Consumer complaint received 2025-04-25 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Information belongs to someone else
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: FL

Complaint narrative:
Subject : Formal Demand for Immediate Suppression and Legal Compliance FCRA Violations Involving Unlawful Reinsertion To Whom It May Concern, I am writing to formally notify your agency that Experian has unlawfully reinserted an account that was previously removed from my credit file, in direct violation of the Fair Credit Reporting Act ( FCRA ), including but not limited to 15 U.S.C. 1681i, 1681c-2, and 1681s-2 ( b ). This letter constitutes my final warning before initiating legal action.

Account ( s ) in Question The reinserted account ( s ) at issue in this dispute are as follows : XXXX XXXX Account ending in [ XXXX These accounts were previously removed after formal disputes and have now been unlawfully reinserted into my Experian credit file without proper certification from the data furnisher and without the legally required notice to me, as required by federal law. 
Your agencys actions not only mirror the conduct that led the Consumer Financial Protection Bureau ( CFPB ) to fine XXXX {$15.00} XXXX in XX/XX/XXXX, but also reflect the very behavior for which Experian itself is currently being sued by the CFPB. That lawsuitfiled in XXXX XXXXalleges that Experian engaged in sham investigations, unlawful reinsertions, and failed to adequately respond to consumer disputes, all in direct violation of federal law. 

This reinsertion occurred without legally required notice, certification, or a legitimate reinvestigation. If this account is not immediately removed and suppressed during reinvestigation, I will pursue litigation without further notice, along with regulatory complaints and all available legal remedies under the Fair Credit Reporting Act. 



CFPB Enforcement Action Against XXXX Precedent for Your Legal Liability On XX/XX/XXXX, the Consumer Financial Protection Bureau ( CFPB ) issued a landmark enforcement action against XXXX XXXXXXXX and XXXX  XXXX XXXX XXXX, imposing a {$15.00} XXXX penalty for egregious violations of the Fair Credit Reporting Act ( FCRA ). The CFPBs investigation revealed multiple systemic failures, including : Reinserting previously deleted accounts without obtaining legal certification, in violation of 15 U.S.C. 1681i ( a ) ( 5 ) ( B ).

Failing to notify consumers within five ( 5 ) business d
ays of reinsertion, as required under the same statute.

Conducting inadequate reinvestigations, in violation of 15 U.S.C. 1681i ( a ) ( 1 ) ( A ), by ignoring consumer-provided documentation.

Relying exclusively on automated systems ( e.g., e-OSCAR ) instead of conducting a meaningful human review, contrary to obligations under 15 U.S.C. 1681e ( b ) and 1681s-2 ( b ). 
The CFPB concluded that XXXX knowingly and willfully engaged in deceptive, unfair, and unlawful credit reporting practices, causing substantial and measurable harm to consumers nationwide. The ruling set a clear precedent : federal regulators will not tolerate systemic FCRA violations. 
Experian is now engaging in the exact same misconduct, which is why the CFPB filed suit against your agency in XX/XX/XXXX, alleging widespread violations of the FCRAincluding sham investigations, illegal reinsertion of deleted accounts, and failure to properly investigate consumer disputes. 
The precedent has been set. If XXXX can be fined, and Experian can be sued, then Experian can also be held fully accountable in this matter. If this unlawful account is not immediately removed from my credit report, I will proceed with litigation without further notice, and pursue maximum statutory and punitive damages under 15 U.S.C. 1681n and 1681o, in addition to filing complaints with the CFPB, FTC, and Attorney General. 
To be absolutely clear, your agency is currently in violation of the following federal statutes : VIOLATIONS OF FEDERAL LAW Violation of 15 U.S.C. 1681c-2 ( b ) : Unlawful Reinsertion Without Certification You have failed to provide legal certification from the furnisher before reinserting this account.

You have failed to notify me of this reinsertion within five ( 5 )
business days.

Violation of 15 U.S.C. 1681i ( a ) ( 5 ) ( B ) : Failure to Notify the Consumer The law requires that I must be notified in writing if previously deleted information is reinserted.

I never received such notice, making this reinsertion unlawful.

Violation of 15 U.S.C. 1681i ( a ) ( 1 ) ( A ) : Failure to Remove the Account During Investigation This section requires that disputed information be suppressed while a reinvestigation is pending. 
If this account is still appearing on my report while under review, you are in violation of federal law.

Violation of 15 U.S.C. 1681s-2 ( b ) : Furnishers Duty to Investigate The furnisher must conduct a meaningf
ul, detailed reinvestigation and can not rely on automated systems like e-OSCAR. 

In XXXXXXXX XXXX TransUnion XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX ), the court ruled that a mere electronic verification is insufficient under the FCRA. 



FORMAL DEMANDS FOR IMMEDIATE AND PERMANENT SUPPRESSION Immediate Suppression of This Account During Reinvestigation Pursuant to 15 U.S.C. 1681i ( a ) ( 1 ) ( A ), you are legally required to suppress this account from all versions of my credit report while any reinvestigation is pending. 
If this account remains visible while under dispute, you are in direct violation of federal law and will face regulatory complaints and civil litigation without further notice. 
Permanent Suppression Unless Legally Certified Documentation Is Provided If you or the data furnisher attempt to reinsert this account in the future, you must first provide the following documentation for legal certification and review : Complete Investigation Log Full audit trail of all actions taken to verify this account.

Names and employee IDs of individuals involved. 

Timestamps of each step performed. 

Chain-of-Custody Documentation All records showing legal transfer of the account between the original creditor and any third-party furnishers. 
Copies of billing statements validating the accuracy and validity of the debt.

Internal Communications & Review Notes Internal emails, memos, and notes related to this dispute or reinvestigation. 

