Consumer complaint received 2025-11-09 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: Servicer under contract with Federal Student Aid
State: TN

Complaint narrative:
Re : Complaint / Enforcement Request Furnisher failed to respond to dispute ( letter sent XX/XX/XXXX ) and is reporting an inaccurate XXXX delinquency without XX/XX/XXXX progression ( Account : XXXX XXXX XXXX XXXX To Whom It May Concern : I am filing this complaint to request CFPB enforcement and assistance. On XX/XX/XXXX, I sent a written dispute and demand for documentation to Dept of Edu. regarding an allegedly reported XXXX late on my credit report. The furnisher never responded. I then filed disputes with the three credit reporting agencies. 

Summary of the problem The account is currently reported as a XXXX delinquency on my credit report. 
The tradeline as reported shows no XXXX or XXXX entries preceding the XXXX status ( i.e., there is no progressive XXXX history ). 
The furnisher reported the account inaccurately and/or incompletely specifically the payment history progression and the Date of First Delinquency ( DOFD ) used to justify the XXXX status. 
I sent a demand for the furnishers supporting documentation on XX/XX/XXXX ). They failed to respond within the required period and have not corrected the tradeline. This lack of a response and continued inaccurate reporting appears to violate the furnishers duties under the FCRA. 

Why this matters ( legal basis ) Furnishers must conduct a reasonable investigation and correct or delete inaccurate information once they receive notice of a dispute. See 15 U.S.C. 1681s-2 ( b ).

Legal Information Institute Credit reporting must reflect accurate payment history and accurate Date of First Delinquency ( DOFD ). The XXXX guidance requires DOFD to reflect the first time the consumer was 30 days past due that led to the current delinquency status, and payment history should be reported in a sequential, accurate manner ( XXXX ). Reporting a XXXX without prior XX/XX/XXXX progression is inconsistent with XXXX expectations and can make reporting inaccurate. 

CFPB and FTC guidance confirm furnishers are responsible for policies and procedures that ensure the accuracy of furnished data and that DOFD errors are a known area of enforcement concern. 


Courts have held that CRAs/furnishers have a duty to reasonably reinvestigate disputes and can be liable when they fail to do so ( see e.g., Cushman v. Trans Union , 115 F.3d 220 ( 3d Cir. 1997 ) ). 
XXXX XXXX What I am requesting the CFPB to do Require Dept of Edu. to produce the exact records they furnished to each CRA for this tradeline for the reporting months in question specifically the XXXX submission files or export, including the DOFD field and Payment History Profile / Payment Rating codes they transmitted to XXXX XXXX and XXXX. ( XXXX exports are the raw evidence of what they reported. ) Require the furnisher to produce the complete account ledger and payment posting history ( cycle dates, posting dates, payment application ) that they relied on to determine the XXXX status. 

If the furnisher can not produce a XXXX submission showing prior XXXX and XXXX entries ( or otherwise demonstrate a proper DOFD and progression ), require them to delete the XXXX tradeline from all CRAs and confirm in writing. 

If the furnisher did not respond to my XX/XX/XXXX demand within the required time or failed to perform a reasonable reinvestigation per 1681s-2 ( b ), pursue appropriate enforcement or remedial action ( including requiring correction, deletion, and any available remedies ).

Legal Information Institute Documents I am attaching ( or will upload during CFPB submission ) Copy of letter mailed on XX/XX/XXXX demand to the furnisher. 
Copy of credit report copy of ID and Proof of add. 


Why CFPB should act now If the furnishers XXXX submissions or ledger do not substantiate the XXXX reporting ( i.e., no prior XX/XX/XXXX, incorrect DOFD, or inconsistent posting dates ), that constitutes inaccurate and misleading reporting and a failure to maintain reasonable procedures to assure accuracy in violation of FCRA and XXXX expectations XXXX CFPB intervention is needed to obtain the furnishers raw reporting files ( XXXX exports ) and ledger so this can be verified and corrected. 

Requested relief ( summary ) Produce the XXXX submission and account ledger within 30 days to the CFPB examiner. 
If no supporting evidence for the XXXX exists, require deletion/correction of the tradeline with all three CRAs and written confirmation to me. 
If the furnisher failed to reasonably investigate or failed to respond to my XX/XX/XXXX demand, consider enforcement action under FCRA 1681s-2 and applicable CFPB supervisory authority. 

Thank you for your prompt attention to this matter. Please update these late payments. 

Sincerely,

Company response to consumer: Untimely response