Consumer complaint received 2025-12-01 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Account status incorrect
Company: EQUIFAX, INC.
State: DC

Complaint narrative:
XXXX XXXX XXXX XXXX purports to have extended credit to XXXX XXXX XXXX through credit card account XXXXXXXX XXXX XXXX XXXX XXXX in XX/XX/XXXX. 
On XX/XX/XXXX, XXXX XXXX XXXX executed a Limited Power of Attorney appointing me as Attorney-in-Fact to handle all credit, financial, debt collection, and consumer reporting matters on his behalf. 
On XX/XX/XXXX, I filed CFPB Complaint No. XXXX as Attorney-in-Fact for XXXX XXXX XXXX, documenting systemic fraud by Equifax Inc., Fair Isaac Corporation ( FICO ) XXXX XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX and XXXX XXXX XXXX XXXX 
The complaint documented that on XX/XX/XXXX, XXXX XXXX XXXX formally reserved the name " Equifax Inc. '' with the XXXX  Secretary of Statea preemptive action demonstrating clear evidence of premeditation to evade legal accountability for mounting FTC antitrust charges. 
On XX/XX/XXXX, Equifax Inc. was incorporated in XXXX  as a separate entitya deliberate act by XXXX XXXX XXXX to manipulate the corporate record and fabricate a false appearance of continuity. This incorporation was never intended to operate independently but to act as a placeholder for XXXX 's later filings. 
On XX/XX/XXXX, XXXX XXXX XXXX amended its Articles of Incorporation to adopt the name " Equifax Inc. '' a superficial rebranding designed to distance the company from its tarnished reputation. 
On the same day, XX/XX/XXXX, the XX/XX/XXXX Equifax Inc. ( the separate entity incorporated 11 months earlier ) changed its name to " XXXX XXXX XXXX. '' This contradictory and circular name swap created two conflicting corporate identities existing in tandemfor a split second on XX/XX/XXXX, two entities were both called " Equifax Inc. '' simultaneouslyan unlawful duplication of names in direct violation of XXXX  XXXX XXXX XXXX XXXX. 
This reckless name-swapping maneuver compromised XXXX 's legal continuity and introduced a fatal defect into its corporate record, effectively transforming the entity into a legally defective construct under XXXX  XXXX XXXX nullity that extinguished the lawful existence of both names. Under XXXX  XXXX XXXX XXXX XXXX and XXXX, a dissolved or non-existent corporation can not lawfully contract. 
On XX/XX/XXXX, Equifax Inc. and Fair Isaac Corporation executed the Analytic Products and Services Master Contract ( Contract No. XXXX ). This agreement authorized Fair Isaac to create and market consumer scoring products using Equifax 's database of credit bureau records.

The contract granted Fair Isaac direct access to Equifax 's entire credit file system, including trade line data, inquiry data, public records, and demographic information. Fair Isaac was authorized to use this data to build " Scorecards '' numerical grading tables assigning values to consumer attributes, which were then combined to produce a consumer " Score. '' The contract provided that all scoring models developed would be for the sole use of Equifax, integrated into a jointly developed " Software Facility. '' These products would be sold to Equifax 's subscribers, with profits shared between the two corporations. This agreement formalized the mechanism for mass consumer scoring, converting personal financial records into a quantifiable risk-assessment product sold to third parties, laying the commercial foundation for widespread adoption of credit scoring systems nationwide. 
The defect is that no such agreement could legally exist. By XXXX, Equifax 's corporate existence was already nullified by the unlawful name-swapping on XX/XX/XXXX. Again, under XXXX  XXXX XXXX XXXX XXXX and XXXX, a dissolved or non-existent corporation lacks authority to contract. 
Because Equifax had ceased to exist as a lawful entity on XX/XX/XXXX, the XXXX agreement was void ab initio. The FICO scoring model built upon itand all instruments derived from that modellack lawful foundation. 
