Consumer complaint received 2024-12-22 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: GA

Complaint narrative:
Dear Credit Reporting Agency, I am writing to formally dispute the continued reporting of the XXXX XXXX XXXX XXXX account ( Account # XXXX ) on my credit report. The information being reported is inaccurate, unverifiable, and constitutes multiple violations of my rights under federal and state laws. 

a. False or Misleading Representations ( 15 U.S.C. 1692e ) If XXXX continues to report the debt as collectible despite it being charged off or forgiven, this constitutes false representation. 
Failure to clarify the status of the debt, especially if it was canceled or forgiven, is misleading. 
b. Failure to Cease Collection on Disputed Debt ( 15 U.S.C. 1692g ( b ) ) If a debt is disputed, the collector ( or creditor, in this case ) must cease all collection activityincluding reporting to CRAsuntil the debt is validated. If the dispute has been ignored or dismissed without validation, this is a violation. 
XXXX. Misrepresentation of Debt Status a. Inaccurate Reporting of Balance Reporting a balance greater than {$0.00} on a charged-off account misrepresents the account status. A charge-off means the creditor has deemed the debt uncollectible and written it off, so the balance should reflect {$0.00} unless sold to a collection agency. 
b. Violation of Truth in Lending Act ( TILA ) Under 15 U.S.C. 1637 ( b ), creditors must provide accurate billing and disclosure. If the reported balance is inconsistent with the charge-off classification, this violates TILA. 

Additionally, the reporting of a non-zero balance on a charged-off account is inaccurate and misleading. If this account has been charged off, the balance should reflect {$0.00}, as required under proper credit reporting standards. 

Violations of My Rights XXXX. Failure to Conduct a Reasonable Reinvestigation ( 15 U.S.C. 1681i ( a ) ) I submitted dispute letters dated XX/XX/year>, and XX/XX/year>, requesting documentation to validate this account, including : Authenticated double-entry accounting records. 
Original signed agreements or contracts.

A copy of the 1099-C form ( if applicable ).

You failed to conduct a reasonable investigation and instead relied solely on unverifiable information provided by the creditor.

Under 15 U.S.C. 1681i ( a ) ( 5 ), if disputed information can not be verified, it must be deleted from the credit report. 
XXXX. Failure to Provide Documentation ( 15 U.S.C. 1681g ) Under 15 U.S.C. 1681g ( a ) ( 1 ), you are required to provide all information in the consumers file upon request. Despite my repeated demands, you have failed to provide : Proof of validation.

Documentation supporting the charge-off classification.

A copy of the 1099-C form required under 26 U.S.C. 6050P if the debt has been canceled or forgiven. 
Your failure to produce these documents violates this provision. 

XXXX. Reporting Inaccurate and Inconsistent Information ( 15 U.S.C. 1681e ( b ) ) Credit reporting agencies must ensure the maximum possible accuracy of the information they report.

Innovis has already removed this account as unverifiable, yet you continue to report it inaccurately. This inconsistency among credit reporting agencies directly violates 15 U.S.C. 1681e ( b ).

Further, if this account has been charged off, the balance must be reported as {$0.00}, as the creditor no longer considers it collectible. Reporting a non-zero balance on a charged-off account is both inaccurate and misleading. 
XXXX. Continuing to Report Unverifiable Information ( 15 U.S.C. 1681i ( a ) ( 5 ) ) You are required to delete any information that can not be verified within 30 days. It has been over 50 days since my initial dispute, and you have failed to provide proper validation.

