Consumer complaint received 2025-03-24 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Problem with a company's investigation into an existing problem — Was not notified of investigation status or results
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: DC

Complaint narrative:
XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXXXXXX XXXX XXXX XXXXXXXX XXXX XX/XX/XXXX To : Transunion Consumer Financial Protection Bureau ( CFPB ) Federal Trade Commission ( FTC ) Securities and Exchange Commission ( SEC ) Federal Communications Commission ( FCC ) Office of the Comptroller of the Currency ( OCC ) National Association of Attorneys General ( NAAG ) U.S. Department of Justice ( DOJ ) Civil Division DOJ Consumer Protection Branch ( CPB ) RE : Request for Immediate Federal and Multi-State Enforcement Against TransUnion for Systemic Violations of Federal and State Consumer Protection Laws and Obstruction of FCRA Rights I am submitting this formal enforcement referral regarding TransUnion for violating federal and state consumer protection statutes through fraudulent suppression of disputes, evasion of regulatory timelines, failure to properly process consumer dispute claims, and provision of deceptive and misleading responsesall in violation of their statutory obligations under the Fair Credit Reporting Act ( FCRA ), Consumer Financial Protection Act ( CFPA ), and corresponding D.C., Pennsylvania, Illinois, and New York consumer protection laws.

This referral is supported by an attached, sworn and notarized Affidavit of Truth ( AOT ), which affirms under penalty of perjury the factual accuracy of the allegations and evidentiary timeline presented, and by a formal Federal Trade Commission ( FTC ) Fraud Report, filed to document TransUnions systemic deception and noncompliance under 15 U.S.C. 45. These documents are included to establish factual basis, sworn attestation, and prior regulatory notification. 
Also attached are letters, received from TransUnion on XX/XX/XXXX in the same envelope, labeled here as XXXX and XXXX, serve as critical evidence of ongoing violations. 
TransUnions Deliberate Failure to Link Communications to Specific Disputes Both Letter XXXX ( Re : Dispute Status ) and Letter XXXX ( Re : Explanation of the Inquiries on Your Credit Report ) were received by me on the same day in the same envelope but fail to identify which dispute or CFPB Complaint ID they address. This is not a clerical oversightit is a recurring practice that : 1. Obstructs consumer understanding of dispute outcomes under FCRA 1681i ( a ) ( 6 ) ( B ), which mandates that CRAs clearly disclose the results of each reinvestigation.

2. Denies procedural transparency by omitting essential identifiers such as : o Dispute subject ( e.g., creditor name or inquiry source ), o Filing date, o Outcome reasoning, o Reinsertion notifications or suppression confirmations.

By sending generic, ambiguous letters disconnected from any specific complaint, TransUnion has : Frustrated regulatory oversight by making it impossible for agencies like the CFPB to trace outcomes back to specific complaints. 
Compromised consumer recordkeeping, which is essential to maintaining accountability and exercising legal remedies. 
Constructively evaded enforcement by preventing both consumers and regulators from matching TransUnions responses to statutory timelines or legal obligations under pending complaints.

This lack of linkage directly violates : FCRA 1681i ( a ) ( 7 ) : Failure to describe the procedure used for each reinvestigation.

15 U.S.C. 45 : As a deceptive business practice that creates the illusion of compliance without actual transparency.

State-level statutory requirements in D.C., Pennsylvania, Illinois, and New York , all of which recognize misrepresentation and omission as violations of consumer protection laws.

This is especially egregious given that I currently have four active CFPB complaints pending against TransUnion : XXXX ( submitted XX/XX/XXXX ) XXXX ( submitted XX/XX/XXXX ) XXXX ( submitted XX/XX/XXXX ) XXXX ( submitted XX/XX/XXXX ) Their responses reflect no effort to identify which, if any, of those complaints they purport to resolvedespite statutory obligations and federal mandates requiring such disclosures in dispute communications. 
Accordingly, I request that this pattern be investigated as a systemic obstruction of due process and be treated as an aggravating factor in any penalties, injunctive relief, or criminal referrals imposed by your offices. 
Breakdown of TransUnion 's Letters and Conduct Letter XXXX : " Re : Dispute Status '' TransUnion asserts that an item I disputed does not currently appear on my credit report and offers no additional details as to : What item was under review.

Whether any investigation took place. 
Whether the item was previously present, deleted, or never existed.

No dispute summary, reinvestigation process, or conclusion was disclosed, despite this being required by law.

Violations : 1. FCRA 1681i ( a ) ( 6 ) ( B ) : TransUnion failed to clearly communicate the results of the reinvestigation. The response is conclusory, vague, and materially omits the substance of the outcome.

2. FCRA 1681i ( a ) ( 7 ) : TransUnion failed to provide a description of the procedure used to investigate the dispute.

3. 15 U.S.C. 45 ( FTC Act ) : The response constitutes a deceptive business practice, creating the illusion of compliance while omitting material facts.