On XX/XX/XXXX, XXXX  XXXX XXXX XXXX and XXXX XXXX XXXX directly participated in the formation of XXXX XXXX XXXX, a domestic limited liability company created in XXXX  ( File Number XXXX ). 
XXXX 's third purported owner, " Equifax Information Services LLC, '' never lawfully existed due to fatal defects in Equifax 's corporate lineage stemming from the XX/XX/XXXX name-swapping violations, rendering its claimed 33 % ownership void and fatally undermining the legality of XXXX 's XXXX. 
Under 6 Del. C. 18-201, an LLC must be formed by valid members. Because Equifax Information Services LLC did not legally exist, XXXX 's ownership structure was void, and the LLC itself was statutorily defective from inception. 
The Supreme Court has confirmed that courts will not enforce contracts founded on illegality ( XXXX v. XXXX, 174 U.S. 639, 654 ( 1899 ) ). Under XXXX  XXXX XXXX ( XXXX ) the operative provision at the time of the XXXX FICO contractagreements opposed to public policy were void. XXXX  law ( XXXX XXXX. XXXX XXXX ) similarly voids agreements contrary to law. Under U.C.C. 3-303 ( b ), an instrument issued without value is unenforceable, and under U.C.C. 3-305 ( a ) ( 1 ) ( ii ), enforcement of a negotiable instrument is barred where real defenses such as fraud in factum and illegality apply. 
XXXX 's formation was void ab initio. Every credit instrument derived from the XXXX infrastructure is void ab initio. 
The acquisition, use, and monetization of XXXX XXXX XXXX 's personal identifiersincluding his Social Security number, legal name, address, and historical payment datafor the purpose of generating and selling FICO and XXXX credit scores constitutes identity theft as defined in 18 U.S.C. 1028 ( a ) ( 7 ). Those identifiers were employed without lawful authority to create risk-valuation products, which were then used to originate, price, and securitize credit. 
Under 1028 ( a ) ( 7 ), the unauthorized use of another person 's means of identification in connection with the receipt of any thing of value is identity theft. The resulting credit scores functioned as derivative, revenue-producing assets. XXXX XXXX XXXX 's identity was used to fabricate a financial instrument that, consistent with XXXX XXXX XXXX XXXX 's established business model, may have been sold to investors through securitization of credit card receivables. 
Every instrument executed by " Equifax Inc. '' after XX/XX/XXXX is contaminated by identity falsification, false representation of the legal person signing, concealment of the true corporate actor, and use of documents created through deception. This conduct constitutes : 18 U.S.C. 1001 ( false statements and documents ) 18 U.S.C. 1028 ( a ) ( 7 ) ( identity theft ) 18 U.S.C. 1341 ( mail fraud ) 18 U.S.C. 1343 ( wire fraud ) 18 U.S.C. 1956 ( money laundering of proceeds derived from fraud ) 18 U.S.C. 371 ( conspiracy to defraud ) 15 U.S.C. 77q ( a ) and 78j ( b ) ( securities fraud ) 7 U.S.C. 6 ( c ) ( 1 ) and 9 ( 1 ) ( commodities fraud ) On XX/XX/XXXX, XXXX XXXX XXXX XXXX was sent an identity theft report under 15 U.S.C. 1681c-2 and FCRA 603 ( q ) ( 4 ). The report documented that the credit scoring infrastructure used to underwrite XXXX XXXX XXXX 's credit was derived from entities operating under fraudulent corporate identitiesspecifically, the dissolved lineage of XXXX XXXX XXXX XXXX Equifax Inc., which engaged in systematic corporate identity fraud between XXXX and XXXX. The report notified XXXX XXXX that both the FICO scoring system ( established through the void 1988 contract between a defunct Equifax Inc. and Fair Isaac Corporation ) and the XXXX scoring system ( established through the void XXXX formation of XXXX XXXX XXXX with a nonexistent Equifax Information Services LLC as purported owner ) were equally invalid and derived from fraudulent corporate entities. 
