Consumer complaint received 2025-10-26 00:00:00
Product: Credit reporting or other personal consumer reports — Other personal consumer report
Issue: Incorrect information on your report — Information is incorrect
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: NJ

Complaint narrative:
I, XXXX XXXX, submit this formal complaint seeking immediate investigation, enforcement, and corrective action against TransUnion LLC for a severe and arbitrary XXXX decrease in my credit score that occurred between XX/XX/XXXX and XX/XX/XXXX. 

This drop followed the lawful opening of a new credit card account and an increase in my utilization rate yet occurred without any hard inquiry, late payment, derogatory mark, or adverse credit event. Every payment on all my accounts has been made on time. 

As a XXXX consumer living below 150 % of the federal poverty level, who depends entirely on Social Security XXXX XXXX ( SSDI ) benefits totaling {$16000.00} per year, I assert that this action by TransUnion is unreasonable, discriminatory, and unlawful. It has inflicted measurable financial and psychological harm, restricting my access to essential credit opportunities and impeding my economic stability. 

This complaint arises under and implicates the following laws and standards : Fair Credit Reporting Act ( FCRA ), XXXX XXXX. XXXX et seq. 
Equal Credit Opportunity Act ( ECOA ), 15 U.S.C. 1691 et seq.

Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692 et seq.

Gramm-Leach-Bliley Act ( GLBA ), 15 U.S.C. 6801 et seq.

New Jersey Consumer Fraud Act ( N.J.S.A. 56:8-1 et seq. ) New Jersey Fair Credit Reporting Act ( N.J.S.A. 56:11-28 et seq. ) New Jersey Law Against Discrimination ( N.J.S.A. 10:5-1 et seq. ) Americans with Disabilities Act ( ADA ), 42 U.S.C. 12132 Fifth and Fourteenth Amendments to the U.S. Constitution due process and equal protection II. STATEMENT OF FACTS I am writing to formally lodge a dispute and seek immediate redress regarding a drastic and unreasonable XXXX decrease in my XXXX XXXX by TransUnion since XX/XX/XXXX. This reduction followed the opening of a new credit card account and a rise in credit utilization due to family medical emergency, yet occurred without any hard inquiry on my credit report making the action arbitrary, punitive, and without legitimate basis. 

At all times, I have paid every credit card bill on time since the inception of each of my XXXX accounts. While my utilization ratio is currently high, this stems directly from my severe financial hardship caused by XXXX, as I live on a fixed SSDI income of only {$16000.00} per year. Additionally, I incurred necessary debt while staying in California for nearly XXXX months at my grandmothers bedside during her stay in the ICU from XX/XX/XXXX to XX/XX/XXXX, where I served as her caretaker until she passed away on XX/XX/XXXX. 

It is unjust and discriminatory to penalize a XXXX individual living below 150 % of the poverty level for not having the financial means to qualify for higher credit limits due to inability to work due to XXXX which would allow lower utilization rates. Such a practice effectively punishes poor and XXXX consumers for circumstances beyond their control and perpetuates systemic bias in access to credit. 

Furthermore, the {$73.00} XXXX collection account listed on my credit report is erroneous and should never have been sent to collections, as I was never notified of any balance due nor given an opportunity to dispute or pay before collection action was taken.

As a direct consequence of TransUnions actions, I am now unable to secure housing despite fleeing XXXX XXXX  and related criminal conduct, have been denied new credit cards and a debt consolidation loan, and have lost access to lower insurance premiums. This has left me a XXXX person with sixteen documented XXXX and a fixed incomeat risk of homelessness and unable to maintain safe or stable living conditions. 

I believe that this drastic reduction and its cascading effects violate my rights under the Consumer Fraud Act, Consumer Protection Laws, Fair Credit Reporting Act ( FCRA ), Equal Credit Opportunity Act ( ECOA ), and Fair Debt Collection Practices Act ( FDCPA ), as well as federal anti-discrimination statutes. These actions are exploitative, biased, unlawful, and fundamentally incompatible with the principles of fairness and equal access to financial services guaranteed by state and federal law.

III. LEGAL ANALYSIS AND VIOLATIONS 1. Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681e ( b ), 1681i The FCRA mandates that consumer reporting agencies follow reasonable procedures to assure maximum possible accuracy. TransUnions decision to reduce my score by XXXX points without a valid adverse event violates the accuracy, fairness, and reasonableness standards of the XXXX. 

Further, XXXX ( a ) requires a reinvestigation of disputed information. TransUnions failure to explain the scoring basis or review the disputed XXXX entry constitutes non-compliance. 
This unreasonable scoring practice, untethered to my actual risk profile, meets the standard of negligence or willful noncompliance under FCRA 616-617, as interpreted in XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX ( XXXX XXXX. XXXX ). 

2. Equal Credit Opportunity Act ( ECOA ), 15 U.S.C. 1691 et seq. ; 12 C.F.R. 1002.6 ( b ) ( 2 ) ECOA prohibits discrimination in any aspect of a credit transaction, including through policies that cause disparate impact on protected groups. Penalizing a XXXX, low-income SSDI recipient with a XXXX drop for lawful credit activity disproportionately affects vulnerable consumers and thus constitutes a disparate impact violation under XXXX  XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX XXXX. 

The algorithm appears to punish consumers who can not raise credit limits due to XXXX or fixed incomea structurally biased outcome inconsistent with XXXX and the principles of fair lending and equal opportunity enforced by the CFPB and DOJ.

3. Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692e ( 2 ) ( A ), 1692e ( 8 ) The unverified XXXX collection entry reflects false and misleading credit reporting. Reporting such a debt without verification constitutes deceptive representation under 1692e. The FTCs Staff Commentary on the FDCPA clarifies that the transmission of inaccurate collection data to a credit bureau qualifies as a misleading act under the statute.

