Consumer complaint received 2025-06-02 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Account information incorrect
Company: EQUIFAX, INC.
State: LA

Complaint narrative:
CFPB COMPLAINT FINAL SUBMISSION Subject : FCRA 605C | FDCPA XXXX | XXXX XXXX | 12 C.F.R. 1022.142 | Enforcement of Deletion Order No. XXXX Submission Date : XX/XX/XXXX Complainant : Status : Private Federal Claimant ( Verified XXXX  Survivor ) Jurisdiction : U.S. District Court Northern District of California Submission Method : eCFPB Portal Respondents : - Equifax Information Services LLC - Experian Information Solutions , Inc . 
- XXXX  XXXX XXXX XXXX XXXX XXXX XXXX XXXX. 
- XXXX  ( XXXX XXXX and XXXX ) This complaint is submitted to establish national enforcement precedent and to set regulatory, statistical, and legal standards for survivor-based FCRA 605C compliance and judicial remedy. The FrancisPolaris Standard should serve as the regulatory benchmark for deletion compliance : any consumer reporting agency or furnisher failing to honor a properly submitted 605C deletion orderaccompanied by a recognized certification ( such as a Polaris Letter ) and law enforcement reportshall be deemed in per se violation of FCRA 605C, FCRA 611, and 12 C.F.R. 1022.142, and subject to full statutory and punitive damages. Reinsertion shall trigger enforcement review and create a presumption of willful misconduct. 

I. EXECUTIVE SUMMARY On XX/XX/XXXX, the Consumer Financial Protection Bureau issued Deletion Order No. XXXX, mandating the permanent suppression of sixteen adverse tradelines under FCRA 605C XXXX This order is supported by Police Report XXXX. XXXX ( certifying identity theft and XXXX-related harm ) and a XXXX XXXX XXXX ( recognized survivor verification entity per CFPB guidance ). 

Between XX/XX/XXXX and XX/XX/XXXX, Equifax, Experian, and XXXX  reinserted all XXXX tradelines in violation of FCRA 605C ( 15 U.S.C. 1681c-2 ( a ) ), FCRA 611 ( a ) ( 5 ) ( B ) ( ii ) ( no 5-day reinsertion notice provided ), and 12 C.F.R. 1022.142 ( f ) ( binding legal effect of Deletion Orders ). 

XXXX, acting as a forensic control group, properly suppressed XXXX of the XXXX tradelines. XXXX then re-fragmented a deleted {$10000.00} tradeline into XXXX new tradelines ( {$3700.00} and {$6300.00} ), constituting false debt re-reporting. 

Documented injuries include {$590000.00} in credit denials from XXXX, XXXX, and a mortgage lender, and emotional distress confirmed via certified XXXX therapy logs. 

XXXX. TIMELINE OF EVENTS - XX/XX/XXXX : CFPB issues Deletion Order No. XXXX - XX/XX/XXXX XX/XX/XXXX : Equifax, Experian, and XXXX  XXXX XXXX deleted tradelines - XX/XX/XXXX : XXXX confirms suppression of XXXX tradelines - XX/XX/XXXX : Complainant receives {$590000.00} in credit denials- XX/XX/XXXX : XXXX  re-fragments XXXX deleted tradeline into XXXX new accounts XXXX. LEGAL VIOLATIONS A. FCRA 605C and 611 Violations - Unlawful reinsertion of deleted tradelines under 605C - Failure to notify prior to reinsertion under 611 ( a ) ( 5 ) ( B ) ( ii ) - Violation of CFPB Order enforcement provision under 12 C.F.R. 1022.142 ( f ) BXXXX XXXX Compliance Differential - XXXX suppressed 81.25 percent ( XXXX of XXXX ) of tradelines ; Big 3 suppressed zero percent - XXXX  timestamped audit is admissible under FRE 902 ( 13 ) - Daubert standard satisfied under FRE 702 C. RICO Violations ( Aidvantage ) - Post-deletion account fragmentation constitutes a pattern of racketeering under RICO 1962 ( c ) - Aidvantage violated FDCPA 807 by misleadingly re-reporting the same debt as two accounts D. Concrete Harm ( Spokeo Standard ) - Actual and reputational harm established through credit denials and therapy records- Standing satisfies Spokeo v. Robins, 578 U.S. 330 IV. ESTOPPEL BY REINSTATEMENT DOCTRINE The Complainant hereby invokes the legal doctrine of : Estoppel by Reinstatement whereby any reappearance of data previously ordered deleted under federal law and CFPB authority is void ab initio, and the respondent is barred from asserting its validity in any form.

