Consumer complaint received 2025-05-18 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Problem with a company's investigation into an existing problem — Their investigation did not fix an error on your report
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: NJ

Complaint narrative:
To Whom It May Concern, I am writing to formally dispute and demand the immediate removal of all late payment notations reported on my consumer credit reports for the following account, as they are inaccurate, unverifiable, and non-compliant with federal consumer protection laws, Metro 2 Compliance Standards, and Uniform Commercial Code ( UCC ) requirements : Account Details : Account Name : XXXX XXXX  Account Number : XXXX Account Type : Auto Loan Responsibility : Joint with XXXX XXXX Date Opened : XX/XX/XXXX Status : Open Balance : {$9600.00} as of XX/XX/XXXX Monthly Payment : {$510.00} Original Balance : {$26000.00} Terms : 75 Months Payment History : XX/XX/XXXX : 30 days past due XX/XX/XXXX : 60 days past due XX/XX/XXXX : 30 days past due XX/XX/XXXX : 30 days past due Reinvestigation Info : Updated from dispute in XX/XX/XXXX ; consumer disagrees. 

The late payment notations for XX/XX/XXXX ( 30 days late ), XX/XX/XXXX ( 60 days late ), XX/XX/XXXX ( 30 days late ), and XX/XX/XXXX ( 30 days late ) are invalid due to : Missing or incomplete due dates and delinquency dates, rendering the reporting unverifiable. 



Failure to provide required billing statements with payment due date, late payment, and minimum payment disclosures.

Inaccurate reporting in violation of FCRA, TILA, and Metro 2 standards.

Pursuant to 15 U.S.C. 1666b, 15 U.S.C. 1637 ( b ), 15 U.S.C. 1681s-2, 15 U.S.C. 1681i, UCC 9-210, and Metro 2 Compliance Standards, I demand the immediate deletion of these late payments and a full investigation into Experian, TransUnion, and Equifaxs reporting practices.

Legal Basis : Late Payments Require Specific Due and Delinquency Dates Late payment notations on a credit report must be tied to specific, verifiable due dates and delinquency dates to be lawful and compliant. This requirement ensures transparency and protects consumers from erroneous reporting. The following explains the legal and procedural necessity : Due Date Requirement : A late payment can not be reported unless it is linked to a specific payment due date outlined in a billing statement, as mandated by 15 U.S.C. 1637 ( b ) ( Truth in Lending Act, TILA ). The due date is the date by which the minimum payment must be received to avoid delinquency. Without a documented due date, a late payment is unverifiable and can not be reported.

Delinquency Date Requirement : The delinquency date is the date when the payment became past due ( e.g., 30, 60, or 90 days after the due date ). Under Metro 2 Compliance Standards, each late payment must specify the exact date the account became delinquent to accurately reflect the severity ( e.g., 30 days late, 60 days late ). Reporting 30 days late or 60 days late without tying it to a specific delinquency date violates Metro 2s accuracy requirements.

Experian, TransUnion, Equifax Reporting Deficiency : The payment history for the XXXX XXXX account states : XX/XX/XXXX : 30 days late, no due date or delinquency date provided. 



XX/XX/XXXX : 60 days late, no due date or delinquency date provided. 



XX/XX/XXXX : 30 days late, no due date or delinquency date provided. 



XX/XX/XXXX : 30 days late, no due date or delinquency date provided. 
This lack of specificity renders the late payments invalid. For example, a 30 days late notation in XX/XX/XXXX implies a missed payment due in XX/XX/XXXX, but Experian provides no evidence of a XX/XX/XXXX due date or a XX/XX/XXXX delinquency date. Similarly, the 60 days late in XX/XX/XXXX suggests a payment missed in XX/XX/XXXX, but no such date is documented. The subsequent 30 days late in XX/XX/XXXX is inconsistent with a 60-day delinquency progressing, further highlighting the inaccuracy.

Procedural Impact : Without specific due and delinquency dates, the late payments are unverifiable under 15 U.S.C. 1681s-2 ( b ), which requires furnishers ( e.g., XXXX XXXX ) and CRAs ( e.g., Experian ) to ensure reported data is accurate and complete. Metro 2 standards ( Generation V ) mandate that payment history fields ( e.g., Date of Account Information, Date of Last Payment ) align with delinquency status codes ( e.g., 1 for 30 days late, 2 for 60 days late ). Experians failure to provide these dates violates Metro 2s Base Segment and J1/J2 Segments for payment history accuracy.

Failure to Provide Billing Statements with Required Disclosures I assert that I never received monthly billing statements from XXXX XXXX for the periods corresponding to the reported late payments ( XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX ). These statements are required under 15 U.S.C. 1637 ( b ) to include : Payment Due Date Disclosure : The date by which the payment must be received to avoid late fees or delinquency.

Late Payment Disclosure : A warning of the consequences of late payment, such as fees or credit reporting.

Minimum Payment Disclosure : The minimum amount due to remain current.

Explanation of TILA Requirements : 15 U.S.C. 1637 ( b ) mandates that creditors send periodic statements at least 21 days before the payment due date ( per 15 U.S.C. 1666b ), containing the above disclosures. These statements are the primary evidence of a consumers obligation and the basis for reporting delinquency. 



Without these statements, XXXX XXXX can not prove I was notified of the due dates or consequences, rendering the late payments unverifiable. Experians reporting of these late payments without verifying the existence of compliant billing statements violates 15 U.S.C. 1681s-2 ( b ) and Metro 2 standards, which require furnishers to provide documentation of billing and payment history.

