Consumer complaint received 2025-04-15 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: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: LA

Complaint narrative:
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  Consumer Financial Protection Bureau XXXX XXXX XXXX XXXX XXXX XXXX XXXX **RE : SECOND FORMAL COMPLAINT AGAINST TRANSUNION XXXX Multiple FCRA, TILA, GLBA, and Metro 2 Violations** **Complaint Reference Number : ** XXXX To Whom It May Concern : I am writing this second formal complaint regarding numerous, severe, and ongoing violations of federal consumer protection laws by TransUnion. Despite my previous complaint, the violations have continued and expanded, indicating willful non-compliance rather than isolated incidents. TransUnion 's credit reporting system has been non-functional for three consecutive days, preventing me from accessing my legally guaranteed rights under federal law. 

# # FCRA Violations 1. **FCRA 605 ( a ) ( 5 ) - Obsolete Information : ** TransUnion continues to report adverse information beyond the XXXX-year limitation period.

2. **FCRA 605 ( c ) - Running of Reporting Period : ** TransUnion has violated this provision which states : " The 7-year period referred to in paragraphs ( 4 ) and ( 5 ) of subsection ( a ) shall begin, with respect to any delinquent account that is placed for collection ( internally or by referral to a third party, whichever is earlier ), charged to profit and loss, or subjected to any similar action, upon the expiration of the 180-day period beginning on the date of the commencement of the delinquency which immediately preceded the collection activity, charge to profit and loss, or similar action. '' 3. **FCRA 605 ( c ) - Date of First Delinquency Manipulation : ** TransUnion has manipulated the Date of First Delinquency field, improperly " re-aging '' accounts to extend negative reporting beyond the statutory 7-year limit. This manipulation directly violates the precise timeframe requirements established in 605 ( c ).

3. **FCRA 611 ( a ) ( 1 ) - Reasonable Investigation Procedures : ** TransUnion has failed to conduct reasonable investigations of my disputes as evidenced by their system being completely non-functional for three consecutive days, preventing access to dispute status information.

4. **FCRA 611 ( a ) ( 5 ) - Reinsertion of Information : ** Previously deleted information has reappeared on my credit report without proper notification.

5. **FCRA 609 ( a ) - Disclosure Requirements : ** TransUnion has failed to provide complete disclosure of all information in my file, as their system displays : " Sorry, an error occurred trying to get your consumer statement information. Please try again later. '' 6. **FCRA 604 - Permissible Purpose : ** My credit report has been accessed without proper permissible purpose.

7. **FCRA 607 ( b ) - Accuracy Guidelines : ** TransUnion has failed to follow reasonable procedures to assure maximum possible accuracy of information in my report.

8. **FCRA 623 ( a ) ( 3 ) - Disputed Information : ** TransUnion has failed to properly mark disputed accounts in my credit file.

9. **FCRA 615 - Adverse Action Notice : ** I have not received proper adverse action notices when my credit applications were denied based on information in my TransUnion report. 

# # Metro 2 Format Violations 10. **Base Segment Field 17A ( Account Status ) : ** Accounts have been improperly coded with incorrect status codes, misrepresenting the true status of my accounts.

11. **Field 24 ( Date of First Delinquency ) : ** This critical field has been manipulated to show incorrect dates, directly violating FCRA 605 ( c ) ( 1 ).

12. **Field 25 ( Compliance Condition Code ) : ** Disputed accounts lack the required 'XB ' code designation.

13. **Fields 27-28 ( Consumer Information Indicator ) : ** TransUnion has failed to properly update these indicators to reflect disputed status.

14. **Payment History Profile : ** This 24-month payment pattern contains inaccuracies that do not reflect actual payment history.

# # TILA and GLBA Integration Violations 15. **TILA Disclosures in Credit Reporting : ** APR and finance charge calculations reported to TransUnion do not match the terms disclosed in my credit agreements.

16. **GLBA Privacy Framework : ** My nonpublic personal information has been shared without proper notice or opt-out opportunities.

17. **GLBA Safeguards Rule : ** TransUnion 's system failures ( 3 consecutive days of downtime ) demonstrate inadequate information security safeguards.

