Consumer complaint received 2025-11-12 00:00:00
Product: Debt collection — Credit card debt
Issue: Written notification about debt — Didn't receive enough information to verify debt
Company: Terrill Outsourcing Group
State: CA

Complaint narrative:
ATTN : CFPB * NOTE WELL : THIS CORRESPONDENCE IS NOT A DUPLICATE OR REPETITION OF ANY PREVIOUS CFPB COMPLAINT. * False Statements, False Validation, Privacy Breach, and FDCPA/FCRA Violations by Superlative RM and Absolute Resolutions Investments LLC To : Consumer Financial Protection Bureau Introduction and Case Reference This correspondence is not a duplicate or repetition of any previous CFPB complaint. This is not a duplicate of any previously CFPB Complaint. The earlier cases were closed prematurely and erroneously based on the false representation by Superlative RM that it has sent validation documentation to the complainants address, none of which was received as of XX/XX/year>. 

This filing is supported by new evidence demonstrating FALSE VALIDATION, PRIVACY BREACHES, AND MULTIPLE VIOLATIONS OF FEDERAL AND CALIFORNIA CONSUMER PROTECTION LAWS BY BOTH SUPERLATIVE RM AND ABSOLUTE RESOLUTIONS INVESTMENTS LLC. 


Background and Chronology XXXX. On or about XX/XX/year>, I sent Superlative RM a formal debt validation and cease and desist demand concerning an alleged XXXX XXXX XXXX XXXX account ending in XXXX, reference XXXX. 

XXXX. The letter required full validation within XXXX  days and confirmation that all collection, reporting, and communication activities had ceased. 

XXXX. On XX/XX/year>, Superlative RM represented to the CFPB that it will honor the complaint by processing the request for validation documents and will discontinue all further communication efforts. 

XXXX. As of XX/XX/year>, no legally sufficient validation materials have been received. 

XXXX. Instead, Superlative RM submitted a statement to the CFPB on XX/XX/year>, and XX/XX/year>, FALSELY claiming that validation documentation has been sent to the complainants address. 

As of XX/XX/year> no such required validation has been received. 

XXXX. The documents received were not legally valid. They consisted of another consumers credit card statement containing that persons full name, complete account information, and full Social Security number. 

XXXX. The account and SSN associated with these materials are not mine, are not even similar to my SSN, and bear no connection to me whatsoever. 

XXXX. I have never held an account with XXXX XXXX XXXX XXXX, and no evidence of any contractual obligation or credit relationship between me and XXXX XXXX has ever been produced. 


Material Deficiencies in Validation Superlative RM and XXXX XXXX XXXX XXXX failed to meet the statutory requirements of debt validation under 15 U.S.C. 1692g ( b ). They did not provide : XXXX. A copy of the original signed agreement or contract bearing my genuine wet-ink signature that forms the legal basis of the alleged debt. 

XXXX. A complete itemized statement and accounting of all charges, credits, fees, and interest from inception to present. 

XXXX. The full chain of assignment, sale, or transfer demonstrating lawful transfer of this alleged account from XXXX XXXX XXXX XXXX to any subsequent entity and ultimately to XXXX XXXX XXXX XXXX. 

XXXX. Documentary proof that XXXX XXXX XXXX XXXX is the current legal owner of the alleged debt and that Superlative RM has written authorization to collect on its behalf. 

XXXX. Verification of the date and amount of the last payment allegedly made and supporting records showing how the current balance was calculated. 

XXXX. Copies of all communications or credit reporting submissions made concerning this alleged account to any consumer reporting agency. 

XXXX. Written proof that Superlative RM or XXXX XXXX XXXX XXXX had a permissible purpose under 15 U.S.C. 1681b of the Fair Credit Reporting Act ( FCRA ) to access or report my credit information. A statement that validation has been sent without providing these documents is not compliance. 

Under 15 U.S.C. 1692g ( b ), the collector must produce verification before any further collection or reporting.

Failure to provide complete documentation while continuing to represent that validation occurred constitutes a willful violation of both 15 U.S.C. 1692e ( false representation ) and 1692f ( unfair or unconscionable practices ).

False Validation and Misrepresentation XXXX XXXX XXXX XXXX and Superlative RMs mere assertion that validation has been provided, without delivering the legally required materials, is a direct violation of 15 U.S.C. 1692g ( b ). 
A STATEMENT THAT THEY WILL COMPLY DOES NOT SATISFY STATUTORY VALIDATION. 
They were required to produce the original signed contract, full accounting, and complete chain of title before any further activity. Their failure to do so renders any claim of validation false, deceptive, and legally deficient, violating the Fair Debt Collection Practices Act ( FDCPA ) 1692e, 1692g, and the Fair Credit Reporting Act ( FCRA ) 1681e ( b ) and 1681s-2 ( a ). 


