Consumer complaint received 2025-12-09 00:00:00
Product: Debt collection — Other debt
Issue: False statements or representation — Attempted to collect wrong amount
Company: Tiffany & Tiffany PLLC
State: NC

Complaint narrative:
This complaint concerns serious deficiencies, inaccuracies, and potentially deceptive practices by XXXX XXXX and its counsel, Tiffany & Brown, in their response to my prior CFPB complaint ( XXXX ). The company submitted non-original, incommplete, and unverifiable documentation to CFPB and the Virginia XXXX XXXX XXXX XXXX raising concerns regarding : recordkeeping violations, improper garnishment activity, failure to validate a debt under REGULATION F, misrepresentation to a federal agency, spoilation of financial records and noncompliance with XXXX standards that the legal counsel does not understand. Their document submission appears to misled regulators, obscure evidentiary gaps and circumvent their statutory duties under federal consumer law. 

XXXX and their legal counsel did not provide an original contract or authoritative copy. 
XXXX XXXX, XXXX pages are poor quality photocopies lacking : Lender signature or execution block, authentication or certification, metadata or audit trail and legible TILA disclosures. This is NOT a contract and is not capable of validating a debt under Regulation F The " LOAN TRANSACTION SUMMARY '' is not a compliant accounting. It lacks beginning balance, running balance, ledger codes, fee explanations, charge-off entry, interest rates calculations and custodian-of-records attestation. This is a violation of XXXX part XXXX XXXX XXXX XXXX XXXX XXXX Tiffany & Brown inserted my own discovery demand as an " exhibit '' Pages XXXX of their submission are not their records but are instead my discovery request, which I previously served on the firm. They intended to create a false impression of substantial disclosure and to misled the CFPB. This raises questions about the firm 's candor and competency.

Their verification letter does not satisfy Regulation F due to no validation documentation, accounting evidence, ledger, charge-off information, custodian certification and explanation of the balance. Furthermore the letter is dated after litigation began, which is a direct violation of 12 CFR 1006.34, as debt validation must occur before initiating legal action, garnishment, or other collection activities. Meanwhile, they submitted summons to defective address multiple times.

Tiffany & Browns response directly contradicts the documents produced. Which I think constitutes material misrepresentation to the CFPB and courts.

Bayport and its consel made an incorrect and overly simplistic statemetn regarding form 1099-C, which they asserted to the CFPB that a creditor only files a 1099-C if the debt is " forgiven '', and that the absence of a 1099-C proves that the debt was not forgiven. This is legally inaccurate and as someone who actually reads the IRM and IRS documentation. A 1099-C is required when ANY of the identifiable events occur, including but not limited to : Charge-off in accordance with federal regulatory standards ( XXXX, USC, FCRPA, TILA, GAAP ), a cessation of collection activity, expiration of the statue of limitations, formal discharge or certain internal collection policies. Form 3949-A to the IRS will confirm this in due time.

This has been escalated to the proper regulatory channels including XXXX and Virginia State Bar.

Company response to consumer: Closed with explanation