Consumer complaint received 2025-04-22 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Problem with a company's investigation into an existing problem — Their investigation did not fix an error on your report
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: FL

Complaint narrative:
I am filing this formal complaint against the three nationwide credit bureaus TransUnion, for willful and repeated violations of federal consumer protection laws, including the Fair Credit Reporting Act ( FCRA ) and the Fair Debt Collection Practices Act ( FDCPA ). Despite my numerous disputes, the Bureaus removed certain fraudulent accounts from my credit reports only to unlawfully reinsert them without proper verification or notice. This conduct violates FCRAs reinsertion provisions ( 15 U.S.C. 1681i ( a ) ( 5 ) ( B ) ) which prohibit a credit reporting agency TRANSUNION from reinserting previously deleted information unless the furnisher certifies its accuracy and the CRA notifies the consumer within 5 business days. The Bureaus failed to meet these requirements. They also failed to ensure maximum possible accuracy of my reports ( FCRA 1681e ( b ) ), did not properly reinvestigate my disputes within 30 days ( FCRA 1681i ( a ) ( 1 ) ( A ) ), and ignored my requests for validation and verification in violation of both FCRA and FDCPA. In short, the transunion actions ( and inactions ) have allowed inaccurate, fraudulent accounts to persist and even reappear on my credit file, causing significant harm. 
XXXX. Background of Disputed Accounts I am a victim of identity theft, which I have documented through an FTC Identity Theft Report and police report ( copies provided to the Bureaus ). Unauthorized accounts and inquiries were added to my credit reports without my consent. I exercised my rights under FCRA and FDCPA to dispute these items and to request their validation : Fraudulent Accounts : XXXX CARD : XXXX that I never opened or authorized. After my initial disputes, some of these accounts were deleted as invalid. However, the transunion later reinserted XXXX CARD : XXXX without notifying me in writing within five days, as required by 15 U.S.C. 1681i ( a ) ( 5 ) ( B ) ( ii ). No certification of accuracy was provided to me upon reinsertion, indicating the process did not comply with the law. Reinserting previously removed debts without proper validation also implicates FDCPA 809 ( b ) ( 15 U.S.C. 1692g ( b ) ), since a debt collector must cease reporting a debt if it can not verify it. The Bureaus effectively allowed debt collectors to continue collection by credit reporting, even after disputes, without ever providing me verification. 
Unauthorized Inquiries : Numerous hard inquiries appeared on my reports from lenders I never applied to ( XXXX  XXXX ). This inquiry lack a permissible purpose under FCRA 604 ( 15 U.S.C. 1681b ) and should have been removed. Reporting inquiries without consent is illegal, yet the Bureaus did not delete them despite my disputes.

Incorrect Personal Information : My credit file shows wrong names ( e.g., variations of my name I have never used ) and addresses in states Ive never lived. This indicates failure to assure maximum possible accuracy ( 15 U.S.C. 1681e ( b ) ) and potentially mixed-file issues. I requested correction or removal of this data, but the Bureaus have not fully complied. 
Despite sending formal dispute letters ( via certified mail ) to transunion including documentation of fraud ( identity theft reports, ID, proof of address ) the Bureaus either failed to respond in a timely manner or conducted perfunctory investigations that did not actually verify the debts. Notably, more than 30 days have passed since my disputes with no adequate verification provided ( violating FCRA 1681is 30-day limit and 1681i ( a ) ( 6 ) duty to report results ). They have also failed to block the fraudulent accounts after receiving my identity theft reports, contrary to FCRA 605B ( 15 U.S.C. 1681c-2 ( a ) ), which requires CRAs to block such information within 4 business days of receiving proof of identity theft.

III. Detailed Violations of Law The Bureaus actions ( and failures to act ) violate multiple provisions of federal law, as detailed below : FCRA 15 U.S.C. 1681i ( a ) ( 1 ) ( A ) Failure to conduct a reasonable reinvestigation within 30 days of my dispute. I notified the Bureaus of inaccuracies ; under FCRA they must reinvestigateor delete the item within 30 days of receiving the dispute. They did not complete proper investigations in this timeframe, nor did they delete all unverified information.

