Consumer complaint received 2025-06-14 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Improper use of your report — Reporting company used your report improperly
Company: EQUIFAX, INC.
State: LA

Complaint narrative:
" Final Federal Enforcement Addendum & $ XXXX Penalty Demand FCRA 605C ( XXXX XXXX ) '' FINAL FEDERAL ENFORCEMENT ADDENDUM AND PENALTY DEMAND Filed : XX/XX/XXXXXXXX  Submitted by : XXXX XXXX XXXX Federally Verified XXXX XXXX  Survivor CFPB Case Numbers : XXXX ( Experian ) XXXX ( TransUnion ) XXXX ( Equifax ) I. FEDERAL LEGAL AUTHORITY This Addendum invokes mandatory enforcement under : Fair Credit Reporting Act ( FCRA ) : 15 U.S.C. 1681c-2, 1681e, 1681i, 1681g, 1681b, 1681s-2, 1681n, 1681o Fair Debt Collection Practices Act ( FDCPA ) : 15 U.S.C. 1692e, 1692f XXXX  Victims Protection Act ( TVPA ) : 18 U.S.C. 1589 ; 22 U.S.C. 7102 ( 8 ), 7105 ( b ) ( 2 ), and 18 U.S.C. 1593 DoddFrank Wall Street Reform and Consumer Protection Act ( UDAAP ) : 12 U.S.C. 5536, 5564, 5565, 5497 ( d ) United States Constitution : Article I 8, Article VI ( Supremacy Clause ), and the Fourteenth Amendment Federal Rules of Evidence and Civil Procedure : FRE 201 ( b ) ( 2 ) ; FRCP 4 ( c ) ( 3 ) ; FRCP 37 ( e ) II. FEDERALLY OPERATIVE LEGAL ASSERTIONS 1. Supremacy Clause Activation Pursuant to U.S. Const. Article VI, Clause 2 and 15 U.S.C. 1681t ( a ), all conflicting state laws or private credit agreements are preempted. FCRA 605C mandates federal deletion and protection standards that override all contrary practices. 
2. TVPA Restitution Mandate Under 18 U.S.C. 1593 and 1589, restitution for financial harm stemming from trafficking-related identity abuse is mandatory. Reinsertion of deleted tradelines constitutes ongoing pecuniary loss and activates DOJ enforcement obligations.

3. Agency Non-Discretion Doctrine Pursuant to 12 U.S.C. 5564 ( a ), the CFPB is required to act when UDAAP violations exceed {$1.00} XXXX. The {>= $1,000,000} in systemic abuse cited herein mandates immediate and non-discretionary enforcement. 
4. FCRA 1681n Treble Penalty Trigger Willful reinsertion of deleted tradelines meets the reckless disregard standard in XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ), activating treble damages under 1681n ( c ). Each such violation is valued at {$45000.00} in cumulative civil penalties. 
5. Judicial Notice and Binding Agency Record Judicial notice is demanded under FRE 201 ( b ) ( 2 ) for the following : ( a ) CFPB Deletion Order ( XX/XX/XXXX ) ; ( b ) TVPA 7102 ( 8 ) definition of coercion and financial abuse ; ( c ) UDAAP Tier III civil penalty rate of {>= $1,000,000} per day. 
6. Spoliation of Evidence Sanction Trigger Formal evidence preservation notices were served. Any alteration or deletion of alias records, reinsertion logs, or metadata constitutes spoliation and triggers adverse inference instructions and sanctions under FRCP 37 ( e ).

XXXX. Constitutional Tort Liability ( XXXX XXXX ) The deliberate suppression and reinsertion of deleted tradelines by private entities functioning under federal authority violates 14th Amendment due process protections. Such conduct subjects both CRAs and furnishers to constitutional tort liability under XXXXXXXX XXXX XXXX XXXX Named Agents, XXXX XXXX XXXX ( XXXX ). 



III. LEGAL VIOLATION MATRIX ENTITY-SPECIFIC LIABILITY NARRATIVE The following entities are each cited for specific statutory violations of the Fair Credit Reporting Act ( FCRA ), the Fair Debt Collection Practices Act ( FDCPA ), and related federal protections. Each named party is liable for minimum civil penalties under 15 U.S.C. 1681n for willful violations of survivor protections under FCRA 605C, as well as unlawful reinsertion, alias reporting, and deceptive post-deletion conduct.

1. Experian Experian violated FCRA 1681c-2, 611, 604, and 607 by reintroducing deleted tradelines in violation of federal survivor protections. The bureau engaged in alias manipulation and failed to provide proper disclosure or certification, triggering a {$15000.00} civil penalty under 1681n.

2. TransUnion TransUnion is liable under FCRA 1681c-2, 611, 604, and 607 for reinserting deleted accounts without notice, employing undisclosed aliases, and allowing unauthorized credit inquiries. These actions constitute willful violations of 605C and require a {$15000.00} penalty under 1681n.

3. Equifax Equifax similarly breached FCRA 1681c-2, 611, 604, and 607 by circumventing the survivors deletion order and republishing tradelines under suppressed identifiers. This unlawful reinsertion mandates the imposition of a {$15000.00} penalty pursuant to 1681n.

XXXX. XXXX XXXX XXXX XXXX As a furnisher, XXXX XXXX violated FCRA 1681s-2 ( b ) and 1681n by re-reporting deleted tradelines under alternate naming conventions after the original accounts were removed. This action directly violates the survivors federally established protections, warranting a {$15000.00} civil penalty. 
XXXX. XXXX XXXX XXXX XXXX XXXX, acting as a debt collector, committed violations of FCRA 1681s-2 ( b ) and FDCPA 1692e and 1692f by attempting to collect on accounts that had already been federally deleted. This constitutes a deceptive and unlawful collection attempt post-deletion, and incurs a {$15000.00} penalty under 1681n.