Name and title of the person who certified the accounts accuracy.

Full Call Logs and Audio Recordings If any phone-based verification occurred, I demand the complete call recordings and transcripts. 
Failure to provide this constitutes an incomplete reinvestigation under the FCRA. 
Legally Sworn Affidavit from a Senior Corporate Officer of the Data Furnisher A legally sworn affidavit must be signed under penalty of perjury by a senior corporate officer of the data furnisher ( e.g., creditor or collection agency ) not a c
all center employee or third-party contractor. 
The affidavit must confirm that all submitted documentation is true, complete, accurate, and legally certified in accordance with the Fair Credit Reporting Act. 
Failure to provide this affidavit renders any future reinsertion of the account legally invalid.

FTC Identity Theft Affidavit Verification Requirement ( Mandatory Under 15 U.S.C 1681i, 1681s-2 ( a ) ( 1 ) ( A ), 1681e ( b ), and 1681m ( e ) ) If an FTC Identity Theft Affidavit was submitted during any previous dispute or investigation concerning the account ( s ) listed in this letter, Experian is legally obligated to verify the affidavits authenticity with the Federal Trade Commission and provide full documentation of that verification process. Pursuant to your obligations under 15 U.S.C. 1681i ( a ) ( 1 ) ( A ) and 1681s-2 ( a ) ( 1 ) ( A ), you must produce the following materials without exception : FTC Verification Confirmation The full name, job title, and employee ID of the Experian representative who contacted the FTC to verify the affidavit. 

The exact date, time, and method of contact used to initiate verification with the FTC ( e.g., phone call, secure database, written correspondence ). 

A copy of the FTCs response or confirmation verifying the affidavits validity. 

Any FTC-generated complaint ID, reference number, or case tracking number issued at the time of verification. 

Experian Internal Investigation & Reference Numbers All internal investigation, tracking, and dispute file numbers associated with the identity theft dispute and reinvestigation. 

These must correspond directly to the account ( s ) listed in this letter and be available for audit and litigation purposes.

Internal Notes, Agent Logs, and Affidavit Review Trail A complete, time-stamped audit trail of all Experian personnel who reviewed or handled the FTC affidavit .

Internal notes, memos, and resolution summaries that document how a final decision was reached. 

This includes any delegation of responsibility, approval signatures, or dispute closure decisions. 

Chain of Custody Documentation ( Affidavit-Specific ) A full set of documents submitted with the FTC affidavit XXXX e.g., police reports, identity documents, proof of residence ). 

A chain-of-custody report detailing when, where, and by whom each document was received, logged, and reviewed. 

Affidavit Handling Procedures Policy A written copy of Experians standard operating procedures for verifying FTC Identity Theft Affidavits, including internal quality control protocols. 
These procedures must comply with federal mandates under 15 U.S.C. 1681m ( e ) regarding identity theft response practices.

All materials and records produced in response to this demand must be accompanied by a legally sworn affidavit or certification, signed under penalty of perjury by a senior Experian officer or
authorized compliance official, in accordance with 15 U.S.C. 1681e ( b ) and 1681m ( e ). This affidavit must confirm that all documentation provided is true, complete, accurate, and in full compliance with Experians obligations under the Fair Credit Reporting Act. Any response lacking such certification will be deemed incomplete and noncompliant.

Failure to verify the FTC affidavit in accordance with 15 U.S.C. 1681i ( a ) ( 1 ) ( A ) and 1681s-2 ( b ) renders any reinvestigation legally insufficient, any reinsertion unlawful, and you
r agency without any valid legal defense.

MANDATORY NOTIFICATION TO ALL CREDIT REPORTING AGENCIES Pursuant to 15 U.S.C. 1681i ( a ) ( 2 ), you are legally obligated to notify all other nationwide consumer reporting agencies XXXX XXXX TransUnion, and Experian, if applicable ) of this dispute within five ( 5 ) business days of receiving it.

Failure to comply with this statutory requirement 
will constitute a direct violation of federal law and will trigger immediate legal action under the Judge in Five Rule, including demands for expedited judicial relief, statutory damages, and injunctive remedies under the Fair Credit Reporting Act ( FCRA ).

This notice is formal and time-sensitive. Noncompliance will result in litigation and regulatory escalation without further warning.

ADDITIONAL LEGAL NOTICE Prohibited Verification Sources Pursuant to FCRA 611 ( a ) ( 1 ) ( A ), Experian is legally obligated to conduct all reinvestigations using reliable, independent, and impartial sources of verification. The use of any source that is a subsidiary, affiliate, or financially connected entity of Experian, TransUnion, XXXX or any national credit reporting agency constitutes a conflict of interest and invalidates the reinvestigation process. 
I hereby demand written certification that none of the following conflicted data providers or affiliated entities were used during any reinvestigation related to the disputed account ( XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX Experian : Clarity Services, Experian RentBureau, Experian Decision Analytics TransUnion : XXXX, XXXX, TransUnion Rental Screening Solutions XXXX XXXX XXXX Other Prohibited Entities : XXXXXXXX XXXX XXXX XXXX XXXXXXXX, Early XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  and XXXXXXXX XXXX XXXX 
Use of any of the above entitiesor any other bureau-controlled or bureau-funded sourceviolates the legal requirement for a fair and independent reinvestigation under the Fair Credit Reporting Act ( FCRA ) and the Fair and Accurate Credit Transactions Act ( FACTA ). Any reinvestigation that relied on these parties will constitute a willful violation of federal law, render the outcome legally invalid, and result in immediate legal action, including the pursuit of statutory, punitive, and injunctive relief under 15 U.S.C. 1681n and 1681o.

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