Consumer complaint received 2025-11-15 00:00:00
Product: Debt collection — I do not know
Issue: Attempts to collect debt not owed — Debt is not yours
Company: W&A Intermediate Co., LLC
State: MO

Complaint narrative:
This complaint concerns the derogatory collection account being furnished by XXXX XXXX XXXX ( XXXX ) to one or more of the nationwide consumer reporting agencies. The information reported by XXXX appears to be inaccurate, unverified, incomplete, and unsupported by proper documentation. XXXX has not demonstrated ownership of the debt, has not provided legally required validation under the Fair Debt Collection Practices Act ( FDCPA ), and has not complied with its obligations under the Fair Credit Reporting Act ( FCRA ). For these reasons, I am requesting that the Consumer Financial Protection Bureau investigate XXXX reporting practices and determine whether they are acting in compliance with federal law. 

The account being reported by XXXX is listed as a collection or charge-off with a past-due balance. XXXX claims to be collecting on a debt and is furnishing this derogatory information to the consumer reporting agencies. However, at no point has XXXX provided any of the documentation required to establish that the debt is legitimate, that the amount is accurate, or that XXXX has any legal right to collect or furnish information regarding this alleged debt. 

XXXX XXXX XXXX is a third-party debt collector. As such, the company is required to comply with the FDCPA and FCRA. Under the FDCPA, XXXX must validate the debt before continuing collection activity if a consumer requests validation. Furnishing information to a credit bureau is considered collection activity. I have not received any proof that XXXX provided validation, nor did XXXX supply any documentation when responding to my disputes filed through the credit bureaus. 

When I disputed the XXXX account with the credit bureaus, I expected a full reinvestigation as required under FCRA 611. Instead, the credit bureaus quickly marked the account as verified without providing any supporting documentation. A proper reinvestigation requires the bureau to review evidence submitted by the consumer, request documentation from the furnisher, and evaluate the accuracy of the information being reported. The speed of the bureaus responses suggests that they relied solely on automated information provided by XXXX through the e-OSCAR system. Automated responses do not meet the standard of a reasonable reinvestigation. 

XXXX has not provided : The original signed agreement or contract Copies of any original creditor statements An itemized account history showing charges, payments, and fees Documentation demonstrating the origin of the debt A complete billing ledger Proof of ownership or assignment of the debt A bill of sale referencing this specific account A chain of title if the debt was sold multiple times Documentation showing how the balance was calculated Proof of the date of first delinquency Any FDCPA-compliant validation notice Without these documents, XXXX can not legally verify or report the debt. 

There are serious concerns surrounding whether XXXX owns, was assigned, or is otherwise authorized to collect this account. Third-party collectors like XXXX can not report or collect on a debt unless they have proper documentation proving ownership or legal assignment. They must also be able to produce a chain of assignment showing how the debt was transferred from the original creditor to any subsequent buyers. 

If XXXX can not provide these documents, they can not legally furnish the account under the FCRA. 

Another major concern is the accuracy of the balance reported by XXXX. Debt collectors frequently receive incomplete, outdated, or inaccurate data from creditors. XXXX has not provided documents showing : How the balance was determined Whether late fees or other charges were added Whether any payments were applied Whether the debt was partially paid or settled previously Whether the original creditor charged off the account correctly Whether the balance includes unlawful or unverified fees Without documentation, XXXX can not prove that the amount being reported is accurate. 

Additionally, the reporting of the XXXX account raises concerns regarding the date of first delinquency. This date determines whether an account is legally reportable. Under FCRA 605 ( a ), no collection account can be reported more than seven years after the date of first delinquency. XXXX has not provided documentation establishing this date. If the date of first delinquency can not be verified, XXXX may be reporting obsolete information, which is a violation of the FCRA. 

XXXX is also required under FDCPA 809 ( b ) to provide a validation notice within five days of initial communication. This notice must identify : The amount of the debt The name of the original creditor A statement of the consumers rights Instructions on how to dispute the debt XXXX has not provided such a notice. Without it, they can not continue collection activityincluding credit reportinglegally. 

Another issue concerns whether XXXX is licensed to collect debts in the relevant jurisdiction. Many states require debt collectors to be registered, bonded, and licensed before collecting debts. If XXXX is collecting without proper licensing, they can not legally report a debt and can not legally pursue collection. 

