Consumer complaint received 2025-05-24 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Problem with a company's investigation into an existing problem — Investigation took more than 30 days
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: MD

Complaint narrative:
Complaint for Violations of the Fair Credit Reporting Act Introduction : Nature of the Action : Plaintiff XXXX XXXX XXXX ( hereinafter Plaintiff ) brings this Complaint against Defendant TransUnion Consumer Solutions ( TransUnion ) for repeated and willful violations of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., and for failure to comply with industry Metro 2 reporting standards. Plaintiff alleges that TransUnion has persistently reported inaccurate and fraudulent information on his credit report and failed to conduct reasonable reinvestigations of disputed information, in violation of federal law. Despite multiple disputes and a prior identity theft report, TransUnion has continued to report erroneous account information, causing ongoing harm to Plaintiffs credit reputation and financial well-being.

Summary of Violations : TransUnions wrongful conduct includes : ( a ) reporting charged-off accounts with ongoing past-due balances, which is inconsistent with FCRA accuracy requirements and Metro 2 guidelines
; ( b ) failing to reinvestigate and correct these inaccuracies within the time frame required by law ; ( c ) refusing to provide Plaintiff with the documentation or description of its investigation as required ; and ( d ) effectively performing only cursory, automated investigations that merely parrot furnishers responses, contrary to the FCRAs mandate of a genuine, reasonable investigationcaselaw.findlaw.comcaselaw.findlaw.com. These practices have been condemned by courts and regulators alike, including in a recent enforcement action where the Consumer Financial Protection Bureau ( CFPB ) described TransUnions dispute handling as sham investigations that flout federal lawconsumerfinance.gov.

Purpose of Complaint : Through this legal-style complaint ( modeled as a federal civil action ), Plaintiff seeks to compel TransUnion to immediately delete all disputed, inaccurate accounts from his credit file and to ensure full compliance with the FCRA and Metro 2 standards. Plaintiff further puts TransUnion on notice that failure to comply within 14 days will result in legal action in federal court, where Plaintiff will seek all available relief, including statutory and punitive damages for TransUnions willful noncompliance. This Complaint is deliberately structured in a formal legal manner so as to bypass automated e-OSCAR dispute processing and demand direct attention from TransUnions compliance and legal departments.

Jurisdiction and Venue : Jurisdiction : This Court has subject matter jurisdiction over this action pursuant to 15 U.S.C. 1681p and 28 U.S.C. 1331, because Plaintiffs claims arise under the federal Fair Credit Reporting Act. TransUnions violations of 15 U.S.C. 1681i and 1681e ( b ) give rise to a private right of action for which Plaintiff seeks relief. Supplemental jurisdiction over any state law claims ( if asserted ) would be proper under 28 U.S.C. 1367. 
XXXX  : XXXX is proper in this District under 28 U.S.C. 1391 ( b ) because Plaintiff resides in this District and the events giving rise to the claims occurred here. TransUnion regularly conducts business in this District and maintains substantial contacts here. TransUnion, as one of the nations largest consumer reporting agencies, is subject to personal jurisdiction in this District and throughout the United States. Given that the harm to Plaintiffs credit report was felt in this District, venue is appropriate for the adjudication of this dispute. 

Intradistrict Assignment : ( If applicable under local rules. ) The events described herein occurred primarily in the county of Plaintiffs residence ( XXXX XXXX, Maryland ). Accordingly, assignment to the XXXX XXXX of this XXXX would be proper. 

Parties Plaintiff : XXXX XXXX XXXX is a natural person and consumer residing in XXXX XXXX, XXXX. Plaintiff is a consumer as defined by 15 U.S.C. 1681a ( c ), in that he is an individual about whom TransUnion prepares and furnishes consumer credit reports. Plaintiff has at all relevant times been the victim of false and inaccurate credit reporting by TransUnion, which has adversely affected his credit score, credit opportunities, and peace of mind. 

Defendant : TransUnion Consumer Solutions/TransUnion LLC ( TransUnion ) is a publicly traded company in XXXX under the ticker symbol XXXX on the XXXX XXXX XXXX XXXX XXXX TransUnion principal place of business is XXXX XXXX XXXX XXXX XXXXXXXX XXXX  XXXX. TransUnion is a consumer reporting agency ( CRA ) as defined by 15 U.S.C. 1681a ( f ) : it regularly engages in the practice of assembling or evaluating consumer credit information for the purpose of furnishing consumer reports to third parties for monetary fees. TransUnion does business nationwide, including substantial business in the XXXX of XXXX. At all relevant times, TransUnion acted through its agents, employees, or representatives, who were in the scope of their employment and under TransUnions supervision and control. 

