Consumer complaint received 2025-10-23 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: CA

Complaint narrative:
XXXX XXXX XXXX XXXX XXXX XXXX, CA XXXX * * Date : * * XX/XX/2025 * * To : * * XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  XXXX XXXX XXXX XXXX XXXX, TX XXXX * * Reference : * * CFPB Complaint # XXXX * * Re : * * Failure to Validate, Improper Assignment, and Continued FCRA/FDCPA Violations Account No. XXXX -- - * * To Whom It May Concern : * * I am writing in response to your XX/XX/2025 Closed with explanation reply. Your response is wholly inadequate and confirms further violations of federal law. 

# # # XXXX. Failure to Answer Questions XXXX My XX/XX/2025 dispute required answers to XXXX specific validation questions. You have not provided : 1. Original creditor information ; 2. Complete debt verification, including a signed contract ; 3. Assignment and transfer records ; 4. Proof the debt was not securitized ; 5. Documentation of reassignment.

Instead, you produced generic statements and an unsigned agreement. This is not validation under * * 15 U.S.C. 1692g ( b ) * * nor compliance with your furnisher obligations under * * 15 U.S.C. 1681i * * and * * 1681s2 ( b ) * *.

# # # 2. CeaseandDesist Ignored Despite my written ceaseanddesist demand, I have documented two ( 2 ) separate calls from XXXX ( XXXX XXXX ). I have preserved screenshots of these calls. This conduct violates * * 15 U.S.C. 1692c ( c ) * * and constitutes unlawful harassment.

# # # 3. Improper Assignment to Multiple Collectors Your own response admits this account was assigned to multiple thirdparty collection agencies. This admission creates additional legal violations : * * * FDCPA 1692g ( b ) : * * Once a debt is disputed, all collection activity must cease until validation is provided. Reassigning the account to multiple agencies without ever validating violates this section repeatedly.

* * * FDCPA 1692e ( 8 ) : * * It is unlawful to communicate credit information without disclosing that the debt is disputed. If XXXX failed to notify each agency of my dispute, this is a violation. 
* * * FCRA 1681s2 ( b ) : * * XXXX, as furnisher, has a duty to ensure accuracy and conduct a reinvestigation upon dispute. Passing the account around without maintaining a verifiable chain of custody demonstrates you can not validate the debt. 
* * * FCRA 1681i ( a ) ( 5 ) ( A ) : * * Unverifiable information must be deleted. Once an account has been assigned multiple times without a clear legal chain, continued reporting is not permissible. 

# # # 4. Legal Obligation to Delete Because XXXX has failed to validate and admits to multiple assignments without producing a legal chain of custody, the alleged debt is unverifiable. Under the FCRA, unverifiable information can not remain on my credit report. XXXX must immediately * * DELETE * * this tradeline from all consumer reporting agencies. 

# # # XXXX. Demand for CFPB Investigation XXXX repeated refusal to answer Questions XXXX, combined with unlawful reassignment and continued furnishing, reflects a pattern of systemic violations. I am demanding that the * * Consumer Financial Protection Bureau * * investigate * * XXXX XXXX XXXX XXXX  * * for ongoing noncompliance with the * * FCRA * * and * * FDCPA * *. 

Be advised : I will continue to file complaints with the CFPB until every one of my validation questions is answered in writing, in full, and until the disputed tradeline is deleted in accordance with the law. 

# # # 6. Immediate Demands XXXX must immediately : * Provide full written answers to Questions XXXX from my XX/XX/2025 letter. 
* Cease all telephone contact and fully honor my ceaseanddesist. 
* Delete all unverifiable information you continue to furnish to the CRAs. 
* Mark the account as * * disputed * * with all CRAs, as required by * * 15 U.S.C. 1692e ( 8 ) * *.

# # # 7. Notice of Intent Failure to comply will result in : * Additional * * CFPB * *, * * FTC * *, and * * California Attorney General * * complaints; * Civil litigation in * * federal court * * under the * * FCRA * * and * * FDCPA * * ; * Claims for statutory, actual, and punitive damages, as well as attorneys fees, pursuant to * * 15 U.S.C. 1681n * *, * * 1681o * *, and * * 1692k * *. 