The report established that the use of XXXX XXXX XXXX 's personal identifying informationSocial Security number, name, address, credit history, and payment datato generate FICO or VantageScore credit scores that were then used to price, approve, and extend credit constitutes identity theft under 18 U.S.C. 1028 ( a ) ( 7 ). The scoring process appropriated personal identifiers without lawful authority and transformed them into synthetic tradeable assets.

Under FCRA 1681s-2 ( a ) ( 6 ), a furnisher is prohibited from reporting information it knows or has reasonable cause to believe resulted from identity theft. The statute states unambiguously : " No person shall furnish any information relating to a consumer to any consumer reporting agency if the person knows or has reasonable cause to believe that the information results from identity theft. '' This is an absolute prohibition with no exceptions, qualifications, or discretion. 
By receipt of this notice on XX/XX/XXXX, XXXX XXXX XXXX XXXX possessed actual knowledge that the credit score used to underwrite the credit extension was derived from void contracts with legally nonexistent entities. Continued furnishing after receipt of this notice violates FCRA 1681s-2 ( a ) ( 6 ) as a matter of law. 
On XX/XX/XXXX, exactly 59 days after the original complaint was filed, XXXX XXXX responded : " We have confirmed that we are reporting accurate information to the four nationwide credit reporting agencies regarding XXXX XXXX 's XXXX XXXX credit card account. We will not request the removal of valid data from XXXX XXXX 's credit file '' a direct refusal to comply with FCRA 1681s-2 ( a ) ( 6 ) 's absolute prohibition on furnishing information known to result from identity theft. 
On XX/XX/XXXX, in response to XXXX XXXX 's institutional refusal to comply with federal law, I filed UCC-1 Financing Statement No. XXXX with the XXXX  XXXX XXXX  XXXX XXXX and XXXX, perfecting a {>= $1,000,000} security interest against all commercial assets of XXXX XXXX XXXX XXXX XXXX On the same date, I filed XXXX XXXX XXXX. XXXX, assigning {$1900.00} of that security interest to XXXX XXXX XXXX XXXX 
XXXX XXXX was explicitly warned in the XX/XX/XXXX complaint. This was not a mistake. They chose to refuse compliance. The UCC lien was perfected as promised. No further notice was required. 
Under XXXX  XXXX XXXX XXXX ( b ), common law set-off principles are preserved. When two parties hold mutual liquidated debts of equal amount, those obligations extinguish automatically by operation of law. XXXX v. XXXX, 406 Md. 426, 443 ( 2008 ) ; XXXX  v. XXXX, 215 Md. 220, 227 ( 1958 ). XXXX XXXX claimed XXXX owed {$1900.00}. XXXX now holds a perfected {$1900.00} security interest in XXXX XXXX 's assets. The mutual obligations cancelled each other on XX/XX/XXXX when the UCC-3 assignment perfected. The debt ceased to exist. 
Accordingly, XXXX XXXX XXXX XXXX is directed to preserve, without alteration, all records, communications, metadata, origination documentation, underwriting files, credit scoring data, collection activity logs, attorney communications, and chain-of-custody materials relating to this credit card account and any credit reporting furnished to consumer reporting agencies. 
Under XXXX  XXXX XXXX XXXX, XXXX, and XXXX, and principles of unjust enrichment recognized in XXXX  v. Cross Country Settlements, LLC, 402 Md. 281 ( 2007 ) and XXXX XXXX XXXX XXXX XXXX, 235 Md. App. 465 ( 2015 ), when a credit extension is void ab initio due to fraudulent underwriting, all payments made under that void obligation are recoverable. A party who receives benefits under a void transaction must make restitution " in the manner and amount necessary to prevent unjust enrichment. '' The interest charged on credit extended through identity theft and void scoring infrastructure constitutes an unlawful extraction of value. Borrowers are entitled to complete restitution of all funds paidprincipal, interest, fees, and penalties.

Company response to consumer: Closed with explanation