Non-Party Furnishers : Various creditor institutions and debt collectors furnished the information at issue to TransUnion. These furnishers include, XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  ( collectively, the Furnishers ). While not named as defendants in this complaint, the Furnishers are mentioned to the extent that TransUnion relied on their information and responses. Under 15 U.S.C. 1681s-2 ( b ), these Furnishers have duties to investigate and correct disputed information when notified by a CRA. TransUnions conduct in this case is intertwined with the Furnishers failures to correct the false data ; TransUnions actions effectively facilitated and continued those statutory violations by the Furnishers. 

Factual Allegations XXXX XXXX XXXX Account : TransUnion was reporting an installment loan account with XXXX XXXX XXXX that had been charged off after alleged non-payment. Here again, TransUnion listed the XXXX account with a status of XXXX XXXX while simultaneously indicating a significant past-due balance remaining. The presence of a past-due balance on an account flagged as a charge-off is contrary to the Metro 2 reporting standards set by the XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Metro 2 guidelines require that once an account is charged off, the account should reflect a zero current balance and no ongoing past due amount ( since the debt is no longer an open receivable on a current schedule ). TransUnions reporting of the XXXX account violated this standard by showing the account as if payments were still actively delinquent post-charge-off. 

XXXX XXXX XXXX XXXX XXXX XXXX : TransUnion was also reporting a XXXX XXXX XXXX XXXX credit card ( XXXX XXXX ) account with inaccurate status. This account was listed as a charge-off with a past-due balance of several XXXX dollars. If this account was legitimately charged off by XXXX XXXX, it should not have a continuing past due amount in the manner a currently delinquent account would. The reporting created a misleading impression that XXXX had an open, delinquent balance with XXXX XXXX, when in reality the account was closed and charged off ( or, potentially, was also impacted by identity theft or prior disputePlaintiff had previously contested its accuracy ). 

Other Accounts and Inaccuracies : In addition to the above, other accounts on Plaintiffs TransUnion report showed similar discrepancies ( charge-off notations with continuing balances, inconsistent dates or amounts, etc. ). Each of these inaccuracies represents a failure by TransUnion to assure maximum possible accuracy in Plaintiffs credit file as required by 15 U.S.C. 1681e ( b ). For example, at least XXXX collection account continued to be reported even after the underlying debt was resolved, and several accounts did not reflect notices of dispute that Plaintiff had lodged, which TransUnion is required to note on the report per 15 U.S.C. 1681i ( c ). For brevity, this Complaint focuses on the primary accounts listed above, but Plaintiff alleges that any and all disputed accounts on his TransUnion report contain errors that TransUnion negligently and willfully failed to correct. 

Impact of Inaccurate Reporting : The inaccurate information described in Paragraph XXXX was highly damaging to Plaintiff. TransUnions report portrayed Plaintiff as significantly more delinquent and high-risk than he actually is. The reporting of multiple active past-due balances on charged-off accounts made Plaintiffs credit profile appear as if he had multiple severe, unresolved delinquencies at the same time. This has adversely affected Plaintiffs credit score and has led to credit denials or offers on far worse terms than Plaintiff would otherwise qualify for. Moreover, the continued presence of fraudulent accounts ( the XXXX XXXX cards opened by identity thieves ) on the report means Plaintiff is effectively being penalized for crimes committed by others, a harm the FCRA specifically intended to prevent through 1681c-2. Plaintiff has suffered credit damage, loss of credit opportunities, and considerable emotional distress ( including stress, anxiety, and frustration ) as a direct result of TransUnions reporting failures. 

XX/XX/XXXX Plaintiffs Dispute to TransUnion : Promptly after reviewing the XX/XX/XXXX credit report, on or about XX/XX/XXXX, XXXX submitted a detailed dispute to TransUnion, challenging the inaccurate accounts. Plaintiff utilized the CFPBs consumer complaint portal to lodge this dispute ( CFPB XXXX XXXX. XXXX, submitted XX/XX/XXXX, and forwarded to TransUnion shortly thereafter ). In his dispute, Plaintiff clearly identified each erroneous account and explained why the reporting was incorrect or inconsistent with the FCRA and Metro 2 standards. Specifically, Plaintiffs dispute highlighted that TransUnion was : Reporting charge-off accounts with an active past-due balance, which is a contradiction and an FCRA violation ( failing to maintain accuracy ) as well as a Metro 2 violation. Plaintiff cited 15 U.S.C. 1681e ( b ) ( requirement for consumer reporting agencies to use reasonable procedures to assure maximum possible accuracy of information ) and noted that this standard was breached by the blatant errors on his report. 

