Consumer complaint received 2025-10-27 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: Early Warning Services, LLC
State: TX

Complaint narrative:
Please be advised that I currently have an active federal lawsuit pending in the U.S. District Court for the Northern District of Texas ( Case No.

4:25-CV-01189-P-BJ_ ) against Equifax Information Services LLC for similar procedural and reinsertion violations under the Fair Credit Reporting Act, 15 U.S.C. 1681 et seq. This serves as a final opportunity for your agency to comply with your FCRA obligations before I extend litigation to include your organization. '' procedural requirements under the Act.

Because your agency has engaged in substantially similar conduct regarding the same fraudulent accounts and disputed information, this letter serves as an opportunity to review your records and immediately correct all procedural violations before similar litigation is initiated against your company.

I am writing regarding repeated violations of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., related to my identity theft dispute. Despite my providing valid documentation of identity theft, your agency has repeatedly reinserted fraudulent account information into my consumer file without proper notice or procedural compliance. 

Chronology of Events XXXX. XX/XX/XXXX I disputed an accounts as fraudulent. Your agency blocked the account as required under 15 U.S.C. 1681c-2 ( a ) ( FCRA 605B ). 
XXXX. XX/XX/XXXX, October 1-2, 2025 The same accounts were reinserted without explanation, documentation, or the XXXX-day notice required by 611 ( a ) ( 5 ) ( B ). 
XXXX. XX/XX/XXXX I disputed the accounts again ; your agency blocked it. 
XXXX. XX/XX/XXXX The accounts were reinserted once more, again without proper notice, explanation, or proof of accuracy. 

Your letter on XX/XX/XXXX admits that it does not independently verify disputed information, but instead relies solely on the furnisher 's own internal review. This 'parroting ' procedure fails to satisfy the requirement of a reasonable reinvestigation under 15 U.S.C. 1681 ( a ) ( 1 ) ( A ), as established in Cushman v. Trans Union Corp., 115 F.3d 220 ( 3d Cir. 1997 ). '' Your response is a Violation of 607 ( b ) - Failure to Maintain " Maximum Possible Accuracy '' Your response shows no independent quality control system to ensure data accuracy. If the furnisher 's data was wrong or fraudulent, you republishing it unverified - violating your duty of accuracy.

Its also in Violation of 611 ( a ) ( 6 ) ( B ) ( iii ) When a consumer requests " a description of the procedure used to determine the accuracy, '' the CRA must provide : The name, address, and phone numk A description of the procedure used.

Your " description '' is boilerplate - it doesn't actually show how you even determined accuracy. You just said you relied on the furnisher and reviewed what was sent, which isn't a proper " description of procedure '' under the statute. 

Your letter literally describes exactly what the court said is not sufficient. 
You relied solely on the furnisher 's internal check - no independent verification. 

At no point were any reinvestigation results, furnisher contact information, or evidence supporting the accuracy of the account provided. The only communication I received was an email recission letter, which does not satisfy the FCRAs statutory notice requirements. 
Applicable FCRA Violations Based on these events, your agency is in violation of multiple FCRA provisions : 1. 605B ( a ) Failure to Permanently Block Identity Theft Information Reinserted blocked fraudulent accounts multiple times without my written consent or valid proof of accuracy.

2. 611 ( a ) ( 1 ) ( A ) Unreasonable Reinvestigation Failed to conduct a reasonable reinvestigation of my disputes, relying solely on furnisher verification without explanation or evidence.

3. 611 ( a ) ( 5 ) ( B ) Failure to Provide Proper Reinsert Notice Reinserted previously deleted or blocked information without sending a written notice containing furnisher contact info and dispute rights within 5 business days.

4. 607 ( b ) Failure to Ensure Maximum Possible Accuracy Repeatedly reporting the same fraudulent account violates your obligation to maintain accurate consumer files.

5. 623 ( a ) ( 6 ) Possible Willful or Negligent Re-Reporting Allowing duplicate or reinsertion of fraudulent account data from furnishers without independent verification constitutes negligent or willful violation of FCRA.

Demand for Immediate Action To resolve this matter without litigation, I demand that your agency : 1. Provide written confirmation that all fraudulent account information related to this dispute is permanently blocked, per 605B ( a ).

2. Provide all documentation showing how you verified the accuracy of the account, including furnisher communications, for each reinsertion.

3. Provide the name, address, and phone number of the furnisher associated with each reinsertion, in compliance with 611 ( a ) ( 5 ) ( B ).

4. Confirm remediation of any duplicate reporting to ensure my file reflects maximum possible accuracy, per 607 ( b ).

5. Provide assurance that any future reinsertion of blocked identity theft information will strictly comply with FCRA procedures.

Case Law Cushman v. Trans Union Corp., 115 F.3d 220 ( 3d Cir. 1997 ) - CRA must do more than rely on furnisher verification when consumer disputes identity theft.

Nagle v. Experian Info. Solutions, Inc., 297 F.3d 1305 ( 11th Cir. 2002 ) Failure to notify consumer within 5 days of reinsertion violates 611 ( a ) ( 5 ) ( B ).

Johnson v. MBNA, 357 F.3d 426 ( 4th ) ir.20049 - CRAs & turnishers must conduct eal investigations, not rubber-stamp.

Dennis v. BEH-1, 520 F.3d 1066 ( 9th Cir. 2008 ) - ignoring consumer evidence = FCRA violation.

This is my final attempt to avoid litigation. I have compiled evidence to show youve been willfully negligent multiple times with reinsertion of fraudulent information while ignoring the laws in how you handle them., Please provide the above documentation and confirmation within 15 business days of receipt of this letter. If you can not provide sufficient evidence you followed the letter of the law in handling my dispute delete these permanently.

Failure to comply will leave me with no alternative but to pursue all available legal remedies, including filing suit for negligent and willful violations of the FCRA, statutory damages, and attorney fees under 15 U.S.C. 1681n and 1681o.

I expect your prompt attention to this matter. Consider this my final attempt to have this permanently fixed before litigation in federal court for procedural violations of the FCRA. 

Sincerely, XXXX XXXX XXXX

Company response to consumer: Closed with explanation