FCRA 15 U.S.C. 1681i ( a ) ( 5 ) ( A ) Failure to delete inaccurate or unverified information. By law, if an item is inaccurate or the furnisher fails to verify it, the CRA must promptly delete or correct that item. Here, furnishers failed to verify the debts ( no contracts or signatures were produced ), yet the accounts remain or were reinserted.

FCRA 15 U.S.C. 1681i ( a ) ( 5 ) ( B ) Unlawful reinsertion of previously deleted information without required certification and notice. Federal law prohibits a CRA from reinserting a deleted item unless the furnisher certifies its accuracy, and even then the CRA must notify the consumer within 5 business days of reinsertion with the furnishers contact details. The Bureaus put deleted fraudulent accounts back on my report without notifying me at all, which is an egregious FCRA violation. I only discovered the reappearance by checking my reports. This denied me the chance to dispute immediately or add a consumer statement, as is my right.

FCRA 15 U.S.C. 1681e ( b ) Failure to maintain reasonable procedures to assure maximum possible accuracy. The recurring inaccurate information on my reports ( fraudulent account, incorrect personal data ) shows the Bureaus procedures are inadequate. In fact, the CFPB has noted that Experian lacked basic matching tools to prevent reinsertions by a new debt collector, causing consumers to see the same inaccurate information reappearwithout explanation under the name of a new furnisher. XXXX  was likewise found to have failed ] to prevent the improper reinsertion of previously deleted information in violation of FCRA. My experience mirrors these findings.

FCRA 15 U.S.C. 1681c-2 ( a ) Failure to block information resulting from identity theft. I provided the Bureaus with an identity theft report identifying specific fraudulent accounts. Under FCRA 605B, a CRA must block those items from my credit file within four business days and notify the furnisher. Any subsequent attempt to reinsert or report that blocked info is unlawful. The Bureaus did not honor this mandatory block, as the accounts continued to report even after they had my theft report. Moreover, if a CRA declines or rescinds a block, it must notify the consumer within 5 days ( 15 U.S.C. 1681c-2 ( c ) ) ; I received no such notices. The CFPBs recent enforcement action against XXXX  confirms that failing to block identity theft accounts ( and failing to notify the consumer of any unblocking ) is a serious violation. 
FCRA 15 U.S.C. 1681i ( a ) ( 6 ) Failure to provide me the results of reinvestigation and verification details. I was entitled to a written notice of the investigation results within 5 business days of completion, including a revised credit report and information on how it was verified or why it was unchanged. Instead, I either received no response or generic form letters that did not explain the outcome. The CFPB found Experian was sending consumers notices that fail to inform them of the investigation results and provided confusing or incorrect information, which is exactly what I experienced. I also requested method of verification details ( e.g. copies of any documents or contracts that prove I owe the debts ), which the Bureaus failed to supply violating FCRA 1681i ( a ) ( 6 ) ( B ) ( iii ) and 1681i ( a ) ( 7 ). 
FDCPA 15 U.S.C. 1692g ( a ) & ( b ) XXXX XXXX  : XXXX Failure of debt collectors to provide validation of the debts and ceasing collection. I notified the furnishers ( collection agencies ) that these accounts were fraudulent and requested validation under FDCPA. Debt collectors must send verification of the debt and original creditor upon request ( and initially advise me of this right ) per 1692g ( a ) ( 4 ) - ( 5 ). None of the collectors provided valid documentation. Moreover, once I disputed and sought validation, they should cease collection activities until providing proof ( 1692g ( b ) ). Reporting a debt to a CRA is considered a collection activity ; by continuing to report or re-report these accounts without validation, the collectors violated FDCPA. Thus, the Bureaus by extension are reporting debts that are legally unvalidated and uncollectible. 
FDCPA 15 U.S.C. 1692e ( 8 ) Communication of false credit information by debt collectors. If a debt is disputed or is the result of identity theft, a collector must mark it as disputed in any reporting. If any collector re-reported the debt under a different account or failed to note my dispute, that is a false representation of the debts status. The reinserted tradelines appeared under new account numbers/names, giving the impression of a new debt. This deceptive practice violates 1692e and 1692e ( 8 ). 
In summary, the Bureaus have failed to follow the law at multiple steps of the process meant to protect consumers. Instead of performing legitimate investigations, they appear to rely on automated, perfunctory processes that parrot whatever their furnishers respond with, regardless of evidence. Notably, the National Consumer Law Center observes that credit bureaus often engage in sham dispute investigations, always deferring to the creditor or collector a practice called parroting. This bias undermines my rights under FCRAs dispute provisions and has occurred in my case.