Failing to note previous disputes/investigations. Plaintiff referenced that he had disputed the same accounts before ( in XXXX ), and TransUnions reinvestigation obligations under 15 U.S.C. 1681i had not been met, as the results remained incorrect. He emphasized that TransUnion must conduct a reasonable reinvestigation of each disputed item, contact the Furnishers with all relevant information, and delete or correct any information that can not be verified as accurate. 

Possibly ignoring supporting documentation. Plaintiff attached and/or referenced supporting documents in the CFPB complaint ( such as correspondence, prior dispute results, the identity theft police report, billing statements showing discrepancies, etc. ), and insisted that TransUnion review this evidence rather than relying on automated means alone. 

In this XX/XX/XXXX dispute, Plaintiff expressly requested that TransUnion : ( a ) delete the fraudulent XXXX XXXX accounts ; ( b ) remove or correct the past-due balance reporting on any charged-off accounts ( including XXXX and XXXX Card ) and several other accounts so that they are accurate or deleted if unverifiable ; and ( c ) provide Plaintiff with a copy of the updated report and an explanation of the investigation results. Plaintiff also indicated that if the accounts were verified as accurate, he wanted to be provided with the method of verification and documentation that TransUnion relied upon, pursuant to 15 U.S.C. 1681i ( a ) ( 6 ) ( 7 ).

TransUnions Statutory Duty to Reinvestigate : Upon receiving Plaintiffs dispute, TransUnion was legally required to conduct a meaningful reinvestigation of the disputed items. Under 15 U.S.C. 1681i ( a ) ( 1 ) ( A ), a consumer reporting agency must reinvestigate disputed information on a consumers report within 30 days of receiving notice of the dispute ( with a possible 15-day extension if the consumer provides additional relevant information during the 30-day period ). By law, TransUnion was required to : notify the Furnishers of the dispute, provide them all relevant information about the dispute, review and consider all information provided by Plaintiff, and then delete or modify any information that is found to be inaccurate or unverifiable. If the reinvestigation resulted in no change, TransUnion was obligated to send Plaintiff a notice of the results and, upon request, a description of the procedure used to determine the accuracy and completeness of the information ( the method of verification ) per 15 U.S.C. 1681i ( a ) ( 6 ) and ( 7 ). These FCRA provisions impose a grave responsibility on TransUnion to do more than simply take a creditors word if the information could be inaccuratecaselaw.findlaw.com. 

TransUnions Failure to Timely Respond ( No Response in 30 Days ) : TransUnion did not provide any response or results of investigation within the 30-day period following Plaintiffs XX/XX/XXXX dispute. By law, the reinvestigation should have been completed by approximately XX/XX/XXXX ( 30 days after the dispute was communicated to TransUnion ), or by XX/XX/XXXX if a XXXX extension applied due to additional information provided by XXXX. Those dates passed with no communication from TransUnion. Plaintiff received no update in XX/XX/XXXX regarding the status or outcome of his dispute. This silence itself was a violation of FCRA 1681i. TransUnions failure to reinvestigate and respond within the statutory timeframe is a clear violation of 15 U.S.C. 1681i ( a ) ( 1 ), which mandates prompt handling of consumer disputes. Indeed, TransUnions conduct forced Plaintiff to take further action, as described below. 

XX/XX/XXXX Delayed TransUnion Response : On XX/XX/XXXX roughly 51 days after Plaintiffs dispute TransUnion provided a belated response through the CFPB portal, which TransUnion characterized as the results of its investigation. In this response ( which Plaintiff received on that date ), TransUnion claimed to have verified the disputed accounts as accurate and made no meaningful changes to the report. TransUnion did not delete the fraudulent XXXX XXXX accounts ; it did not remove the past-due balance fields on the charge-off accounts ; and it did not otherwise correct the misinformation. Essentially, XXXX XX/XX/XXXX response indicated that the data was verified as accurate by the source. The response was cursory and failed to specifically address the evidence Plaintiff had provided. Furthermore, TransUnion did not provide any of the underlying documents or details of the verification process. It did not, for example, supply Plaintiff with copies of any verification forms or correspondence from XXXX XXXX, XXXX, or XXXX XXXX. Nor did it explain how a charge-off with a past-due balance could be deemed accurate under industry standards. 

