Consumer complaint received 2025-10-23 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Improper use of your report — Reporting company used your report improperly
Company: CITIBANK, N.A.
State: NJ

Complaint narrative:
I request the CFPB investigate Citi Cards / Citibank ( the Furnisher ) and the nationwide consumer reporting agencies for systemic violations involving the reporting and verification of a charged-off Citi account in my consumer file ( Acct : XXXX ). I allege the Furnisher and CRAs relied on derivative materials ( account statements, screenshots, payment-history images, and truncated reproductions ) rather than primary-source native records with chain-of-custody to verify and re-insert late-payment / charge-off information. CFPB guidance and 12 C.F.R. 1000.6.34 ( c ) require fair, transparent, auditable handling of consumer financial data ; these practices were not followed. I ask CFPB to issue investigative subpoenas/ Civil Investigative Demands ( CID ) to Citi and the relevant CRAs, require full production, and order deletion if primary evidence can not be produced. 

Legal basis ( key statutes & regs ) FCRA : 15 U.S.C. 1681i ( a ) ( reinvestigation ), 1681e ( b ) ( maximum possible accuracy ), 1681s-2 ( b ) ( furnisher duties ), 1681c-4, 1681c-3, 1681h.

CFPA Implementation/ CFPB Regulations : 12 C.F.R. Part 1000, especially 1000.6.34 ( c ) ( fair, transparent handling of consumer financial data ). 

Regulation F / CFPB operational guidance on XXXX  / XXXX and primary-source evidence standards. 

Remedies : 15 U.S.C. 1681n & 1681o ( willful / negligent violations ). 

III. Facts ( brief ) Account : Citi Cards / Citibank Acct ending XXXX reported charge-off / late payments ( dates and history as on XXXX  listing ). 

I timely disputed with XXXX  and the other major CRAs ; CRA responses indicate completed investigationconsumer disagrees. 

The furnishers verification responses cited account statements, screenshots, and payment history summaries without producing native transactional exports or original signed application / contract. 

I request CFPB investigate whether Citi and the CRAs violated FCRA and 12 C.F.R. 1000.6.34 ( c ) by validating reporting with derivative, non-native, or non-authenticated records. 

Specific documentary & audit evidence requested ( produce in native format OR certified custodial copies ) I ask CFPB to issue a XXXX  / supervisory demand requiring Citi ( and any agents/servicers ) to produce the following within FIFTEEN ( 15 ) CALENDAR DAYS of CFPB demand ( or within 15 days of any XXXX issued by CFPB ) : Primary-Source Identity & Origination Original signed credit application and cardmember agreement ( native XXXX  with embedded signature image OR certified original paper copy ). Include all metadata ( IP address, device ID, timestamp ) if electronic. 

Original promissory note or credit contract, assignments, and any subsequent sale/transfer instruments ( native format ). 

Full Transactional & Posting Records ( native ) Complete native transaction export ( XXXX ) for the account showing every posting, charge, payment, adjustment, return, fee, reversal, and balance calculation from origination to present, with system transaction IDs and timestamps. 

Payment processing receipts/ ACH trace records corresponding to alleged payment dates. 

Charge-off & Accounting Worksheets All charge-off memos, final charge-off worksheets, GAAP accounting entries, and internal XXXX or notes used to calculate the charge-off amount and the effective date posted. 

D. Dispute & XXXX  / XXXX Records All XXXX  / XXXX tickets, XXXX  payloads, attachments, and message logs transmitted between Citi and each CRA. Include request payloads, response payloads, and system receipt timestamps. 

API call logs and dispatch / delivery receipts showing when Citi received dispute data and when it returned verification responses. 

Employee & QA Verification Records For every Citi employee who accessed, reviewed, validated, approved, or signed off on the disputed verification or charge-off : full name, employee ID, job title/department, business email/phone, and exact date/time ( timezone ) of action. Produce contemporaneous verification checklists, sign-off forms, or QA records used in the review. 

Names/IDs of any third-party vendors, collection agents, or servicers who participated in the verification ; provide same metadata. 

System & Audit Trails Complete system audit logs ( native export ) showing chain-of-custody for records used in the verification, including backups and snapshots, with checksums or file hashes to confirm integrity.

G. Custodian Declaration Signed sworn custodial declaration from Citis records custodian attesting to authenticity, source system, and that records were maintained in the ordinary course of business and not created or altered for this dispute. 

Confirmation of Evidence Use Policy Written confirmation whether Citi relied solely on account statements, screenshots, payment-history images or derivative reproductions in the verification ; if so, explain with detail and authorizing personnel. 

V. Requested CFPB enforcement actions I respectfully request CFPB Enforcement to take the following actions if initial review indicates non-compliance : Issue Civil Investigative Demands ( CID ) to Citi and relevant CRAs for the records above. 

Issue supervisory orders requiring deletion of any charge-off / late-payment reporting that can not be verified with primary-source records. 

Seek appropriate remedial or punitive administrative action or consent order where systemic practices are found to rely on derivative evidence in contravention of 12 C.F.R. 1000.6.34 ( c ) and FCRA.

Require remediation notices to consumers and notification to downstream resellers/subscribers of any deletions.

Citi ( and any agents/servicers ) to produce the following within FIFTEEN ( 15 ) CALENDAR DAYS of CFPB demand ( or within 15 days of any CID issued by CFPB ) : Primary-Source Identity & Origination

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