4. D.C. CPPA 28-3904 ( f ) & ( e ) : This conduct involves material omissions and misrepresentations about the status and handling of a consumer complaint.

5. Pennsylvania Unfair Trade Practices and Consumer Protection Law, 73 P.S. 201-2 ( 4 ) ( v ), ( xxi ) : Misleading or deceptive conduct likely to confuse a reasonable consumer about their rights or TransUnion 's obligations.

6. Illinois Consumer Fraud and Deceptive Business Practices Act, 815 ILCS 505/2 : TransUnion engaged in unfair and deceptive conduct by failing to properly identify what was being investigated.

7. New York General Business Law 349 : TransUnions failure to disclose dispute findings misleads consumers regarding their credit records and legal rights. 
Letter XXXX : " Re : Explanation of the Inquiries on Your Credit Report '' TransUnion defended the presence of inquiries based on permissible purpose under FCRA, without identifying the creditor, account, inquiry date, or the basis for assuming authorization. This is a generic form response without tailoring or acknowledgment of the specific dispute submitted.

Notably, TransUnion refused to investigate the inquiry, despite having received a formal dispute that challenged an inquirys legitimacy, see CFPB Complaint ID XXXX. 
Violations : 1. FCRA 1681i ( a ) ( 1 ) : Failure to conduct a reasonable reinvestigation into disputed inquiries.

2. FCRA 1681i ( a ) ( 2 ) : Failure to forward all relevant information about the dispute to the furnisher of the inquiry.

3. FCRA 1681c-2 ( a ) : Failure to block information resulting from fraud, where identity misattribution was raised.

4. FCRA 1681e ( b ) : Failure to ensure maximum possible accuracy where the source or legitimacy of inquiries remains unclear or contested.

5. D.C. CPPA 28-3904 ( f ) & ( e ) : Misrepresenting rights related to dispute of inquiries and permissible purpose.

6. Pennsylvania 73 P.S. 201-2 ( 4 ) ( v ), ( xxi ) : TransUnions refusal to investigate potential unauthorized inquiries constitutes deceptive conduct.

7. Illinois 815 ILCS 505/2 : Failure to explain the inquiry in context constitutes concealment and misrepresentation of consumer credit activity.

8. New York GBL 349 : TransUnions refusal to properly handle a dispute concerning inquiries misrepresents the consumers right to challenge inaccuracies.

Legal Basis for Enforcement Federal Statutory Violations : FCRA 1681i ( a ) ( 1 ), ( 2 ), ( 6 ), ( 7 ), 1681e ( b ), 1681c-2 ( a ) 15 U.S.C. 1681n ( willful noncompliance ), 1681o ( negligent noncompliance ) 15 U.S.C. 45 ( unfair and deceptive acts and practices under the FTC Act ) Criminal Conduct Warranting DOJ Review : 18 U.S.C. 1001 : False statements or material omissions in regulatory disclosures.

18 U.S.C. 1343 ( Wire Fraud ) : Communications made with intent to defraud through omissions or deceptive resolution letters.

18 U.S.C. 1962 ( RICO ) : Pattern of deceptive conduct and evasion of lawful regulatory process with commercial gain.

Pattern of Evasion, Misrepresentation, and Systemic Risk TransUnions conduct reflects more than isolated oversightit reveals a deliberate and coordinated pattern of regulatory evasion, legal misdirection, and procedural suppression of consumer rights. The companys repeated failure to provide dispute results that are linked, transparent, or complete represents not only noncompliance with statutory mandates, but an intentional effort to frustrate consumer remedies and obstruct regulatory scrutiny. 
By sending vague, unlinked letters in response to active legal complaintseach omitting dispute identifiers, outcomes, or investigation detailsTransUnion is : Creating the false appearance of compliance while actively circumventing FCRA and CFPA procedural obligations.

Avoiding accountability by denying consumers and regulators the ability to audit or verify whether statutory timelines and investigation duties were met.

Suppressing dispute clarity in a way that weakens the CFPBs ability to monitor patterns across complaints and undermines multi-agency oversight.

This behavior is not unique to a single incidentit has emerged across multiple complaints, through multiple letters, involving distinct issues such as inquiry legitimacy, personal information suppression, and permissible purpose disputes. When paired with sworn documentation ( Affidavit of Truth ), an FTC fraud report, and active CFPB complaints, this reveals a structure of willful obstruction and legal misrepresentation that can not be resolved through informal channels alone. 
Given the volume of unresolved complaints, the absence of meaningful engagement, and the critical role TransUnion plays in the national financial infrastructure, these violations expose both consumers and institutions to systemic risk. Enforcement is not merely appropriateit is required to preserve the integrity of the credit reporting system.