No Method of Verification Provided : Plaintiff, upon receiving TransUnions XX/XX/XXXX response, noticed that TransUnion did not include a method of verification letter or description. On XX/XX/XXXX ( the same day the response was received ), Plaintiff requested via follow-up communication that TransUnion provide a detailed description of the procedures used to verify the disputed information, as is his right under 15 U.S.C. 1681i ( a ) ( 7 ). TransUnion failed to comply with this request. TransUnion did not send any further explanation of how it conducted its reinvestigation. It provided no information about who at the Furnishers was contacted, what information was given to the Furnishers, or what the Furnishers replied with. This lack of transparency violated TransUnions obligation to provide the method of verification upon request, an important consumer right designed to allow individuals to assess whether the credit bureaus investigation was reasonable. By withholding this information, TransUnion hindered Plaintiffs ability to further challenge or correct the errors, effectively stonewalling his dispute. 

TransUnions XXXX on Automated Procedures : From the substance of TransUnions XX/XX/XXXX investigation results, it is evident that TransUnion relied solely on automated processes ( e.g., e-OSCAR ) and the Furnishers electronic responses in handling Plaintiffs dispute. TransUnions response to the CFPB complaint was generic and gave no indication of any human review of Plaintiffs documentation. Upon information and belief, TransUnion simply sent an Automated Consumer Dispute Verification ( ACDV ) form through the e-OSCAR system to XXXX XXXX, XXXX, and XXXX XXXX, and other accounts and then blindly accepted their responses that the accounts were verified as reported. TransUnion did not exercise any independent judgment or scrutiny, even though the face of the data contained glaring inconsistencies ( such as a charge-off with an ongoing balance ). In essence, TransUnions investigation was no investigation at all it was an automated forwarding of information and regurgitation of whatever the Furnishers responded with.

Failure to Conduct a Reasonable Reinvestigation : TransUnions handling of the dispute fell far short of a reasonable reinvestigation as required by FCRA 1681i ( a ). A reasonable investigation would have entailed, at minimum : recognizing the obvious red flags in the data, seeking clarifications from Furnishers about the charge-off status vs. balance discrepancy, and independently verifying the identity theft claims ( for example, by reviewing the police report, comparing signatures, or examining account application records for the XXXX XXXX XXXX XXXX. TransUnion did none of this. It merely confirmed the information with the source and took no further steps, which courts have held to be inadequate. In XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX held that simply sending a form to the creditor and doing nothing more is insufficient a credit bureau must bear some responsibility for evaluating the accuracy of information obtained from subscribers in a reinvestigationcaselaw.findlaw.com. Similarly, the XXXX XXXX XXXX XXXX XXXX Trans Union Corp. held that a reinvestigation that merely parrots the creditors position can not fulfill the obligations contemplated by the statute.caselaw.findlaw.com TransUnions conduct here mirrors the discredited practices in those cases. It shifted the burden back to Plaintiff and the Furnishers, rather than actually resolving the dispute, thus violating the core purpose of 1681i. 

CFPB Recognition of XXXX XXXX Practices : XXXX pattern of handling disputes in this automated, perfunctory manner is not only a violation of the FCRA as interpreted by the courts, but it has also drawn regulatory scrutiny. On XX/XX/XXXX, the CFPB filed a public enforcement action against XXXX, alleging that XXXX  does not take sufficient steps to ... investigate ... consumer disputes, resulting in the inclusion of incorrect information on credit reports.consumerfinance.gov The CFPBs Director XXXX XXXX stated that TransUnion was conducting sham investigations rather than properly reviewing the disputes as required by federal law.consumerfinance.gov The experiences of the Plaintiff in this case exemplify the very misconduct that the CFPB identified. XXXX failure to genuinely investigate Plaintiffs dispute especially in the context of identity theft and blatant reporting errors aligns with the CFPBs allegations that XXXX systems prioritize speed and automation over accuracy and fairness. This regulatory action underscores that TransUnions violations in Plaintiffs case are not isolated incidents but part of a broader pattern of willful non-compliance. 

