Consumer complaint received 2025-09-14 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:
I request that the CFPB ( 1 ) open an immediate enforcement investigation into Experian, Equifax, TransUnion, and involved furnishers ; ( 2 ) compel deletion and suppression of all disputed/identity-theft data ; ( 3 ) require certified documentation ( Method of Verification ) for any item retained ; ( 4 ) order removal of all dispute comments and fraud alerts that are obstructing mortgage approvals ; ( 5 ) require a reinsertion-prevention plan compliant with FCRA 611 ( a ) ( 5 ) ( B ) ; ( 6 ) impose UDAAP remedies and civil money penalties ; and ( 7 ) require restitution and make referrals to DOJ and appropriate agencies for criminal violations where applicable. I request full corrective action within four ( 4 ) calendar days due to ongoing housing harm.

Factual Background I am a documented identity-theft victim ( FTC Report # above ). Over the past year, I submitted disputes to the national CRAs for fraudulent accounts, personal-data errors ( addresses, name variation, DOB ) , and unauthorized inquiries. The CRAs responded using automated workflows ( E-OSCAR/ACDV ) , returned boilerplate outcomes, and reinserted previously deleted items without certification or notice, while also attaching or retaining dispute comments and internal fraud alerts that blocked my mortgage approval and access to VA/FHA products.

The CRAs and/or furnishers trafficked my nonpublic data to secondary/tertiary consumer reporting agencies and data brokers ( e.g., XXXX, XXXX, XXXX, XXXX, XXXX, XXXX, XXXX  ) without my consent, magnifying harm, exposure, and denial impacts. I am a XXXX veteran ; these actions aggravate harm under federal servicemember protections.

Harms Real-estate denial and mortgage obstruction due to improper dispute comments/fraud alerts and identity-theft reinsertion.

Financial suppression : inflated rates, lost approvals, reduced credit access.

Emotional distress and reputational damage ( ongoing ).

Continued identity-theft exposure from unauthorized sharing and weak safeguards.

Violations ( Primary ) FCRA : 1681e ( b ) ( maximum possible accuracy ), 1681i ( reasonable reinvestigation ; anti-automation rubber-stamping ), 611 ( a ) ( 5 ) ( B ) ( reinsertion certification & written notice ), 1681g ( file disclosure ), 1681b ( permissible purpose ), 1681c-2 ( 605B identity-theft block ), 1681s-2 ( furnisher duties ).

CFPA / Dodd-Frank Title X ( UDAAP ) : unfair, deceptive, abusive acts and practices ; CFPB enforcement authority.

GLBA + FTC Safeguards Rule & Red Flags Rule : failure to protect nonpublic information ; failure to detect/respond to identity-theft patterns.

ECOA ( Reg B ), FHA, RESPA, ADA : discrimination and housing/credit obstruction via dispute comments, fraud alerts, and inaccurate file handling.

SCRA ( servicemember protections ) and VA lending protections : aggravated harms to a veteran.

CFAA ( 18 U.S.C. 1030 ), CIRCIA/Cybersecurity Enhancement : deficient controls leading to exposure/abuse of personal data.

18 U.S.C. 241242, 1028 : civil-rights conspiracy and identity-theft-related misconduct ( for referral ).

State privacy and UDAP ( e.g., CCPA/Cal. Civ. Code 1798 et seq. ).

UCC 1-308 ( reservation of rights ) regarding any alleged consent or contracts.

Why E-OSCAR Use Here Violates the Law The bureaus appear to have routed my disputes through E-OSCAR, returning perfunctory ACDV results without substantive review. Indicators include : ( a ) form-letter denials ; ( b ) failure to address specific identity-theft evidence ; ( c ) rapid verified/updated toggles inconsistent with manual review ; ( d ) reinsertion of items previously removed, without a furnishers certification and without written notice required by FCRA 611 ( a ) ( 5 ) ( B ). Reliance on automated templates in lieu of a meaningful reinvestigation violates 1681i, and perpetuates inaccuracy in violation of 1681e ( b ). E-OSCAR may assist data exchange, but it can not substitute the bureaus statutory duties. 

Specific Items in Dispute ( for deletion/suppression across all CRAs and resellers ) XXXX Account # XXXX {$440.00} Collection/Charge-off, XXXX XXXX XXXX Incorrect Address ( Current ), XXXX XXXX XXXX XXXX Incorrect Address ( Previous ), XX/XX/XXXX Incorrect DOB variation, XXXX XXXX XXXX Incorrect Name variation , all other derogatory, unverifiable, fraudulent, obsolete, reinserted, and suppressed data across Experian, Equifax, TransUnion, XXXX, XXXX, XXXX, XXXX, XXXX, XXXX, XXXX, and affiliated resellers.

Documents the CFPB Should Compel ( MOV and Compliance Proof ) Identity-theft block actions under FCRA 605B ; all reasons for any refusal.

Reinsertion certification from each furnisher, plus written reinsertion notices sent to me ( or proof that none exist ).

Full Method of Verification per item : contracts/notes, wet-ink or e-signature records, consent logs, IP addresses, device/browser fingerprints, timestamped audit trails, call/voice recordings, ACDV/CDV/AUD packets, Metro-2 fields used to verify, and screen-prints from furnisher systems.

E-OSCAR audit logs showing dispute codes, timestamps, response codes, human reviewer IDs, decision matrices/algorithms used, and escalation steps.

Data-sharing map and access logs identifying every third party that received or accessed my data since XXXX.

GLBA/Safeguards/Red Flags program documents ( policies, risk assessments, training logs, vendor management files, incident response records ).

Adverse-action notices or any notices tied to fraud alerts/dispute comments that blocked mortgage underwriting.

All communications among the CRAs and furnishers regarding my disputes, identity-theft status, and reinsertion decisions.

Required CFPB Remedies and Enforcement 1. Order immediate deletion/suppression of all disputed and identity-theft items listed above across all CRAs and downstream resellers.

2. Order removal of all dispute comments/fraud alerts that are obstructing mortgage approvals unless explicitly requested by me.

3. Require certified MOV for any item the bureaus propose to retain ; if not produced, the item must be deleted.

4. Mandate a reinsertion-prevention protocol : no item may reappear without 611 ( a ) ( 5 ) ( B ) furnisher certification and prior written notice to me.

5. Impose UDAAP remedies and civil penalties ; require a compliance plan, independent audit, and senior-officer certifications.

6. Restitution : require the CRAs/furnishers to compensate me for financial and housing harms.

7. Referrals : where the record shows willful or reckless noncompliance, refer to DOJ and appropriate agencies for potential criminal/civil action.

Relief and Compensation Sought Immediate correction of my consumer files ; permanent removal of all disputed/identity-theft items and comments.

Restitution and damages for housing denial, rate inflation, credit suppression, identity-theft exposure, emotional distress, reputational harm, and veteran-specific harms.

Written confirmation of all deletions/suppressions sent to me and all parties that previously received the inaccurate data.

Costs and fees associated with remediation and monitoring.

Four-Day Urgency Because the unlawful reinsertion and dispute-commenting are actively blocking mortgage approval and veteran housing access, I request full corrective action within four ( 4 ) calendar days of CFPB receipt. Every day of delay compounds the harm.

Certification : I declare under penalty of perjury that the facts provided are true and correct to the best of my knowledge. I authorize the CFPB to share this complaint with the named CRAs, furnishers, and regulators for investigation and enforcement. 

Complainant : XXXX XXXX Date : XX/XX/XXXX XXXX

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