This doctrine binds all furnishers and CRAs thatonce provided with l
awful deletion documentation under FCRA 605C and 12 C.F.R. 1022.142 ( f ) re-report suppressed accounts either in original, modified, or fragmented form. Such re-reporting without advance written notice under FCRA 611 ( a ) ( 5 ) ( B ) ( ii ) constitutes per se estoppel, legal nullification, and full civil liability under : 15 U.S.C. 1681n ( willful noncompliance ), and 15 U.S.C. 1681o ( negligent noncompliance ). 

This doctrine is applied retroactively, and once triggered, bars the re-reported data from having any legal effect or validity. Respondents become automatically liable for all resulting damages.

This doctrine forms the legal cornerstone of the FrancisPolaris Standard, and is intended to set a national precedent for deletion enforcement, survivor protections, and CFPB oversight.

V. V. EVIDENCE SUMMARY ( as already written ) This section placement gives the doctrine proper weight as its own binding legal principle, distinguishes it from fact/evidence-based violations, and emphasizes its foundational and future-precedent role in your strategy.

VI. EVIDENCE SUMMARY - Exhibit A : CFPB Deletion Order No. XXXX - Exhibit B : Police Report No. XXXX ( certified trafficking victim report ) - Exhibit C : Polaris Certification Letter- ( CFPB Deletion Order No. XXXX ) - Exhibit D : XXXX Suppression Audit XXXX of XXXX accounts suppressed - Exhibit E : Reinsertion Screenshots Equifax, Experian, XXXX  - Exhibit F : Aidvantage account splitting logs - Exhibit G : Denial letters from lenders totaling {$590000.00} in damages - Exhibit H : Certified mail receipts to CRAs and Aidvantage - Exhibit I : Therapy records confirming XXXX trauma and psychological injury -Exhibit J : FTC complaints -Exhibit K : Equifax breach CFPB Complaints ( XXXX XXXX ) : XXXX. Equifax XX/XX/XXXX XXXX. Experian XX/XX/XXXX XXXX. XXXX XX/XX/XXXX XXXX. Equifax XXXX XXXX Complaint ( Reinsertion Violation ) XX/XX/XXXX XXXX. CFPB Deletion XXXX XXXX. XXXX Attachments submitted in support ( PDF, timestamped ) : - CFPB_Deletion_Order.pdf - XXXX - XXXX - XXXXSuppression_Data.pdf - Reinsertion_Screenshots.pdf - Aidvantage_Split_Logs.pdf - Denial_Letters.pdf - Certified_Mail_Receipts.pdf - Therapy_Logs.pdf VII. FEDERAL DEMAND FOR COMPLETE CREDIT FILE CLEARING Pursuant to FCRA 605C, 12 C.F.R. 1022.142 ( f ), and the enforceable CFPB Deletion Order No. XXXX, I now move for the immediate and permanent deletion of all remaining tradelines, personal identifiers, and account data across all CRA files XXXX as documented in the enclosed XX/XX/XXXX credit reports from Experian, Equifax, and XXXX. 

This enforcement demand encompasses : All open, closed, charged-off, derogatory, or duplicate accounts ; All addresses, names, inquiries, and public record entries tied to previously deleted or suppressed tradelines ; All reinserted data not accompanied by written notice as required under FCRA 611 ( a ) ( 5 ) ( B ) ( ii ).

These entries are : Legally void pursuant to the Estoppel by Reinstatement doctrine ; In violation of survivor protections under federal law ; Functionally indistinguishable from previously suppressed or fragmented tradelines ; Admissible as willful violations under 15 U.S.C. 1681n and 1681o.

This demand for full file suppression and universal deletion is federally mandated, statutorily protected, and non-negotiable. It is binding on all CRAs and furnishers by force of federal statute, regulatory interpretation, and judicial precedent. 
This complaint incorporates by reference the following * * prior regulatory complaints * *, filed in good faith and supported by certified law enforcement and Polaris documentation : This complaint incorporates by reference the following prior regulatory complaints, all submitted in good faith and supported by law enforcement and Polaris documentation : This complaint is intended to set regulatory precedent, ensure federal protection and immunity for survivors, and provide a model for survivor-based deletion enforcement.

I affirm under penalty of perjury pursuant to 28 U.S.C. 1746 that the fact
s, claims, and evidence submitted herein are true and correct, and that this complaint is made in good faith to enforce federal consumer protection law.

This submission is designed for maximum compliance with CFPB enforcement standards and evidentiary admissibility. Immediate regulatory action is requested.

Company response to consumer: Closed with explanation