Continued Reporting of Disputed Accounts : As of the filing of this Complaint, TransUnion continues to report the disputed accounts on Plaintiffs credit file without the corrections requested. The XXXX XXXX accounts remain, still marked as charge-offs with balances ; the XXXX and XXXX XXXX XXXX and other accounts, still show past-due amounts despite charge-off status. Each monthly cycle that passes, these accounts potentially update in TransUnions system as continuing derogatory marks, further prolonging the damage to Plaintiffs creditworthiness. Plaintiff has expended considerable time and effort trying to resolve these issues ( including writing complaints, gathering evidence, and researching his rights ), all due to TransUnions failure to meet its statutory obligations. 
TransUnions Violations Were Willful or, Alternatively, Negligent : TransUnions conduct described above was willful. TransUnion is fully aware of its duties under the FCRA it has been subject to prior lawsuits and regulatory actions for similar conduct, and it literally co-owns the e-OSCAR system used for disputes. TransUnion knew or had reason to know that the information it was reporting about Plaintiff was inaccurate ( the inconsistencies were facially obvious ), yet it willfully chose to ignore the red flags. TransUnion also willfully decided to use an automated dispute verification system without employing any manual review for Plaintiffs dispute, despite the complexity ( involving identity theft and multiple accounts ). In the alternative, if TransUnion claims it did not act intentionally, then at minimum its actions were negligent. Any reasonable company in TransUnions position, acting with due care, would have conducted a proper investigation and corrected the errors. TransUnions failure to do so, whether by conscious design or gross indifference, directly caused harm to Plaintiff.

Summary of Harm to Plaintiff : As a direct result of TransUnions actions and omissions, Plaintiff has suffered injury including damage to his credit reputation, denial of credit opportunities, higher interest rates on credit offers, and emotional distress ( XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  ) from the ongoing inability to correct his credit report. Plaintiff has been forced to engage in a protracted struggle to have basic errors corrected, undermining his confidence in the fairness of the credit reporting system. These harms are precisely what the FCRA was designed to prevent. TransUnions repeated failure to comply with the FCRAs mandates is particularly egregious given the multiple opportunities it had to correct course ( in XXXX and again in XXXX ). Plaintiff now brings this Complaint seeking relief to finally rectify the situation and hold TransUnion accountable under the law. 

Case Law and Regulatory Support XXXX XXXX TransUnion XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) : In XXXX, the XXXX XXXX emphasized that a credit bureaus reinvestigation of disputed information must be more than a token effort. The court held that the FCRA imposes grave responsibilities on agencies like TransUnion to ensure accuracy, and that a so-called reinvestigation that merely rubber-stamps the furnishers response is inadequatecaselaw.findlaw.com. In that case, Trans Union had verified an obviously fraudulent account by simply asking the creditor, which the court found could violate 1681i. The XXXX XXXX flatly stated that the burden of investigation is on the consumer reporting agency, not the consumer : the statute places the burden of reinvestigation squarely on the [ CRA ] a reinvestigation that merely shifts the burden back to the consumer and the credit grantor can not fulfill the obligations contemplated by the statute.caselaw.findlaw.comcaselaw.findlaw.com TransUnions handling of Plaintiffs disputes in the present case mirrors the disapproved conduct in XXXX. Like TransUnion in this case, TransUnion simply parroted information from its subscribers ( creditors ) without carrying out its own duty to verify accuracy. Under XXXX, such conduct violates 1681is requirement of a reasonable reinvestigation. 

XXXX v. XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) : In XXXX, the XXXX XXXX confronted a scenario involving fraudulent accounts ( opened by the plaintiffs son ) where the CRA relied solely on form requests to creditors during reinvestigation. The court held this was insufficient. It famously wrote : In a reinvestigation of the accuracy of credit reports, a credit bureau must bear some responsibility for evaluating the accuracy of information obtained from subscribers.caselaw.findlaw.com The XXXX XXXX reasoned that if a consumer has alerted the agency that the source of information ( the creditor ) maXXXX be unreliable ( for example, due to fraud or error ), the agency is obliged to go beyond the initial source and conduct a more searching inquirylaw.justia.com. It rejected the argument that a consumer should have to resolve the fraud directly with the creditor, affirming that the onus is on the CRA to resolve it caselaw.findlaw.com. In the case at bar, Plaintiff explicitly alerted TransUnion that the accounts were products of fraud or error ( and even provided an identity theft report and other evidence ). Under XXXX, TransUnion was duty-bound to do more than just ask the creditor via e-OSCAR. TransUnions failure to take any additional steps ( such as actually examining the police report or contacting Plaintiff for more info ) runs afoul of the standard set in XXXX. The lessons of XXXX reinforce that TransUnions simplistic approach to Plaintiffs dispute was legally deficient. 

