Consumer complaint received 2025-12-01 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Problem when making payments — Problem during payment process
Company: CLGF Holdco 1, LLC
State: GA

Complaint narrative:
SUPPLEMENTAL CFPB COMPLAINT NEW EVIDENCE FALSE STATEMENTS IN FURNISHER RESPONSE Concora Credit Inc./ XXXX XXXX XXXX XXXX Milestone Mastercard Prior CFPB Case Nos. XXXX and XXXX Summary This complaint presents new evidence that Concora Credit Inc. ( XXXXervicer for XXXX XXXX XXXX XXXX  ) submitted factually incorrect, internally inconsistent, and technically impossible information in its XX/XX/XXXX response to the CFPB. 

Concora now claims that my XX/XX/XXXX debit-card payment of {$1100.00} was returned for insufficient funds on XX/XX/XXXX and XX/XX/XXXX. 
My bank statement, payment confirmations, and Concoras own call notes prove this explanation is false. 

The company failed to conduct a reasonable FCRA reinvestigation, supplied inaccurate information to the CFPB, and reported a 30-day late that could not have legally existed under XXXX XXXX credit reporting rules. 

I request reopening, supervisory escalation, and enforcement review.

1. Bank Statement Proves the Insufficient Funds Claim Is False ( Exhibit D XXXX XXXX  XX/XX/XXXX Statement ) Concora claimed it received two insufficient-funds notices ( XX/XX/XXXX and XX/XX/XXXX ). 
My bank statement shows : No NSF fee No returned payment No reversal entry No decline Balances of {$2200.00} {$8900.00}, far above the {$1100.00} payment Under debit-network rules, a payment can not be returned 13 days later without : a return code, an NSF fee, a reversal entry, or any bank record. 

None exist. 

Concoras NSF claim is factually impossible and unsupported by any banking evidence. 



2. Concora Confirmed Receipt of All Payments ( Exhibits A, B, & C ) Concora issued confirmations stating : XX/XX/XXXX Your payment has been RECEIVED ( {$1100.00} ) XX/XX/XXXX Payment received ( {$250.00} ) XX/XX/XXXX Payment received ( {$620.00} ) These confirmations show : The disputed payment was successfully authorized, accepted, and posted I made additional payments immediately when I discovered an issue My account was fully paid before any 30-day delinquency could exist This contradicts Concoras later claim that the account was still 30 days late.

3. Concoras Call Notes Contradict Their Written Explanation ( Exhibit E Call Notes ) On XX/XX/XXXX, Concoras representative : acknowledged lack of notice of any reversal waived fees, indicating awareness of internal error promised to dispute the false late reporting made no mention of insufficient funds or returned payments This directly conflicts with Concoras XX/XX/XXXX narrative and indicates that the returned payment explanation was created after CFPB involvement, not supported by contemporaneous records. 



4. Concoras XX/XX/XXXX CFPB Response Contains Provably False Statements ( Exhibits F & G ) Concoras response asserts : an initial insufficient funds notice on XX/XX/XXXX a final confirmation on XX/XX/XXXX possible notification by my bank account access blockage because I was seeking legal counsel Every one of these statements is contradicted by evidence : My bank statement shows no NSF events I received no bank notice Concora accepted multiple payments after the dates they claim they were receiving NSF notices I did not appoint legal counsel, making their stated reason for blocking access retaliatory These contradictions raise concern that Concora submitted inaccurate or fabricated information to a federal agency and failed its FCRA reinvestigation obligations.

5. The Reported 30-Day Late Is Not Legally Permissible Under XXXX XXXX reporting standards : A 30-day late may ONLY be reported if the account remained continuously unpaid for 30 days after the due date.

That did NOT occur. 

Because : I made a payment on XX/XX/XXXX, which resets the delinquency clock Concora accepted that payment Concora internally reversed it 13 days later without notice I immediately made two corrective payments ( XX/XX/XXXX, XX/XX/XXXX ) There was no uninterrupted 30-day delinquency.

Thus, reporting a 30-day late is inaccurate and noncompliant with FCRA 1681s-2 ( a ) and 1681s-2 ( b ).

6. Documentation Requested but Not Provided I requested the specific documentation Concora would be required to possess if its explanation were true : the ACH/debit return code for XX/XX/XXXX and XX/XX/XXXX the authorization log for the XX/XX/XXXX debit payment and alleged reattempts the bank return notice Concora claims it received the furnishers method of verification ( required under FCRA 1681i ( a ) ( 7 ) ) delinquency calculation records showing continuous nonpayment for 30 days Concora produced none of these items because these events did not occur.

7. Evidence Suggests a Pattern of Deceptive Conduct ( UDAAP ) Multiple factors indicate more than a simple error : Only the highest-fee subprime product ( Milestone Mastercard ) had its payment reversed The reversal occurred 13 days later, inconsistent with debit-network protocols No bank evidence, return code, or NSF record exists Account access was blocked after I exercised my rights The company changed its explanation only after regulatory involvement This suggests a potential pattern of practice designed to retain fee revenue and keep accounts in subprime statusconduct that may constitute unfair, deceptive, or abusive acts and practices.

8. Consumer Harm I have been forced to invest substantial time, effort, and resources correcting an error that should never have occurred, including : compiling exhibits, issuing certified letters, filing multiple CFPB complaints, reconstructing payment histories, responding to shifting explanations, and attempting to obtain documents the company is legally required to maintain.

This level of consumer burden is itself a form of harm recognized under UDAAP.

Requested Action I respectfully request that the CFPB : Reopen the prior cases and treat this as new material evidence contradicting the furnishers CFPB response. 

Compel ConcoraXXXX XXXX XXXX XXXX to produce : the return code, the bank return notice, the authorization log, and delinquency calculation records.

Direct the furnisher to remove the inaccurate 30-day late from all credit bureaus.

Refer this matter to CFPB Supervision & Enforcement and the OCC for review of potential false furnisher conduct and UDAAP violations.

Company response to consumer: Closed with explanation