Consumer complaint received 2025-04-13 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: IL

Complaint narrative:
RE : Follow-Up to CFPB Complaint Unauthorized Reporting and Improper Investigation of Securitized Student Loan Accounts This is a follow-up in response to the company 's interim decision and investigation regarding my formal complaint against TransUnion and XXXX. I am submitting this clarification to emphasize key legal and procedural violations that remain unresolved, specifically : 1. Lack of a Signed Promissory Note by XXXX XXXX has failed to provide any original, signed promissory note evidencing that I consented to or entered into a contractual agreement with them. The absence of this document raises serious legal concerns regarding the legitimacy of their authority to collect on or report these debts. 

According to the Truth in Lending Act and general principles of contract law, a signed agreement is essential to establish enforceability. XXXX 's inability or refusal to produce this document invalidates their standing to collect on or report these accounts. 

2. Securitized Loans Are Held in Trusts XXXX Can not Enforce or Collect The loans in question were securitized and placed into a trust, which removes XXXX legal ownership or authority to collect. Under UCC Article 9 and federal trust law, once XXXX XXXX are securitized, the servicer becomes merely an administrator with no legal claim to the debt unless explicitly empowered by the trust a fact they have not demonstrated. 

Without a verifiable chain of title and authorization from the trust holder, XXXX is operating without standing or permissible purpose. This is a potential FDCPA and FCRA violation, as it involves false representation of authority and reporting without legal grounds. 

3. TransUnion 's Complicity and Financial Incentive TransUnion continues to report these disputed accounts without proof of authorization or signed agreements. This undermines their obligation under 15 U.S.C. 1681i to conduct a thorough and independent reinvestigation. Instead, they appear to rely solely on the word of the data furnisher in this case, XXXX whose conflict of interest is clear. 

TransUnion has a known financial interest in maintaining relationships with data furnishers, who pay to furnish and access consumer data. This creates a significant conflict of interest, and undermines the integrity of the dispute process. 

Furthermore, TransUnion failed to provide documentation confirming : The existence of a signed promissory note ; Proper authorization to report the loans ; Compliance with my request to block inaccurate information under FCRA 605B, despite submitting an ID Theft Report and supporting documentation.

4. Violation of My Rights Under FCRA and Identity Theft Law I also reiterate that this reporting is a violation of 15 U.S.C. 1681b, as no permissible purpose exists for TransUnion to continue publishing these accounts on my credit report without lawful consent. Furthermore, given that my personal information was used in the absence of authorization, this constitutes a potential violation of 18 U.S.C. 1028A Aggravated Identity Theft. 

Requested Remedy Given the clear lack of documentation, chain of title, and legal basis to collect or report these loans : All XXXXrelated accounts must be permanently removed from my credit file ; TransUnion must cease and desist further reporting of these accounts ; I request a complete audit trail of all communications and data TransUnion relied upon in their investigation ; I request confirmation that both entities have retained and preserved all documentation related to this case for potential legal discovery. 

If this issue is not resolved in full compliance with FCRA and other applicable statutes, I am prepared to escalate this matter to my State Attorney General, the FTC, and pursue civil litigation for damages.

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