Consumer complaint received 2025-09-15 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Problem with a company's investigation into an existing problem — Investigation took more than 30 days
Company: EQUIFAX, INC.
State: TX

Complaint narrative:
Complainant : XXXX XXXX XXXX Address : XXXX XXXX XXXX, XXXX XXXX, XXXX, TX XXXX Email : XXXX Phone : ( XXXX ) XXXX XXXX : XX/XX/XXXX SSN ( Last XXXX ) : XXXX Date : XX/XX/XXXX Companies Complained About ( THIS COMPLAINT TARGETS ONLY THESE XXXX BUREAUS ) : TransUnion LLC, XXXX. XXXX XXXX, XXXX, PA XXXX Equifax XXXX XXXX XXXX, XXXX XXXX XXXXXXXX, XXXX, GA XXXX ( Experian is excluded here ; its XXXX XXXX window has not yet expired as of XX/XX/XXXX. ) Subject : CFPB Escalation Repeated FCRA Noncompliance ( Missed XXXX Reinvestigation Deadlines ; Failure to Provide Method of Verification ) EECU Account # XXXX / # XXXX Short Summary ( What happened and why XXXX filing ) : I disputed the XXXX tradeline through XXXX on XX/XX/XXXX, documenting major inconsistencies ( including conflicting account numbers across bureaus ) and requested correction or deletion if not fully verifiable, plus the Method of Verification ( MOV ). TransUnion and Equifax both exceeded the FCRAs 30-day reinvestigation deadline on that dispute and again exceeded 30 days on my XX/XX/XXXX follow-up deletion demandyet neither removed the tradeline nor provided the legally required MOV. Under 15 U.S.C. 1681i ( a ) ( 5 ) ( A ), unverified information must be deleted. I seek deletion of the XXXX XXXX from TransUnion and Equifax, or full MOV within 15 days if they refuse. 


PART 1 ORIGINAL CFPB DISPUTE AND FIRST 30-DAY VIOLATION CFPB submission date : XX/XX/XXXX ( XXXX  account ; XXXX XXXX # XXXX / # XXXX ) Key inaccuracies highlighted ( illustrative, as of the XX/XX/XXXX snapshots ) : Conflicting account numbers : TransUnion lists XXXX, while Equifax/XXXX list XXXX Balance : XXXX {$5200.00} vs. EQ/XXXX {$5200.00} Last Activity : TU/XXXX XXXXXXXX XXXX XXXX XX/XX/XXXX Remarks & status conflicts ( incl. 90 days past due on XXXX bureau but not others ) Late counts ( XX/XX/XXXX ), months reviewed, monthly payment, XXXX %, and past-due all conflict Receipt Response ( Missed 30 days ) : TransUnion : received XX/XX/XXXX XXXX XX/XX/XXXX ( EDUCATIONAL ECU-ACTIVE DISPUTE ). 48 days. 
Violates 15 U.S.C. 1681i ( a ) ( 1 ) ( A ). Generic text is not a compliant reinvestigation result ; no MOV provided. 
Equifax : received XX/XX/XXXX responded XX/XX/XXXX ( new dispute frivolous / in process ). 51 days. 
Violates 1681i ( a ) ( 1 ) ( A ). If deemed frivolous, Equifax still had to give timely notice with reasons and what info is needed. See 1681i ( a ) ( 3 ) ( B ) ( 5-business-day notice requirement ). The notice here was late and deficient.

No additional information was submitted by me during the 30-day periods that could have tolled the clock under 1681i ( a ) ( 1 ) ( B ).

PART 2 FORMAL DELETION DEMAND AND SECOND 30-DAY VIOLATION On XX/XX/XXXX, I sent a Failure to Reinvestigate Within 30 Days / Failure to Provide MOV demand via CFPB.gov, again seeking deletion under 1681i ( a ) ( 5 ) ( A ) or, alternatively, a full MOV.

Receipt ( Non ) Response ( Missed 30 days again ) : TransUnion : received XX/XX/XXXX as of XX/XX/XXXX, no response or deletion. 37 days. 
Equifax : received XX/XX/XXXX as of XX/XX/XXXX, no response or deletion. 38 days. 

Experian received XX/XX/XXXX ; I am not including Experian in this complaint because its 30-day period has not yet expired as of XX/XX/XXXX. 


CONTROLLING LAW & GUIDANCE 15 U.S.C. 1681i ( a ) ( 1 ) ( A ) [ FCRA 611 ( a ) ( 1 ) ( A ) ] CRA must conduct a reasonable reinvestigation and complete it within 30 days of receiving a dispute.

15 U.S.C. 1681i ( a ) ( 2 ) ( A ) CRA must promptly provide all relevant information from the consumer to the furnisher.

15 U.S.C. 1681i ( a ) ( 3 ) ( B ) If the CRA deems a dispute frivolous/irrelevant, it must notify the consumer within 5 business days of making that determination, state the reasons, and identify any information needed to investigate.

15 U.S.C. 1681i ( a ) ( 5 ) ( A ) If disputed information is inaccurate, incomplete, or can not be verified, it shall be promptly deleted.