The absence of statements also suggests a billing error under 15 U.S.C. 1666b, as XXXX XXXX failed to deliver statements necessary for me to fulfill my payment obligations. This error invalidates the reported delinquencies. 

Inaccurate Reporting Violations The late payment notations are inaccurate for the following reasons, violating FCRA and Metro 2 standards : Inconsistent Delinquency Progression : The payment history shows a 30-day late status in XX/XX/XXXX, escalating to 60 days late in XX/XX/XXXX, then reverting to 30 days late in XX/XX/XXXX. This is logically inconsistent, as a 60-day delinquency typically progresses to 90 days late unless a payment was made to cure the delinquency. Experian provides no evidence of such a payment, and the reversion to 30 days late suggests an error in status coding, violating Metro 2s requirement for accurate delinquency progression ( e.g., codes 1 to 2 to 3 ).

Lack of Verification : Experian, Transunion, Equifax reinvestigation in XX/XX/XXXX, which I disputed, failed to correct these inaccuracies. Under 15 U.S.C. 1681i ( a ) ( 1 ), Experian must conduct a reasonable reinvestigation within 30 days, verifying data with original records ( e.g., billing statements, payment records ). Relying on automated systems like E-OSCAR or unverified furnisher responses does Unverifyable Data : The late payments are unverifiable due to missing due dates, delinquency dates, and billing statements, making their continued reporting a violation of 15 U.S.C. 1681s-2 ( b ).

Metro 2 Non-Compliance : Metro 2 requires accurate reporting of the Account Status Code, Payment Rating, and Date of Account Information. The lack of specific dates and inconsistent delinquency statuses ( 30 to 60 to 30 days ) violates these standards, as does the failure to update the account status after my dispute. This breaches Metro 2s Consumer Information Indicator ( e.g., D for disputed ) and Compliance Condition Code requirements.

Consumer Laws and UCC The following laws support my demand for removal : 15 U.S.C. 1666b ( TILA ) Billing Error Resolution : XXXX XXXX failure to send billing statements constitutes a billing error, as I was not properly notified of my payment obligations. Experians reporting of resulting late payments violates FCRAs accuracy requirements.

15 U.S.C. 1637 ( b ) ( TILA ) Billing Statement Requirements : The absence of statements with due date, late payment, and minimum payment disclosures invalidates the late payments, as Ally Financial failed to comply with TILAs mandatory disclosures.

15 U.S.C. 1681s-2 ( FCRA ) Furnisher Responsibilities : XXXX XXXX  and Experian, Transunion, Equifax failed to ensure the accuracy and completeness of reported data, violating their duty to investigate and correct inaccuracies after my dispute.

15 U.S.C. 1681i ( FCRA ) Reinvestigation Requirements : Experian, Transunion, Equifax inadequate reinvestigation in XX/XX/XXXX, which failed to remove unverifiable late payments, violates the requirement for a reasonable investigation within 30 days. 



UCC 9-210 Request for Accounting : I have the right to demand an accounting of the alleged debt, including billing statements and payment records. XXXX XXXX failure to provide these, and Experians failure to verify them, renders the late payments unenforceable. 

Specific Demands I demand the following immediate actions : Remove All Late Payments : Delete the late payment notations for XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX from my credit reports, as they are unverifiable, inaccurate, and non-compliant. 



Provide Evidence : Produce billing statements for the disputed periods, including payment due date, late payment, and minimum payment disclosures, as required by 15 U.S.C. 1637 ( b ).

Verify Compliance : Confirm that all reporting adheres to Metro 2 Generation V standards, including accurate status codes and delinquency dates.

Cease Reporting : Stop reporting these late payments, as they lack a permissible purpose under 15 U.S.C. 1681b.

Written Confirmation : Provide written confirmation of the removal and an updated credit report within 15 days.

Warning DO NOT attempt to validate these late payments using : Automated E-OSCAR responses or unverified furnisher data.

Generic records lacking specific due and delinquency dates.

Fabricated or incomplete billing statements.

Any attempt to uphold these notations with fraudulent or unverifiable evidence will be treated as willful noncompliance under 15 U.S.C. 1681n, subjecting Experian, TransUnion, Equifax, and XXXX XXXX to : Complaints to the Consumer Financial Protection Bureau ( CFPB ), Federal Trade Commission ( FTC ), and [ Your State ] Attorney Generals Office.

Legal action for violations of FCRA and TILA, seeking statutory damages ( up to {$1000.00} per violation ), actual damages ( e.g., credit harm, emotional XXXX ), and punitive damages, concrete injury damages.

Requests for regulatory sanctions for systemic Metro 2 and FCRA violations.

Investigation Accountability Your investigation must be manual and thorough, including : Direct verification with XXXX XXXX, obtaining original billing statements and payment records. 



A detailed explanation of how each late payment complies with FCRA, TILA, UCC, and Metro 2 standards.

Immediate removal of all unverifiable notations, as required by 15 U.S.C. 1681i ( a ) ( 5 ).

Failure to comply within 15 days will escalate this matter to regulatory and legal action.

Conclusion The late payments reported for the XXXX XXXX account are inaccurate, unverifiable, and unlawful due to missing due and delinquency dates, absent billing statements, and inconsistent reporting. Experian, TransUnion, and Equifaxs failure to correct these violations after my XX/XX/XXXX dispute breaches 15 U.S.C. 1666b, 1637 ( b ), 1681s-2, 1681i, UCC 9-210 , and Metro 2 Compliance Standards . I demand their immediate removal and reserve all rights to pursue remedies for the harm caused by your noncompliance.

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 non-monetary relief