# # System Failure Documentation As evidence of ongoing violations, I have documented TransUnion 's system failure message : " Sorry, an error occurred trying to get your consumer statement information. Please try again later. '' This error has persisted for three consecutive days, preventing me from exercising my federally protected rights to access and dispute information in my credit file. This prolonged outage constitutes a separate and serious violation of FCRA 611 and demonstrates willful non-compliance with federal law.

# # # Legal Impact of 3-Day Duration The prolonged nature of this system failure is particularly significant because : 1. Under FCRA 611 ( a ) ( 1 ), TransUnion must complete investigations within 30 days. A 3-day system outage consumes 10 % of my statutorily guaranteed investigation period, which violates the " reasonable procedures '' requirement.

2. Courts have consistently ruled that persistent technical failures demonstrate a " willful '' violation rather than mere negligence, qualifying for higher statutory and potential punitive damages.

3. The extended duration creates a presumption of harm, as I have been repeatedly denied access to my legally protected information over multiple documented attempts.

# # # Documentation Strategy During Extended Outage During this ongoing system failure, I have implemented the following documentation strategy : 1. Maintained a detailed log of every attempt to access my information, including : - Date and exact time of each attempt - Screenshots showing continued error messages - System reference numbers displayed during failed attempts 2. Documented financial activities impacted during this period, including : - Credit applications submitted - Loan terms offered - Housing applications affected by the system failure 3. Recorded all communication attempts with TransUnion customer service, including : - Names of representatives - Call reference numbers - Their acknowledgment of the system issue - Any timeline provided for resolution # # Legal Framework Integration The violations documented above demonstrate systemic failures across interconnected regulatory frameworks : # # # FCRA-Metro 2 Integration Violations 1. **Industry Standard Compliance Failure : ** Metro 2 technical specifications serve as the legally recognized industry standard for accuracy under FCRA 623 ( a ) ( 1 ). TransUnion 's deviations from these standards constitute separate FCRA violations with each reporting cycle.

2. **Investigation Process Integration : ** TransUnion has failed to properly implement Metro 2 dispute codes to track investigation status as required by FCRA 611, with ACDV/AUD responses not following proper Metro 2 formatting .

3. **Data Integrity Across Frameworks : ** TransUnion has failed to maintain consistent Metro 2 reporting that aligns with TILA disclosure requirements, creating a cross-framework violation pattern. Payment histories in Metro 2 data do not match TILA billing statements, and Terms Duration fields conflict with loan documents.

4. **Security Framework Violations : ** TransUnion 's Metro 2 data transmissions fail to comply with GLBA safeguards requirements, with consumer identification fields exposed to privacy violations and inadequate security controls as evidenced by the system outage.

# # # Evidence Collection Strategy I have implemented a comprehensive evidence collection strategy that includes : 1. Full documentation of each Metro 2 technical field error with specific identification of incorrect field values 2. Preservation of all E-OSCAR ACDV responses showing uncorrected Metro 2 errors 3. Timestamped records of multiple dispute attempts for identical Metro 2 field errors 4. Documentation of economic damages resulting from credit score impacts of these errors 5. Complete collection of all system failure evidence supporting willful non-compliance claims # # Request for Action I respectfully request that the CFPB : 1. Conduct a thorough investigation of all violations listed above 2. Order TransUnion to immediately correct all inaccuracies in my credit report 3. Assess appropriate civil penalties for the willful violations documented 4. Require TransUnion to provide evidence of corrective measures taken to prevent future violations 5. Monitor TransUnion 's compliance with federal law for a reasonable period 6. Address the systemic integration failures between FCRA, TILA, GLBA, and Metro 2 compliance 7. Consider how the 3-day system outage demonstrates a pattern of willful non-compliance I am prepared to pursue all available legal remedies including litigation to protect my rights under federal law. These violations have caused measurable harm to my creditworthiness, financial stability, and ability to secure favorable credit terms.

All information in this complaint is true and accurate to the best of my knowledge. 

Sincerely, XXXX XXXX Enclosures : - Screenshots of TransUnion system failure ( dated ) - Copy of previous CFPB complaint - Credit report copies showing inaccuracies - Dispute correspondence records- Documentation of credit denials resulting from inaccurate reporting

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 explanation