15 U.S.C. 1681i ( a ) ( 6 ) ( A ) CRA must provide written results and a free updated report within 5 business days after completing reinvestigation.

15 U.S.C. 1681i ( a ) ( 6 ) ( B ) ( iii ) & 1681i ( a ) ( 7 ) Upon my request, CRA must provide the Method of Verification within 15 days ( furnishers name/address/phone ; description of procedure ; copies of documents relied upon ).

15 U.S.C. 1681e ( b ) [ FCRA 607 ( b ) ] CRAs must follow reasonable procedures to assure maximum possible accuracy.

15 U.S.C. 1681s-2 ( b ) ( XXXX ) Furnishers must investigate upon CRA notice and correct/delete inaccurate information. 
12 C.F.R. 1022.43 ( Reg V ) Furnishers must reasonably investigate covered disputes and may not deem them frivolous without proper notice.

CFPB Circular 2022-07 CRAs/furnishers must reasonably investigate disputes ; parroting/generic responses are noncompliant.

Submission channel : Disputes through CFPB.gov do not change the CRAs statutory duties or deadlines under 1681i. 


RELEVANT CASE LAW XXXX XXXX TransUnion, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) CRAs must conduct an independent, reasonable reinvestigation ( not merely parrot furnishers ). 
XXXX v. TransUnion, XXXX XXXX XXXX ( XXXX Cir. XXXX ) Willful noncompliance where CRAs fail to ensure accuracy and meet statutory duties. 
XXXX XXXX XXXX, XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) Failing to follow reasonable procedures and deadlines violates the FCRA. 
XXXX XXXX Credit Bureau, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) Technically accurate but misleading information can be inaccurate under the FCRA. 
XXXX v. XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) Failure to reasonably reinvestigate disputed data creates actionable harm. 
XXXX v. XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) CRAs can not rely on unverifiable information beyond statutory deadlines. 


WHY THIS IS NONCOMPLIANCE XXXX XXXX TransUnion and Equifax both exceeded the XXXX reinvestigation deadline on the initial XX/XX/XXXX dispute and again on the XX/XX/XXXX deletion demand ( violations of XXXX ( a ) ( XXXX ) ( A ) ). 

XXXX ) XXXX frivolous handling was both late and defective ( violates XXXX ( a ) ( XXXX ) ( B ) and does not toll the 30-day requirement ).

3 ) Neither bureau provided the requested MOV within 15 days as required by 1681i ( a ) ( 6 ) ( B ) ( iii ) and 1681i ( a ) ( 7 ).

4 ) The conflicts ( including mismatched account numbers across bureaus ) show a failure to assure maximum possible accuracy ( 1681e ( b ) ).

5 ) Under 1681i ( a ) ( 5 ) ( A ), information that can not be verified within the reinvestigation period must be deletedlate or generic responses do not cure missed statutory deadlines. 


REQUESTED RELIEF ( What I want the CFPB to do ) XXXX ) Direct TransUnion and Equifax to * * delete the XXXX XXXX * * ( # XXXX / # XXXX ) from my credit files for failure to timely complete reinvestigation and inability to verify within the statutory period, as required by * * 15 U.S.C. 1681i ( a ) ( 5 ) ( A ) * *.

2 ) Require each bureau to provide a * * free updated credit report * * showing the deletion within 15 days of CFPB action ( 1681i ( a ) ( 6 ) ( A ) ).

3 ) If any bureau refuses to delete, compel production of the * * full Method of Verification * * within * * 15 days * * ( per 1681i ( a ) ( 6 ) ( B ) ( iii ) & 1681i ( a ) ( 7 ) ), including furnisher name/address/phone, date/time of verification, detailed description of procedures, and * * legible copies of all documents * * relied upon.

4 ) Require certification that the information * * will not be reinserted * * absent certification of accuracy and * * written notice within 5 business days * * ( see 1681i ( a ) ( 5 ) ( B ) ).

5 ) Consider supervisory/enforcement action for repeated deadline and MOV violations and require remedial measures to prevent recurrence.

Harm : These violations have allowed inconsistent, inaccurate, and unverified negative data to remain on my reports beyond statutory deadlines, adversely impacting my creditworthiness and financial opportunities. 

Attachments : XX/XX/XXXX CFPB dispute ( XXXX ) with exhibits ( ID, proof of address, highlighted reports ) Proof of receipt dates : XXXX XX/XX/XXXX ; XXXX XX/XX/XXXX XXXX XX/XX/XXXX late generic response ; XXXX XX/XX/XXXX late frivolous/in process notice XX/XX/XXXX follow-up deletion demand ( EECU ) Proof of second-cycle receipt dates : XXXX XX/XX/XXXX ; XXXX XX/XX/XXXX ; and nonresponses through XX/XX/XXXX Certification : I certify the information provided is true and correct to the best of my knowledge and that attached documents are accurate copies. 

XXXX XXXX XXXX

Company response to consumer: Closed with non-monetary relief