The credit bureaus reinvestigation processes also raise concerns. Under FCRA 611, credit bureaus must conduct reasonable investigations and delete any information that can not be verified. The bureaus rapid responses suggest that they relied solely on XXXX automated verification rather than requiring the company to provide documentation. This is not a lawful reinvestigation. 

XXXX also had an obligation under FCRA 623 ( a ) ( 3 ) to notify the credit bureaus that the account was disputed. If XXXX failed to mark the account as disputed, this violates federal law. Furnishers can not continue reporting disputed information without providing dispute notifications to all bureaus. 

Additionally, furnishers like XXXX must conduct a reasonable investigation when notified of a dispute by a credit bureau under FCRA 623 ( b ). A reasonable investigation requires : Reviewing all information provided by the consumer Reviewing all relevant internal records Reviewing documents from the original creditor Correcting any inaccurate information Deleting information that can not be verified XXXX has not demonstrated that they conducted such an investigation. Their failure to provide documentation suggests that no meaningful investigation occurred. 

XXXX inaccurate reporting has caused harm, including : Denial of credit Higher interest rates Harm to creditworthiness Loss of financial opportunities Added stress and emotional distress Negative information from a debt collector carries significant weight with lenders. When unverified information is reported, the consequences for the consumer are severe. 

XXXX failure to provide documentation suggests that they are furnishing information without validating it. This violates FCRA 623 ( a ) ( 1 ) ( A ), which requires furnishers to report accurate information. Without validation, they can not prove that the information they are reporting is accurate. 

XXXX  reporting of unverified information also violates FDCPA 807, which prohibits false or misleading representations. Reporting a debt without documentation is misleading because it suggests that the debt is valid when the collector can not prove it. 

XXXX may also be violating FDCPA 808 by attempting to collect an amount that is not authorized by contract or law. Without documentation, XXXX can not demonstrate that the balance is lawful. 

Furthermore, XXXX may be reporting debts that are time-barred. If the debt is beyond the statute of limitations, it can not legally be pursued through litigation, and some states prohibit reporting of time-barred debts altogether. XXXX has not provided documents establishing that the debt is within the statute of limitations. 

XXXX failure to provide validation is a direct violation of the FDCPA. XXXX must cease all collection activityincluding furnishing to credit bureausuntil proper validation is provided. 

The companys lack of documentation suggests that they may not possess the records necessary to legally collect or report the debt. Debt collectors often purchase portfolios containing incomplete data. When they do not have original documentation, they can not fulfill validation requests. 

XXXX refusal or inability to provide documentation means that the credit bureaus must delete the unverified information under FCRA 611 ( a ) ( 5 ) ( A ).

In addition, if the original creditor recalled, settled, discharged, or closed the account, XXXX must stop reporting it. Without documentation, XXXX can not show that they are the lawful collector. 

There is also a concern that XXXX may have reported more than one variation of the same account. Duplicate reporting or inconsistent reporting is a known issue with debt buyers. If XXXX is reporting more than one version of the debt or if another collector is reporting the same debt, this may constitute multiple violations of the FCRA. 

Furthermore, XXXX reporting may not be consistent across all three credit bureaus. If they reported different balances, dates, or account statuses to different bureaus, this indicates a failure to maintain reasonable procedures for accuracy. 

Given all the deficiencies described above, XXXX has failed to meet its burden of proving the legitimacy of the alleged debt. Under federal law, XXXX must demonstrate : The debt exists They own or represent the owner of the debt The amount is accurate The data is complete and supported by evidence They are legally entitled to collect and report the debt They followed all FDCPA and FCRA requirements XXXX has demonstrated none of the above. 

For all these reasons, XXXXs reporting appears to violate : FCRA 602 ( a ) ( maximum accuracy requirement ) FCRA 607 ( b ) ( reasonable procedures requirement ) FCRA 611 ( reinvestigation requirements ) FCRA 623 ( a ) ( furnisher accuracy and dispute obligations ) FCRA 623 ( b ) ( furnisher reinvestigation obligations ) FDCPA 807 ( misrepresentation ) FDCPA 808 ( unfair practices ) FDCPA 809 ( b ) ( validation requirement ) The CFPB should investigate XXXX to determine whether it is acting within federal law and whether its reporting practices are unfair, deceptive, or abusive. 

Given that XXXX has not provided validation, has not demonstrated ownership, has not shown the debt is accurate, and has not provided documentation during reinvestigations, the information they are reporting is unverified. 

Under federal law, unverified information must be deleted.

Company response to consumer: Closed with non-monetary relief