Consumer complaint received 2025-12-25 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Account status incorrect
Company: VW Credit
State: NC

Complaint narrative:
This response is submitted to formally dispute the adequacy and legal sufficiency of Volkswagen Financial Services response and to clarify the unresolved violations of the Fair Credit Reporting Act.

1. Failure to Comply W

ith 15 U.S.C. 1681i ( a ) ( 5 ) ( B ) Unlawful Reinsertion The core issue remains unlawful reinsertion of previously deleted information, not the historical existence of a lease agreement. Under 15 U.S.C. 1681i ( a ) ( 5 ) ( B ), a consumer reporting agency may not reinsert previously deleted information unless all statutory conditions are satisfied, including : The furnisher must certify the accuracy and completeness of the information to the consumer reporting agency prior to reinsertion ; and The consumer reporting agency must notify the consumer within five ( 5 ) business days of reinsertion, including the name, address, and telephone n
umber of the furnisher and a statement of consumer rights.

Volkswagen Financial Services response does not provide evidence that either requirement was met.

Specifically, Volkswagen Financial Services failed to produce : Any certification record demonstrating compliance with 1681i ( a ) ( 5 ) ( B ) ; The date of certification ; The method of certification ; Confirmation that certification occurred prior to reinsertion ; Any documentation showing that TransUnion provided the required five-day consumer notice.

A reference to a block rescission request is not equivalent to statutory certification under 1681i ( a ) ( 5 ) ( B ) and does not cure reinsertion violations.

Absent proof of certification and notice, reinsertion is unlawful as a matter of law.

2. Submission of a Lease Agreement Does Not Satisfy Reinsertion Requirements Volkswagen Financial Services submission of a historical lease agreement is legally insufficient.

The existence of a contract does not : Authorize reinsertion after deletion ; Replace statutory certification requirements ; Establish compliance with reinsertion notice obligations ; Validate post-deletion reporting authority.

Reinsertion compliance is a procedural statutory requirement, independent of whether an account once existed. Furnishers may possess contractual documents and still violate the FCRA if procedural requirements are not met.

Volkswagen Financial Services conflated historical account existence with reinsertion legality, which the FCRA does not permit.

3. Failure to Ensure Maximum Possible Accuracy 15 U.S.C. 1681e ( b ) As currently reported, the account reflects : Status : Payment after repossession Balance : {$0.00} Comment : Settled ; less than full balance This combination creates materially misleading reporting, even if individual data points may be factually true.

Under 15 U.S.C. 1681e ( b ), furnishers and consumer reporting agencies must ensure maximum possible accuracy, which includes preventing information that is misleading or materially incomplete.

Reporting a repossession with settlement language and a zero balanceparticularly following prior deletionfails the maximum possible accuracy standard and is inconsistent with Metro 2 reporting logic.

4. Metro 2 Compliance Deficiencies Volkswagen Financial Services response does not demonstrate compliance with Metro 2 standards governing : Reinsertion certification auditability ; Repossession and settlement status consistency ; Accurate post-termination account coding ; Reporting authority following deletion.

Metro 2 requires that data furnished be complete, consistent, and capable of audit verification. No Metro 2 certification records or field-level validation were provided to support reinsertion.

Absent such documentation, continued reporting is non-compliant.

5. Burden of Proof Remains Unmet Volkswagen Financial Services has not met its burden to demonstrate lawful reinsertion. Without production of : Certification of accuracy and completeness ; Proof of timely consumer notice ; Metro 2-compliant reporting justification ; continued reporting constitutes unlawful reinsertion and materially misleading reporting under the FCRA.

Company response to consumer: Closed with non-monetary relief