows no reasonable investigation. 

Regulation V ( XXXX C.F.R. Part XXXX, Subpart XXXX Furnisher Rule ) : TD Bank must maintain reasonable accuracy and integrity policies and properly handle disputes ; the variance grid shows systemic integrity failures across fields CRAs rely on.

As CRAs ( Experian/Equifax/TransUnion ) : 1681i : Failure to conduct a reasonable reinvestigationaccepting one-word e-OSCAR verified responses without obtaining documents ; failure to delete when the furnisher can not verify within the statutory period.

1681e ( b ) : Failure to follow reasonable procedures to assure maximum possible accuracy where DOFD is missing/incorrect, dispute codes are absent, and status updates are stale. The CRAs have thus been complicit in publishing the ongoing inaccuracies.

Re-aging & DOFD : 623 ( a ) ( 5 ) / 605 ( c ) require accurate DOFD and prohibit re-aging to extend obsolescence. TD Banks serial charge-off coding and missing DOFD contravene these requirements, and CRAs ongoing publication further injures me.

If any third-party collector/debt buyer is involved ( e.g., assignment/servicing ) : FDCPA 1692g ( b ) ( continued collection/furnishing without validation ) and 1692e ( 8 ) ( failure to communicate that a debt is disputed ) are implicated when reporting/collection continues during unresolved validation. ( I request regulators confirm whether TD Bank or any assignee furnished during validation gaps. ) Pattern & risk to consumers : TD Bank has previously been the subject of CFPB enforcement related to consumer-reporting issues, demonstrating the need for supervisory attention here. 


Harm : Prolonged score suppression, adverse credit terms/denials, and significant time and cost to correct obvious errorsdespite clear, timely disputes and deletion demands.

Company response to consumer: Closed with explanation