This is your final opportunity to cure these violations before enforcement action is taken. 

-- - * * Sincerely, * * XXXX XXXX XXXX XXXX XXXX XXXX, CA XXXX cc : * * XXXX XXXX XXXX XXXXXXXX XXXX * * Attachment : Formal Complaint and Jury Demand Draft -- - # XXXX ) * * FINAL NOTICE BEFORE SUIT * * XXXX XXXX ( Acct ending XXXX ) * * From : * * * * XXXX XXXX * * XXXX XXXX XXXX XXXX, CA XXXX Email : [ XXXX ] ( XXXX : XXXX ) Phone : ( XXXX ) XXXX * * To : * * * * XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX, TX XXXX * * And To : * * * * XXXX XXXXXXXX XXXX XXXX XXXX XXXX ( Form Code # XXXX  ) * * XXXX XXXX XXXXXXXX XXXX XXXX, TX XXXX * * CC : * * TransUnion, XXXX, XXXX, XXXX ( Notice of Dispute/Deletion Request ) * * Via : * * XXXX XXXX and email/portal submission * * Date : * * XX/XX/2025 * * Reference : * * CFPB Complaints XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  Account : * * XXXX XXXX ending XXXX XXXX XXXX XXXX XXXX ( Acct No. XXXX XXXX XXXX XXXX XXXX ) -- - XXXX has * * ignored XXXX written notices * * and furnished only generic replies that do not constitute a reasonable furnisher reinvestigation under the * * FCRA * * and * * Regulation V * *. This * * Final Notice Before Suit * * demands immediate corrective action and preservation of evidence. 

# # XXXX. Procedural Posture and Record XXXX. * * XX/XX/2025 * * Direct written dispute with five validation items and a ceaseanddesist. 
XXXX. * * XX/XX/2025 * * XXXX Closed with explanation response lacking competent verification ( unsigned agreement, no chain of placement, no itemized accounting ). 
XXXX. * * XX/XX/2025 * * Third notice recorded; * * no adequate reinvestigation * * or production of business records ; continued reporting without proper dispute notation. 

# # XXXX. Governing Duties ( NonExhaustive ) * * * FCRA 623 ( b ), 15 U.S.C. 1681s2 ( b ) : * * Upon CRA notice of dispute, furnisher must conduct a * * reasonable reinvestigation * *, review * * all relevant information * *, and * * modify, delete, or block * * information that is inaccurate, incomplete, or * * can not be verified * * ; must * * report results * * to CRAs. 
* * * Reg V, 12 C.F.R. 1022.43 ( e ) : * * Reasonable investigation requires consideration of * * all * * relevant information provided by CRAs and consumer ; and use of * * reasonable procedures * *.

* * * FCRA 623 ( a ) ( 3 ) : * * XXXX must report the tradeline as * * disputed by consumer. * * * * * FCRA 611 ( a ) ( 5 ) ( A ), 15 U.S.C. 1681i ( a ) ( 5 ) ( A ) : * * CRAs must delete * * unverifiable * * information ; furnishers must enable that result by accurate responses. 
* * * FDCPA/ Rosenthal FDCPA : * * To the extent thirdparty collectors acted after disputes/C & D, * * 15 U.S.C. 1692g ( b ) * * and * * Cal. Civ. Code 1788.17 * * prohibit continued collection absent validation.

# # III. Material Deficiencies in XXXX  Handling XXXX. * * No competent contract/assent evidence. * * An * * unsigned * * card agreement is not competent proof of account formation, terms, or assent for the reported periods. 
XXXX. * * No chainofplacement/assignment. * * XXXX admits multiple placements but produced * * no * * complete chain, no agency instructions to * * cease collection pending validation * *, and no proof all collectors were notified the debt is * * disputed * * ( * * 1692e ( 8 ) * * risk ). 
XXXX. * * No itemized accounting * * tying the reported balance, late fees, and chargeoff to admissible business records ; no XXXX substantiation ; no interest/fee methodology. 
XXXX. * * No proof of dispute notation * * furnished to * * all CRAs * * as required by * * 623 ( a ) ( 3 ) * *.