IV. Pattern of Non-Compliance CFPB Enforcement Evidence My experience is not isolated ; it reflects systemic problems that the CFPB and courts have recognized and acted upon. I cite the following recent enforcement actions and cases to underscore the severity of these violations and the need for CFPB intervention : CFPB Lawsuit against XXXX  ( XX/XX/XXXX ) : The CFPB sued XXXX  for failing to properly investigate consumer disputes and for reinserting errors on credit reports. The Bureau alleges XXXX  conducted sham investigations and routinely ignored evidence submitted by consumers. Instead of fixing errors, XXXX  allowed deleted inaccuracies to reappear under different furnishers, harming consumers credit access. CFPB XXXX XXXX XXXX noted this misconduct can have serious consequences and that credit reporting giants must follow the law This lawsuit seeks to halt XXXX  unlawful practices and impose penalties. My case involves the very same practices poor dispute handling and improper reinsertion now under CFPB litigation. 
XXXX Settlement with TransUnion ( XX/XX/XXXX ) : TransUnion and a subsidiary agreed to pay {$15.00} XXXX to settle charges of failing to ensure report accuracy. In that case ( involving tenant screening reports ), TransUnion failed to remove inaccurate or incomplete records, which hurt consumers ability to obtain housing. While focused on tenant data, the settlement highlights the Bureaus obligations under FCRAs maximum possible accuracy standard. It shows regulators will impose multi-million dollar penalties when CRAs allow faulty data to remain, reinforcing that the issues in my complaint rise to the level of enforcement. 
CFPB Action against XXXX  ( XX/XX/XXXX ) : The CFPB issued an order against XXXX  for widespread FCRA violations in its dispute handling processes. The Bureau found XXXX  failed to properly conduct reinvestigations, failed to prevent improper reinsertions, and failed to block information resulting from identity theft, among other violations. XXXX  also neglected to send consumers adequate results of investigations. XXXX  was ordered to pay a {$15.00} XXXX civil penalty and fix its procedures. According to XXXX, XXXX  ignored consumer documents and evidence, allowed previously flagged inaccuracies to return to credit reports. This is precisely what I have endured across all three Bureaus. The CFPBs action against XXXX  underscores that reinsertion of disputed data and ignoring identity theft claims are unlawful and punishable. My complaint seeks similar scrutiny and relief with respect to XXXX, XXXX, and TransUnions conduct in my case. 
Case Law : Courts have long interpreted the FCRA to require meaningful dispute investigations by CRAs, not just automated formality. In XXXX XXXX XXXX XXXX XXXXXXXX, the Third Circuit held that a CRA must go beyond the original source [ the creditor ] and can not simply rely on whatever the furnisher says if that approach yields no resolution doing so would violate the FCRAs reinvestigation duty ( XXXX XXXX XXXX, XXXX ( XXXX XXXX. XXXX ) ). Similarly, in XXXX XXXX XXXX, XXXX, XXXX XXXX XXXX ( XXXX XXXXXXXX XXXXXXXX ), the XXXX XXXX emphasized that furnishers of information ( and by extension CRAs ) have a responsibility to investigate and correct disputed information, especially when there are indicia of identity theft or fraud. These cases support that the Bureaus cursory handling of my disputes effectively rubber-stamping the erroneous information falls short of FCRAs requirements and exposes them to liability. Moreover, failure to notify a consumer of reinsertion has been found to violate the FCRA and supports damages ; e.g., XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX. XXXX XXXX ( XXXX XXXX XXXX ) ( CRAs lack of notice of reinsertion was a breach of FCRA 1681i ). In sum, there is ample legal precedent that the Bureaus actions are illegal and harmful. 
XXXX Impact on Consumer ( Harm Caused ) Due to these violations, I have suffered serious negative consequences : my credit score plummeted because of the reinserted bogus accounts and numerous hard inquiries. I have been denied credit and faced higher interest rates on loans. The stress of dealing with identity theft was exacerbated by the Bureaus failure to correct the record. Ive spent countless hours sending disputes, making phone calls, and seeking relief, to little avail. These inaccuracies also jeopardize opportunities for employment and housing ( since many employers and landlords check credit ). The continued presence of fraudulent debt on my reports is a constant source of anxiety and constitutes ongoing damage to my reputation and finances. All of this harm is directly attributable to the Bureaus non-compliance with consumer protection laws. 
VI. Relief Requested I respectfully request the CFPBs assistance to enforce the law and obtain the following relief : Immediate Deletion/Blocking of Fraudulent Data : The CFPB should compel XXXX, TransUnion, and XXXX  to permanently delete all fraudulent accounts and inquiries from my credit files across all bureaus. In addition, any information identified in my identity theft report must be blocked from reappearing, per 15 U.S.C. 1681c-2. This includes the specific accounts I have disputed ( detailed in my correspondence with the Bureaus ) and any related listings by different collection agencies. The bureaus must ensure these items do not reinsert under any name or form unless strict FCRA prerequisites are met.

