Consumer complaint received 2025-10-06 00:00:00
Product: Debt collection — Credit card debt
Issue: Written notification about debt — Didn't receive enough information to verify debt
Company: Lloyd & McDaniel, PLC
State: FL

Complaint narrative:
Lloyd & McDaniel , PLC XXXX XXXX XXXX XXXX  KY XXXX RE : THIRD AND FINAL REQUEST FOR DEBT VALIDATION NOTICE OF CONTINUED NON-COMPLIANCE Your File No. XXXX XXXX XXXX XXXX  Alleged Account Number : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Alleged Creditor : XXXX XXXX XXXX. 

To : Lloyd & McDaniel , PLC ( Debt Collector ) To the Representatives of Lloyd & McDaniel , PLC : This is my third and final written communication regarding the above-referenced alleged debt. I am writing in response to your inadequate correspondence dated XX/XX/XXXX, ( Letter arrived on XX/XX/XXXX ) which you sent after my initial and second written disputes and requests for validation made pursuant to my rights under 15 U.S.C. 1692g of the Fair Debt Collection Practices Act ( FDCPA ).

Your response has failed, once again, to meet the legal standard for debt validation. Your continued collection efforts without providing proper verification are a violation of federal law. 

1. Material Misrepresentation of the Debt 's Origin.

Your letter contains a significant factual inaccuracy, stating : Your account was originally opened with XXXX XXXX, XXXX, successor by merger to XXXXXXXX XXXX 

This is false. The documents you provided prove this statement is incorrect. The Office of the Comptroller of the Currency ( OCC ) certification you included confirms the merger was effective XX/XX/XXXX. My account statements show the account was opened in XXXX with XXXXXXXX XXXX This material misrepresentation violates 15 U.S.C. 1692e of the FDCPA and undermines the credibility of your entire claim.

2. Failure to Provide Contractual Documentation.

My previous letters specifically demanded the Original Purchase Agreement and proof of a signed contract. You have provided neither. I have never received a copy of the original application or the cardholder agreement that I purportedly agreed to with XXXXXXXX XXXX You can not validate a contractual debt without providing the contract.

3. Failure to Prove Chain of Title and Standing.

You have not provided any documentation proving you have the legal right to collect this specific debt.

You must provide : The bill of sale or assignment agreement from XXXX XXXX XXXX XXXX XXXX XXXXXXXX, that explicitly lists my name, address, and the specific account number ending in XXXX. 
The agreement demonstrating that Lloyd & McDaniel , PLC, is legally authorized to collect this specific account.

A generic " Notice of Merger '' is not sufficient to prove the chain of title for my specific account.

4. Insufficient Itemization. 
The billing statements you provided show an account that was already severely delinquent. You have not provided a complete accounting from a XXXX balance, showing how the principal was established through my transactions. 

FINAL DEMAND FOR VALIDATION & CEASE COMMUNICATION This is my final request for you to comply with federal law. You are required to cease all collection activity until you provide verification of the debt. Your incomplete and inaccurate response does not constitute verification. 

Within 30 days of your receipt of this letter, you must provide the following : 1. The original signed application and the complete Cardmember Agreement from XXXXXXXX XXXX  that governed this account. 
2. A complete chain of title, including the bill of sale/assignment from XXXXXXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX, referencing my specific account, and your agreement with XXXX XXXX to collect this specific debt. 
XXXX. A full, itemized accounting of the alleged debt from a {$0.00} balance.

Furthermore, I hereby exercise my right under 15 U.S.C. 1692c ( c ) to demand that you cease all telephone calls. All future communication with me regarding this alleged debt must be in writing and sent to my address above. 

If you fail to provide the legally required validation within 30 days, you must immediately and permanently : Close this account. 
Cease all collection activities.

Permanently delete any information you have reported to any credit reporting agency regarding this alleged debt.

Your failure to properly validate this debt after three written requests, coupled with your material misrepresentation, constitutes a willful pattern of non-compliance with the FDCPA. I will not hesitate to file complaints with the Federal Trade Commission ( FTC ), the Kentucky Attorney General, and the Florida Attorney General. I will also pursue all available legal remedies, including filing a lawsuit in a court of competent jurisdiction for statutory damages for each violation.

This matter will not be closed until you provide the legally mandated validation or terminate all collection efforts.

Company response to consumer: Closed with explanation