XXXX v. XXXX  XXXX. XXXX, XXXX XXXX XXXX. XXXX XXXX ( XXXX XXXX. XXXX ) : In XXXX, the plaintiffs disputed an erroneous credit item multiple times, and XXXX  repeatedly verified it by relying on the creditors word, despite evidence the information was wrong. The court denied summary judgment for XXXX, holding that 1681i ( a ) can require a CRA to go beyond the original source of information when the circumstances indicate the source may be XXXX. The decision noted that the majority of courts have found that a CRA must verify the accuracy of its initial source in certain situations, rather than blindly trusting the XXXX. In XXXX, the plaintiffs had even provided court documents to prove the account was resolved, yet XXXX  still took the creditors outdated report at face valuelaw.justia.com. The court cited XXXX and XXXX approvingly in concluding that whether a CRAs investigation was reasonable is usually a question for the XXXX, especially when the consumer has provided information calling the creditors data into XXXX. XXXX applies squarely here : XXXX gave TransUnion ample reason to doubt the furnishers ( pointing out obvious errors and fraud ), but TransUnion persisted in relying exclusively on those furnishers. Just as in XXXX, a fact-finder could ( and likely would ) determine that TransUnion willfully failed to conduct a proper reinvestigation. The case law thus supports Plaintiffs position that TransUnions conduct was unlawful under the FCRA. 

Recent CFPB Enforcement CFPB XXXX XXXX  ( XXXX. XXXX. XXXX ) : The Consumer Financial Protection Bureaus lawsuit against Experian, filed in XX/XX/XXXX, serves as powerful confirmation by the nations chief consumer credit regulator that XXXX  dispute-handling practices violate the FCRA.

Metro 2 Compliance Standards : While not codified in the FCRA, the Metro 2 format guidelines ( issued by the XXXX XXXX XXXX XXXX ) are the industry standard for reporting credit information. Adherence to Metro 2 is indicative of reasonable procedures for accuracy under 1681e ( b ). One key Metro 2 guideline is that an account that is charged off ( Category Profit and Loss Write-Off ) should have a current balance of {$0.00} and no past-due amount, since the debt is no longer an open obligation in the creditors portfolio. .Metro 2 Compliance Standards. Adherence to Metro 2 is indicative of reasonable procedures for accuracy under 1681e ( b ). One key Metro 2 guideline is that an account that is charged off ( Category Profit and Loss Write-Off ) should have a current balance of {$0.00} and no past-due amount, since the debt is no longer an open obligation in the creditors portfolio. By maintaining past-due balances on charged-off accounts, TransUnion deviated from Metro 2 standards, further highlighting the unreasonableness of its procedures. Additionally, Metro 2 provides specialized codes for indicating disputed information and identity theft accounts ; TransUnion either did not use these codes or ignored them in Plaintiffs case. The result was tradelines that were blatantly non-compliant with industry norms, reinforcing that TransUnions conduct was not just a technical error but a failure of the very controls meant to ensure data integrity.

Willfulness and Pattern of Non-Compliance : The above legal authorities show that TransUnion has been on notice for decades that it must do more than superficial checks when consumers dispute information, especially in cases of fraud or obvious error. XXXX ( XXXX ) and XXXX ( XXXX ) have long been part of FCRA jurisprudence, and the FCRA statute itself is clear in its language. The fact that in XXXX TransUnion is still engaging in conduct that those cases found unlawful strongly suggests willfulness. TransUnions pattern of ignoring both court guidance and regulatory warnings ( like those from the CFPB and prior state Attorneys General settlements ) constitutes reckless disregard of consumers rights, which meets the standard for willfulness under 15 U.S.C. 1681n ( a ). Consequently, not only is TransUnion liable to Plaintiff for actual damages ( and/or statutory damages ), but an award of punitive damages is warranted to deter TransUnion from continuing its unlawful practices and to punish it for this pattern of misconduct.

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