Compliance Verification : The Bureaus should be required to provide written confirmation that the deletions and blocks have been implemented, along with updated copies of my credit reports showing a clean record. Furthermore, I request that the CFPB review the
Bureaus internal reinvestigation documentation for my disputes how they handled my dispute letters, whether they forwarded my evidence to furnishers, and how the improper reinsertions occurred. If they failed to forward my documents or made only cursory checks, that should be noted as part of enforcement ( as the CFPB has alleged happened in other cases ).

Investigation into Furnishers : I urge the CFPB to also consider enforcement against the furnishers ( creditors/debt collectors ) who supplied these fraudulent accounts. If a debt collector failed to conduct a reasonable investigation after notice of dispute from the CRA ( violating 15 U.S.C. 1681s-2 ( b ) ) or re-reported a debt without validating it to me ( violating FDCPA and potentially FCRA 1681s-2 ( a ) ( 8 ) ), they should be held accountable. The CFPBs Circular 2022-07 makes clear that regulators can take action against furnishers who do not properly investigate disputes. Such action will complement the relief in my individual case by addressing the source of the erroneous data.

Civil Penalties and Consumer Redress : Given the willful nature of these violations the Bureaus were alerted multiple times and yet persisted maximum penalties are warranted. The CFPB should impose appropriate civil money penalties on each Bureau for these breaches ( consistent with recent fines : e.g. {$15.00} XXXX against XXXX  ). I also seek any available monetary relief for the harm Ive suffered, which the CFPB can facilitate through its complaint resolution process or enforcement action. Under FCRA, I have private rights to damages ( statutory, actual, and punitive under 15 U.S.C. 1681n, 1681o ), but I am first seeking resolution through the CFPBs intervention to hopefully avoid litigation.

Systemic Reforms : Beyond my case, I ask the CFPB to mandate that the Bureaus review and fix their dispute handling systems : specifically, to stop any automated rejection of disputes without human investigation ( ensuring no dispute is improperly labeled frivolous without a valid reason and notice to the consumer ), to integrate fraud report information across all bureaus ( perhaps via the automated system required by FCRA 1681i ( a ) ( 5 ) ( D ) for sharing dispute results, and to implement the basic matching protocols that would prevent deleted items from sneaking back in under slightly different details. The goal is to force improvements so that no other consumer faces the same nightmare of recurring fraudulent entries.

VII. Conclusion The facts demonstrate clear violations of federal law by, TransUnion, in concert with certain furnishers. The Bureau have ignored their duties under FCRA and FDCPA, even after multiple notices, to the severe detriment of my financial well-being. I urge the CFPB to use its authority to investigate this matter, ensure the fraudulent data is removed and blocked, and to take enforcement action as needed. The CFPBs own statements recognize that when companies fail to investigate disputed information, consumers are left paying higher costs and face greater difficulty in life. That is exactly my situation ; I am counting on CFPB to uphold my rights and restore the accuracy and integrity of my credit reports. 
Thank you for your attention to this urgent complaint. I am available to provide any additional information or documentation needed. I have attached copies of relevant dispute letters, identity theft reports, and prior correspondence for your reference. 
Sincerely, XXXX XXXX

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 non-monetary relief