Prior Enforcement History and Regulatory Pattern TransUnions current conduct can not be viewed in isolation. In 2017, the Consumer Financial Protection Bureau issued a Consent Order against TransUnion for engaging in deceptive marketing practices and misrepresentations about the usefulness and cost of credit scores and reports. That action resulted in {$13.00} million in restitution and a {$3.00} million civil penalty. More recently, TransUnion has also faced repeated scrutiny for its handling of disputes, failure to maintain accurate consumer information, and use of evasive communications to avoid accountability.

The pattern of conduct I am reportinggeneric responses, failure to tie dispute outcomes to specific CFPB complaint IDs, suppression of reinvestigation detail, and misrepresentation of permissible purposeis not new. It reflects a continued and willful disregard for statutory compliance, even after having been placed under consent decree and federal supervision. 
Given this history, I respectfully request that regulators treat this matter as part of an ongoing systemic noncompliance pattern, and not as a one-off violation. Enforcement actions should reflect that TransUnion has had ample opportunity to correct its processes and has instead doubled down on opaque, deceptive, and obstructive tactics.

Supporting Case Law The following federal appellate and district court decisions reinforce the legal arguments presented above and confirm that the conduct exhibited by TransUnionranging from failure to reinvestigate to deceptive dispute communicationshas been previously adjudicated as unlawful under the FCRA. These cases establish binding and persuasive precedent that : 1. Willful and negligent violations of the FCRA carry statutory and compensatory liability ; 2. Reinvestigations must be meaningful, not perfunctory ; and 3. Patterned noncompliance and vague responses constitute actionable failures that expose CRAs to enforcement and judicial remedy.

Each case cited below illustrates the legal threshold for compliance and underscores how TransUnions actions meet or exceed the level of misconduct required to justify regulatory and judicial intervention. 
XXXX. XXXX XXXX. XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) Willful FCRA violations include reckless disregard for legal duties. 
XXXX. XXXX XXXX Trans Union XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) Reinvestigation must go beyond parroting the furnishers response. 
XXXX. XXXX XXXX XXXX, XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) Negligent or minimal FCRA reinvestigation procedures result in liability. 
XXXX. XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) CRA must ensure accuracy under 1681e ( b ). 
XXXX. XXXX v. Trans Union XXXX XXXX. XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) Pattern of inaccuracies supports systemic noncompliance. 
XXXX. XXXX v. XXXX XXXX. XXXX, XXXX XXXX XXXX XXXX XXXX ( C.D. XXXX. XXXX XXXX, XXXX ) Failure to block disputed data under FCRA 1681c-2 ( a ) was actionable. 
XXXX. XXXX v. XXXX, XXXX XXXX XXXX ( XXXX. XXXX XX/XX/XXXX ) Vague or generic response letters violate reinvestigation obligations.

Request for Immediate Action Based on the conduct described in TransUnions letters and its failure to meet its legal obligations under federal and state law, I request the following : 1. A m
ulti-agency investigation into TransUnions systemic FCRA and CFPA violations.

2. Civil monetary penalties and injunctive relief imposed under the CFPBs UDAAP authority and the FTC Act.

3. Referral to DOJ for potential criminal charges under 18 U.S.C. 1001 and 18 U.S.C. 1343 based on deceptive regulatory correspondence.

4. State Attorney General coordination through NAAG to evaluate violations under D.C., PA, IL, and NY consumer protection statutes.

5. Review by the SEC regarding TransUnions public disclosures and risk reports, in light of growing FCRA liabilities.

6. FCC inquiry into misuse of consumer data across communication channels, particularly if auto-dispute responses originate from third-party integrations.

7. An order compelling TransUnion to lawfully fulfill its statutory obligations under the Fair Credit Reporting Act and Consumer Financial Protection Act by issuing complete, timely, and specific responses to my currently open CFPB complaints : XXXX ( submitted XX/XX/XXXX ), XXXX ( submitted XX/XX/XXXX ), XXXX ( submitted XX/XX/XXXX ), XXXX0 ( submitted XXXX XXXX XXXX ), This includes : i ) Identification of each disputed item, ii ) A clear statement of the outcome, iii ) A description of the reinvestigation procedures used, and iv ) Delivery of these results within the mandated statutory timeframe.

( a ) TransUnions failure to do so constitutes an ongoing violation of FCRA 1681i ( a ) ( 6 ) ( B ) and 1681i ( a ) ( 7 ), and further obstructs regulatory review by the CFPB and other oversight bodies.

I am prepared to submit additional documentation, sworn statements, and certified dispute filings supporting each claim described herein. I am also willing to cooperate with any federal or state agency conducting further review. 
Respectfully, XXXX XXXX XXXX Attachments : Sworn and Notarized Affidavit of Truth FTC Fraud Report : XXXX

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