Privacy and Data Breach Violations By sending another consumers credit card statement containing personally identifiable information, including the individuals name, account number, and full Social Security number, Superlative RM and XXXX XXXX XXXX XXXX have engaged in an egregious breach of federal and state privacy laws. 
These actions constitute violations of : Fair Credit Reporting Act ( 15 U.S.C. 1681b, 1681e ( b ) ) for obtaining, using, or disclosing consumer information without permissible purpose and failing to ensure maximum possible accuracy.

Gramm-Leach-Bliley Act ( 15 U.S.C. 6801-6809 ) for failing to safeguard customer information and prevent unauthorized disclosure of nonpublic personal information.

California Consumer Privacy Act and California Privacy Rights Act ( Cal. Civ. Code 1798.100 et seq. ) for unlawful disclosure and mishandling of personal information.

California Rosenthal Fair Debt Collection Practices Act ( Cal. Civ. Code 1788 et seq. ) for unfair and deceptive practices in connection with the collection of consumer debts. This conduct also demonstrates negligent and possibly willful mishandling of another consumers nonpublic data, creating both a privacy violation and potential identity theft exposure. 


Joint Responsibility of Superlative RM and XXXX XXXX XXXX XXXX Both Superlative RM and XXXX XXXX XXXX XXXX is fully liable for the actions of its agent, Superlative RM, under principles of vicarious liability and direct participation. 

As the alleged creditor and data controller, XXXX XXXX XXXX XXXX benefited from and authorized Superlative RMs conduct. Under 15 U.S.C. 1692a ( 6 ) and 15 U.S.C. 1681s-2, both entities are considered furnishers and collectors bound by federal law.

Requested Relief and Enforcement Action I respectfully request that the CFPB : 1. Investigate Superlative RM and Absolute Resolutions Investments LLC for violations of the FDCPA ( 15 U.S.C. 1692 et seq. ), FCRA ( 15 U.S.C. 1681 et seq. ), the Gramm-Leach-Bliley Act ( 15 U.S.C. 6801-6809 ), and California privacy and debt collection laws. 

XXXX. Require immediate production of full and legally compliant validation documentation as specified above - NOT A STATEMENT THAT THEY WILL COMPLY - AS A SIMPLE STATEMENT THAT THEY WILL COMPLY DOES NOT SATISFY STATUTORY VALIDATION. 
If Superlative RM and XXXX XXXX XXXX XXXX can not produce, in full and without omission or deficiency, each of the following items : ( XXXX ) a copy of the original signed agreement or contract bearing my genuine wet-ink signature that forms the legal basis of the alleged debt ; ( XXXX ) a complete itemized statement and accounting of all charges, credits, fees, and interest from inception to present ; ( XXXX ) the full chain of assignment, sale, or transfer demonstrating lawful transfer of this alleged account from XXXX XXXX XXXX XXXX to any subsequent entity and ultimately to Absolute Resolutions XXXX XXXX XXXX XXXX XXXX ) documentary proof that Absolute Resolutions Investments XXXX is the current legal owner of the alleged debt and that Superlative RM has written authorization to collect on its behalf ; ( XXXX ) verification of the date and amount of the last payment allegedly made and supporting records showing how the current balance was calculated ; ( XXXX ) copies of all communications or credit reporting submissions made concerning this alleged account to any consumer reporting agency ; and ( XXXX ) written proof that Superlative RM or Absolute Resolutions XXXX XXXX had a permissible purpose under 15 U.S.C. 1681b of the Fair Credit Reporting Act ( FCRA ) to access or report my credit information, then their claim is legally invalid under 15 U.S.C. 1692g ( b ) of the Fair Debt Collection Practices Act, and all collection, communication, and reporting activity must immediately cease and desist. 


XXXX. Direct both entities to cease all collection, communication, and credit reporting regarding the alleged XXXX XXXX XXXX XXXX account until lawful validation is produced. 

XXXX. Order the deletion of any credit bureau entries, inquiries, or tradelines associated with this alleged account. 

XXXX. Compel both entities to acknowledge the privacy breach, notify the affected third party, and certify corrective action to the CFPB and California DFPI. 

XXXX. Refer this matter to the Federal Trade Commission ( FTC ), the California Department of Financial Protection and Innovation ( DFPI ), and other regulators for enforcement and potential penalties. 

XXXX. Ensure restitution and statutory damages under 15 U.S.C. 1681n, 1681o, and 1692k for willful and negligent noncompliance. 


Closing and Certification I reserve all rights and remedies available under federal and state law. 



XXXX XXXX XX/XX/year> XXXX

Company response to consumer: Closed with explanation