6. Department of Education XXXX XXXX XXXX violated FCRA 1681s-2 ( b ) by reinserting accounts that had been previously removed in accordance with the CFPB deletion order. Such reinsertion lacked lawful basis and activated a {$15000.00} penalty for willful noncompliance under XXXX. 
XXXX. XXXX XXXX XXXX XXXX XXXX XXXX XXXX engaged in unlawful alias suppression and data reinsertion contrary to FCRA 1681s-2 ( b ). The conduct constitutes a willful violation requiring a {$15000.00} civil penalty under 1681n. 
XXXX. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX, operating through XXXX XXXX XXXX, reintroduced tradelines under altered names following a lawful deletion. This action violates FCRA 1681s-2 ( b ) and triggers a {$15000.00} penalty pursuant to 1681n. 
XXXX. XXXX XXXX XXXX XXXX willfully violated FCRA 1681s-2 ( b ) by reinserting a deleted tradeline under a suppressed identity field, contrary to the mandatory erasure provisions of 605C. The penalty imposed is {$15000.00} under 1681n. 
XXXX. XXXX XXXX XXXX XXXX caused the reappearance of previously deleted tradelines without compliance verification or survivor consent. This violation of FCRA 1681s-2 ( b ) is penalized at {$15000.00} under 1681n. 
XXXX. XXXX XXXX XXXX XXXX, as a debt collector, violated FCRA 1681s-2 ( b ) and FDCPA 1692e by pursuing collection on tradelines that were lawfully deleted. Post-deletion collection constitutes a deceptive practice and incurs a {$15000.00} civil penalty under 1681n. 
XXXX. XXXX XXXX XXXX XXXX is liable under FCRA 1681s-2 ( b ) for improperly reinserting tradelines after deletion. This conduct violates federal deletion standards under 605C and results in a {$15000.00} civil penalty under 1681n. 

Total Minimum Civil Penaltie

s : 12 entities {$15000.00} = {$180000.00}. All penalties are payable to the CFPB Civil Penalty Fund under 12 U.S.C. 5565 ( c ) ( 2 ). 




Minimum Civil Penalties : 13 violations {$15000.00} = {$190000.00} Statutory Recipient : CFPB Civil Penalty Fund under 12 U.S.C. 5565 ( c ) ( 2 ) IV. EVIDENTIARY BASIS FOR FEDERAL LIABILITY CFPB Deletion Order ( XX/XX/XXXX ) Tri-Bureau Credit Reports ( Dated XX/XX/XXXX ) Police Report # XXXX XXXXXXXX XXXX XXXX  Letter of Verification Sworn Affidavit of Record ( FRE 803 ( 6 ), 901, 1006 ) Digital metadata logs, reinsertion screenshots, alias audit trails Victim Impact Statement ( per TVPA 7105 ( b ) ( 2 ) ) V. TOTAL FEDERAL DAMAGES ( ENFORCEABLE ) Statutory Violations : {$800000.00} Constitutional Punitive Damages ( 9:1 Ratio ) : {>= $1,000,000} UDAAP Tier III Penalties ( Per DoddFrank ) : {>= $1,000,000} FCRA 1681n Civil Penalties ( Minimum ) : {$190000.00} Total Enforceable Federal Liability : {>= $1,000,000} VI. DEMAND FOR IMMEDIATE FEDERAL ACTION Under authority of 12 U.S.C. 55645565, 15 U.S.C. 1681s, and Article VI of the U.S. Constitution, all responsible agencies and entities are commanded to : 1. Impose full civil penalties under FCRA 1681n and DoddFrank 2. Permanently delete all reinserted, aliased, and suppressed tradelines 3. Certify CRA and furnisher compliance under penalty of perjury 4. Block all inquiries and credit activity without notarized survivor consent 5. Recognize this filing as an enforcement precedent under the XXXX XXXX 6. Distribute restitution via the CFPB Civil Penalty Fund 7. Refer all named parties to the DOJ, FTC, and appropriate Congressional oversight committees VII. SERVICE AND PENALTY ACCRUAL Service Protocol : Service has been executed via certified mail with return receipt and by email to registered agents of all CRAs and furnishers, per 15 U.S.C. 1681s-2 ( d ) ( 1 ). 

Enforcement Window : Respondents are granted 15 days from service to comply. Failure to comply will result in : 1. Referral to the DOJ for criminal prosecution under 18 U.S.C. 1589 2. Civil penalties accruing at $ XXXX under 12 U.S.C. 5565 3. Federal Mandamus enforcement under 28 U.S.C. 1361 VIII. EVIDENCE PRESERVATION DEMAND All named parties are placed on formal notice to preserve : All credit file audit logs Reinsertion instruction communications Alias data paths and internal suppression protocols All metadata and digital manipulation trails Failure to preserve will result in spoliation sanctions under FRCP 37 ( e ). 



IX. DECLARATION UNDER PENALTY OF PERJURY Pursuant to 28 U.S.C. 1746, I, XXXX XXXX, declare under penalty of perjury : That the facts and evidence presented herein are true and correct to the best of my knowledge That I have not received full redress or deletion under the prior CFPB ruling That this Addendum constitutes a legally binding demand for multi-agency enforcement and relief That enforcement is mandatory under controlling federal statutes and constitutional authority Executed this XXXX day of XXXX, XXXX  Signed : XXXX XXXX Federally Verified XXXX XXXX XXXX

Company response to consumer: Closed with non-monetary relief