5. * * Investigation not reasonable * * under * * 623 ( b ) * * / * * Reg V * * XXXX  replies are conclusory and fail to address the XXXX validation items sent * * XX/XX/2025 * *. 
XXXX. * * Ongoing harm * * the tradeline remains, impacting creditworthiness ; CRA results show * * continuing furnishing * * without adequate verification. 

# # IV. Demands ( 7Day Deadline from Receipt ) Within * * 7 calendar days * *, XXXX must : XXXX. * * Produce * * legible * * business records * * : executed application/contract ; monthly statements ; payment history ; DOFD ; chargeoff calculations ; itemized fees/interest ; correspondence logs ; and internal dispute workpapers ( including * * eOSCAR ACDVs/AUDs * * ). 
XXXX. * * Produce * * a full * * chainofplacement/assignment * * : engagement letters, account transfer manifests, start/stop dates, and written instructions to each agency to * * cease collection * * pending validation and to mark the debt as * * disputed * *. 
XXXX. * * Confirm in writing * * that all current and future reports to * * TransUnion, XXXX, XXXX, XXXX * * include the * * dispute notation * * consistent with * * 623 ( a ) ( 3 ) * *. 
XXXX. * * If any item above can not be produced * *, immediately * * instruct deletion/suppression * * of the tradeline with all CRAs and provide me copies of all deletion/suppression transmissions. 

# # V. Litigation Hold / Spoliation Notice Effective immediately, * * preserve * * all potentially relevant ESI and hardcopy records, including but not limited to : cardmember records ; call recordings ; dialer logs ; collector placements ; ACDV/AUD histories ; Metro 2 furnishing logs ; policies/procedures under * * 12 C.F.R. 1022.42 * * ; internal emails/notes concerning my disputes ; and communications with thirdparty collectors. Destruction or alteration may give rise to sanctions and adverseinference instructions. 

# # VI. Remedies Sought if NonCompliant If XXXX fails to comply by the deadline, I will file suit in the * * U.S. District Court for the XXXX XXXX XXXX XXXX XXXX  * seeking : ( a ) actual, statutory, and punitive damages under * * 15 U.S.C. 1681n, 1681o * * ; ( b ) fees and costs ; ( c ) injunctive and declaratory relief; and ( d ) all other relief deemed proper. I will also request * * CFPB supervisory referral * * and notify the * * California Attorney General * * and * * FTC * * of the pattern of noncompliance. 

* * Respectfully, * * * * XXXX XXXX * * XXXX XXXX XXXX XXXX, CA XXXX Enclosures : Prior dispute letters ( XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX ) ; XXXX replies ; CRA records ; call screenshots. 

-- - # XXXX ) * * Complaint Updates ( for Filing ) * * # # Add to * * III. FACTS * * ( new paragraphs ) 11A. On * * XX/XX/2025 * *, Plaintiff sent a * * third written notice * * ( Final Notice Before Suit ) to XXXX XXXX and its directdispute address ( Form Code # XXXX  ), reiterating the XXXX validation items and demanding production of competent records, chainofplacement, and proper dispute notation. 
XXXX. XXXX ignored or failed to adequately respond to the third notice and continued to furnish the tradeline without verifying the accuracy and completeness of the information, further evidencing an unreasonable reinvestigation under * * 15 U.S.C. 1681s2 ( b ) * * and * * 12 C.F.R. 1022.43 ( e ) * *. 
XXXX. Plaintiff suffered additional harm, including diminished creditworthiness and emotional distress, as the disputed tradeline remained reported without verification. 

# # Add * * COUNT 4 Willful Pattern or Practice of Noncompliance ( FCRA 1681n ) * * 16. XXXX  repeated failure, after multiple CFPB disputes and three written notices, to conduct a reasonable reinvestigation and to correct or delete unverifiable information constitutes a * * willful * * pattern or practice of noncompliance with * * 15 U.S.C. 1681s2 ( b ) * * within the meaning of * * 1681n ( a ) ( 1 ) ( A ) * *.

17. Plaintiff is entitled to * * statutory and punitive damages * *, costs, and attorneys fees under * * 1681n ( a ) ( 2 ) ( 3 ) * *.

* ( Clerkready caption, civil cover sheet, and in forma pauperis templates can be added on request. ) *

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