This is a direct violation of 15 U.S.C. 1681i ( a ) ( 5 ), as you continue to report unverifiable information despite my multiple requests. 
XXXX. Violation of Consumer Disclosure Rights ( 15 U.S.C. 1681c ( f ) ) Under 15 U.S.C. 1681c ( f ), you are required to include a notation that an account is disputed. If this dispute notation is missing from my credit report, you are in violation of this provision. 
XXXX. Failure to Issue a 1099-C Form ( 26 U.S.C. 6050P ) If this account was charged off and is considered forgiven or canceled, the creditor was required to issue a 1099-C form for debts exceeding {$600.00}. The absence of this form raises questions about the validity of the charge-off and its reporting. 
XXXX. Violation of Permissible Purpose ( 15 U.S.C. 1681b ) If XXXX XXXX XXXX or the credit reporting agency can not produce signed contracts proving my authorization, the continued reporting of this account may constitute a violation of 15 U.S.C. 1681b, which governs permissible purposes for reporting information. 
XXXX. Illegal Re-Aging of Debt ( 15 U.S.C. 1681c ) If the Date of First Delinquency ( DOFD ) on this account has been altered to make the debt appear newer than it is, this constitutes illegal re-aging. 
Under 15 U.S.C. 1681c ( a ) ( 4 ), negative accounts must be removed from credit reports after seven years from the XXXX. 
XXXX. Inadequate Explanation of Reinvestigation Results ( 15 U.S.C. 1681i ( a ) ( 6 ) ) Under 15 U.S.C. 1681i ( a ) ( 6 ) ( B ) ( iii ), credit reporting agencies are required to provide a description of the reinvestigation process and the procedure used to verify disputed information. Simply stating that the account was verified by the creditor without providing supporting documentation does not satisfy this requirement. 
Immediate Actions Required 1. Failure to Remove Data Breach-Related Accounts ( 15 U.S.C. 1681c-2 ) Under 15 U.S.C. 1681c-2 ( a ), I am entitled to request the removal of any account resulting from a data breach. I informed you that my information was compromised in a data breach, and this account is directly tied to the fraudulent use of my information. You have failed to comply with your obligation to remove this unverifiable and fraudulent account. 

XXXX. Failure to Conduct a Reasonable Reinvestigation ( 15 U.S.C. 1681i ( a ) ) Under 15 U.S.C. 1681i ( a ), you are required to conduct a reasonable reinvestigation of disputed information and provide documentation verifying the accuracy of the account. 

I requested authenticated double-entry accounting records, original signed contracts, and a 1099-C form if the debt was charged off, forgiven, or canceled.

Your failure to produce this documentation demonstrates that the account can not be verified, making its continued reporting a violation of 15 U.S.C. 1681i ( a ) ( 5 ). 
3. Reporting Inaccurate Information ( 15 U.S.C. 1681e ( b ) ) Credit reporting agencies are required to ensure the maximum possible accuracy of information in consumer reports. 

XXXX has already removed this account from my credit file as unverifiable, yet you continue to report it inconsistently. 
Additionally, if this account has been charged off, the balance must reflect {$0.00}. Reporting a non-zero balance is inaccurate and misleading, violating 15 U.S.C. 1681e ( b ).

4. Failure to Block Fraudulent Information ( 15 U.S.C. 1681c-2 ( b ) ) Under FACTA and 15 U.S.C. 1681c-2 ( b ), you are required to block disputed information related to a data breach or identity theft within four business days after receiving evidence of the breach. Your failure to block or remove this account constitutes a violation of my rights under this provision.

5. Failure to Provide Consumer Disclosures ( 15 U.S.C. 1681g ) I requested copies of all information related to the disputed account, including contracts, applications, and validation records, under 15 U.S.C. 1681g ( a ). You have failed to provide these documents, violating my right to access information in my file.

6. Failure to Issue a 1099-C Form ( 26 U.S.C. 6050P ) If the account has been charged off or canceled, XXXX XXXX XXXX was required to issue a 1099-C form to both me and the IRS for debts exceeding {$600.00}. The absence of this form raises questions about the validity and accuracy of the charge-off and makes the reporting of this account fraudulent. 

XXXX. Violation of FTC Data Security Standards As part of my FTC complaint, I reported that my information was exposed in a data breach. Your continued failure to investigate or remove accounts linked to this breach constitutes unfair and deceptive practices under FTC standards, as well as a breach of your obligation to safeguard consumer data. 

Remove the Account : Since you have failed to provide proper validation, this account must be deleted from my credit report immediately in accordance with 15 U.S.C. 1681i ( a ) ( 5 ).

Update the Balance to {$0.00} : If you continue to report this account, it must reflect a {$0.00} balance, as required for charged-off accounts.

Provide Validation Documentation : If you intend to continue reporting this account, provide the following within 10 days : Authenticated double-entry accounting records.

Original signed agreements or contracts.

A copy of the 1099-C form, if applicable.

Notice of Escalation If you fail to take the necessary corrective actions or provide proper documentation, I will escalate this matter by : Filing formal complaints with the Consumer Financial Protection Bureau ( CFPB ) and Federal Trade Commission ( FTC ) for violations of the FCRA.

Reporting the issue to the Internal Revenue Service ( IRS ) for failure to issue a 1099-C form.

Consulting with legal counsel to pursue claims for statutory and actual damages under 15 U.S.C. 1681n ( willful noncompliance ) and 15 U.S.C. 1681o ( negligent noncompliance ).

I trust you will address this matter promptly and ensure compliance with your obligations under federal law. Please confirm the removal or correction of this account within 10 days. 

Thank you for your immediate attention to this matter.

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