Consumer complaint received 2025-08-13 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: OH

Complaint narrative:
CFPB Complaint Unlawful Collection & Credit Reporting Company : XXXX  XXXXXXXX XXXX 
XXXX XXXX. : XXXX XXXX ) Summary of the Problem XXXX  XXXX XXXX ( and/or its third-party collection agent, if any ) is reporting and attempting to collect an alleged debt account no. XXXX. The reporting is inaccurate and/or can not be substantiated with required documentation. Despite my dispute, the furnisher has continued to report and/or collect without providing legally required validation and without conducting a lawful reinvestigation. I am requesting immediate deletion of the tradeline from all consumer reporting agencies and cessation of all collection activity. 
2 ) What Im Asking the CFPB to Do Require XXXX  XXXX XXXX ( and any collector it employs ) to : Delete the account from Equifax, Experian, and TransUnion ; Cease all collection unless and until full validation compliant with law is provided ; Provide me with the documents listed in Section 5 below ; and Correct their policies, procedures, and Metro 2 reporting controls.

Record this complaint in the Company Response database.

3 ) Legal Grounds ( Violations Cited ) A. Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692 et seq. ( if a third-party collector is involved ) 1692g ( a ) & ( b ) Validation notice and cease-collection pending validation. Collector failed to provide complete validation and/or continued collection/reporting without first mailing verification of the debt.

1692e False, deceptive, or misleading representations ( including misrepresenting legal status/amount/credit reporting status ).

1692f Unfair or unconscionable means ( e.g., reporting disputed debt as undisputed, collecting fees not authorized by agreement or law ).

1692c Communications at inconvenient times/places or after written request to limit/cease.

Regulation F, 12 C.F.R. Part 1006 Including 1006.34 ( validation information content/format ), 1006.26 ( time-barred debt disclosures and suits ), and recordkeeping requirements.

B. Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., and Regulation V, 12 C.F.R. Part 1022 1681s-2 ( a ) Furnishing accurate information & duty to correct/update ; prohibition on reporting information known to be inaccurate ; duty to provide notice of dispute to CRAs.

1681s-2 ( b ) Duties after notice of dispute from a CRA : reasonable investigation, review of all relevant information, correct/delete within required time.

1681i CRA reinvestigation obligations ; furnishers failure to reasonably investigate causes/maintains inaccurate reporting.

1681e ( b ) Requirement to follow reasonable procedures to assure maximum possible accuracy.

1681c ( a ) Obsolescence rules ( no reporting beyond allowable period ).

Regulation V ( 12 C.F.R. Part 1022, Subpart E ) Furnisher Rule : 1022.401022.43, including policies/procedures for accuracy and integrity of furnished information ; specific duty to investigate direct disputes and correct/delete when information can not be verified.

C. Credit Reporting Format / Industry Standards ( supporting basis ) CDIA Metro 2 and the CRAs Credit Reporting Resource Guide ( CRRG ) require accurate coding ( e.g., dispute code XB during investigation, proper Date of First Delinquency, status codes, and prohibition on re-aging ). Failure to follow these standards causes/maintains inaccuracy and violates the FCRAs accuracy and integrity requirements above. 
D. Indiana Law ( supplemental ) Indiana Collection Agency Licensing Ind. Code 25-11-1 et seq. ( collection agencies must be properly licensed ; violations can void the ability to lawfully collect and constitute deceptive practices ). 
Indiana Deceptive Consumer Sales Act Ind. Code 24-5-0.5 et seq. ( prohibits deceptive or unconscionable consumer sales practices, including misrepresentations about a consumers debt or legal rights ).

Indiana Statutes of Limitation Ind. Code 34-11-2-9 ( 6 years ) & 34-11-2-11 ( 10 years ) depending on the contract type. If this account is time-barred, any implication that a lawsuit is permissible or failure to give required time-bar disclosures ( also addressed by Reg F 1006.26 ) is unlawful.

( If the company is not licensed, is using a name other than its licensed name, is collecting outside the SOL, or is failing to give time-bar disclosures, those are additional violations. ) 4 ) Facts ( Brief ) The account XXXX is being reported by XXXX  XXXX XXXX as a collection. 
I disputed the account and requested validation but no response. 
The company failed to provide complete validation as required ( no original signed agreement, no full account-level transaction history, no chain of title/assignment ). 
Despite the dispute, the company continued to report the tradeline to the CRAs without marking it as disputed, and/or with inaccurate balances, dates, or status. 
Any validation provided consisted of generic billing screens/letters, not the contract and itemized records required to verify the amount, ownership, and legal enforceability. 
On information and belief, either ( a ) the Date of First Delinquency is incorrect ( re-aging ), ( b ) the amount includes fees/interest not authorized by the original agreement or applicable law, and/or ( c ) the account may be time-barred under Indiana law.

5 ) Documents/Information I Am Demanding Please compel XXXX  XXXX XXXX XXXX and any collector ) to produce within 30 days : Original contract or signed application establishing my liability and the governing terms ; Complete account-level ledger from inception : all transactions, fees, interest, and adjustments ; Itemized calculation of the current balance with the contractual/legal basis for each fee/charge ; Chain of title/assignment showing lawful ownership/authority to collect ( every transfer with dates and consideration ) ; Date of First Delinquency ( DOFD ) used for credit reporting and evidence supporting that date ; Furnisher policies & procedures required by Reg V 1022.42, including accuracy/integrity controls and Metro 2 coding rules ; Validation notice compliant with FDCPA 1692g and Reg F 1006.34 ( including itemization date, itemized amounts, and dispute/cease-collection rights ) ; Licensing proof under Ind. Code 25-11-1 ( name used to collect must match license ) ; If the debt is time-barred, the time-bar disclosures required by Reg F 1006.26 and a written confirmation that no suit will be filed.

6 ) Specific Violations Observed ( Check all that apply ) Reported the account without a permissible purpose or after charge-off without ownership/assignment ( FCRA 1681b ( f ), 1681s-2 ( a ) ).

Failed to mark the tradeline as disputed while investigating ( FCRA 1681s-2 ( a ) ( 3 ) ; Metro 2 XB code ).

Re-aged the account by altering DOFD ( FCRA 1681c ( a ) ; accuracy/integrity duties ).

No reasonable investigation of disputes received from CRAs ( FCRA 1681s-2 ( b ) / 1681i ).

Continued collection and/or reporting without first mailing verification ( FDCPA 1692g ( b ) ).

Misstated amount/legal status or added unauthorized fees ( FDCPA 1692e, 1692f ).

Attempted to collect or implied ability to sue on a time-barred debt ( Reg F 1006.26 ; FDCPA 1692e ).

Operated without proper Indiana license or used an unlicensed/assumed name ( Ind. Code 25-11-1 ).

Engaged in deceptive/unconscionable practices ( Ind. Code 24-5-0.5 ).

7 ) Requested Relief Immediate deletion of the XXXX  XXXX XXXX tradeline for Account XXXX from Experian, Equifax, and TransUnion ; Written confirmation that collection has ceased and that no sale/transfer will occur while the account is disputed ; Corrected internal procedures to ensure future compliance with FCRA/Reg V, FDCPA/Reg F, Metro 2, and Indiana law ; Provision of all documents listed in Section 5 ; Any other relief the CFPB deems just and proper.

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