4. New Jersey Consumer Fraud Act ( N.J.S.A. 56:8-2 ) The CFA prohibits unconscionable commercial practices, deception, fraud, false pretense, and misrepresentation. TransUnions unexplained, automated penaltyimposing severe financial damage absent any legitimate causeconstitutes an unconscionable and deceptive act under New Jersey law. The practice misleads lenders into perceiving heightened risk, damaging the consumers creditworthiness without factual justification.

5. New Jersey Law Against Discrimination ( NJLAD, N.J.S.A. 10:5-1 et seq. ) The NJLAD extends to public accommodations and financial services. Penalizing a disabled consumer for lawful financial actions, due to their inability to increase credit capacity, reflects a discriminatory effect that violates N.J.A.C. 13:13-3.2 ( a ) ( 4 ), which prohibits discriminatory treatment in credit evaluation and financial access.

6. Gramm-Leach-Bliley Act ( GLBA ), 15 U.S.C. 6801 ( b ) If TransUnion accessed utilization data through soft inquiries or non-disclosed data sources, such access violates GLBA data privacy and confidentiality obligations. Using private financial data algorithmically to impose penalties without notice, consent, or transparency contravenes both GLBA 501 ( b ) and FTC Safeguards Rule, 16 C.F.R. Part 314.

7. Due Process and Equal Protection Credit bureaus exercise quasi-regulatory authority over co
nsumers financial reputations. Under Goldberg v. Kelly, 397 U.S. 254 ( 1970 ) and Mathews v. Eldridge, 424 U.S. 319 ( 1976 ), any deprivation of property or reputation interests by an entity operating under public authorization requires procedural fairness. 

The arbitrary XXXX decrease, executed without notice, rationale, or opportunity to contest, violates fundamental principles of due process and fairness embodied in both the U.S. Constitution and Article I, Paragraph 1 of the New Jersey Constitution.

IV. ALGORITHMIC BIAS AND SYSTEMIC DISCRIMINATION TransUnions reliance on opaque, unregulated algorithmic scoring models presents a systemic risk of discriminatory outcomes. Such algorithms, operating without human review, frequently penalize consumers with limited credit histories, low incomes, or disabilitiesconditions protected under federal law.

The CFPBs Advisory Opinion on Algorithmic Credit Scoring ( XXXX  ) explicitly warns that automated systems can not shield credit entities from liability under ECOA or FCRA. When algorithmic models produce disparate outcomes, entities remain legally responsible for ensuring fairness and explainability.

This case demonstrates how a flawed algorithm likely produced a disparate and disproportionate result, treating lawful, responsible financial behavior as a high-risk event. This not only violates federal standards but erodes public trust in the integrity of the credit reporting system. 

V. CONSUMER HARM AND PUBLIC POLICY IMPLICATIONS The unwarranted XXXX reduction has caused tangible harm : Economic harm, by restricting access to affordable credit, loans, and housing. 
Reputational harm, by misrepresenting my financial responsibility to lenders. 
Psychological harm, as a XXXX individual now viewed as financially untrustworthy without cause. 

Public policy strongly disfavors punitive scoring behavior detached from actual financial risk. The Federal Reserves Credit Scoring Guidelines and the FTCs Policy Statement on Unfairness ( XXXX ) require that financial scoring practices be proportionate, transparent, and consistent with objective data. 

TransUnions conduct not only fails this standardit undermines the equitable purpose of the FCRA and XXXX by making fair credit access impossible for XXXX and low-income Americans. 

VI. LEGAL PRECEDENTS SUPPORTING REMEDY XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) : Inaccurate credit reporting constitutes concrete harm. 
Pintos v. XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX XXXX XXXX ) : CRAs must ensure accuracy and fairness in reporting. 
XXXXXXXX XXXX. TransUnion LLC, XXXX XXXX XXXX : Establishes liability for misleading and harmful score reductions. 
XXXX v. XXXX XXXX, XXXX XXXX XXXX ( XXXX ) : Confirms transparency in consumer credit processes. 
XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( XXXXXXXX XXXX XXXX ) : Failure to contextualize consumer data is actionable under FCRA. 
XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ) : Disparate treatment in credit evaluation violates XXXX. 

XXXX. REQUESTED ACTIONS AND RELIEF I respectfully request that your offices : 1. Initiate a coordinated multi-agency investigation into TransUnions credit scoring algorithms and reporting procedures for violations of federal and state law. 
XXXX. XXXX TransUnion to provide a detailed disclosure explaining the precise data and factors used to justify this XXXX reduction. 
XXXX. Order the immediate restoration of my credit score to its XXXX XXXX level and remove the unverified XXXX collection from my record. 
XXXX. Recommend enforcement action or civil penalties to ensure compliance with FCRA, XXXX, and NJCFA standards. 
XXXX. Implement algorithmic oversight requirements ensuring transparency and fairness in credit score calculations for XXXX and low-income consumers. 
XXXX. Refer this matter to the DOJ XXXX XXXX XXXX for investigation into systemic discriminatory scoring practices. 

TransUnions unexplained and disproportionate XXXX XXXX XXXX reduction is arbitrary, deceptive, discriminatory, and unlawful. It reflects a systemic failure of algorithmic accountability and violates both federal and state consumer protection and anti-discrimination statutes. 

The law requires that credit reporting be accurate, fair, transparent, and nondiscriminatory. My case demonstrates the oppositea punitive and baseless algorithmic decision that punished lawful behavior, exacerbated my financial hardship, and violated my rights under FCRA, ECOA, FDCPA, NJLAD, and constitutional due process.

I therefore request immediate corrective and enforcement action to restore fairness, transparency, and accountability within TransUnions credit reporting practices.

Respectfully submitted,

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