Consumer complaint received 2025-11-30 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: GA

Complaint narrative:
Beginning in XXXX and continuing through XXXX, I discovered several inaccurate and unverifiable collection tradelines appearing on my credit reports. These accounts were furnished by XXXX XXXX XXXX, XXXX XXXX XXXX XXXX, and XXXX XXXX XXXX XXXX. 

In XXXX, I briefly filed a bankruptcy case, which I voluntarily dismissed soon after. No discharge was issued, and no debts were wiped out. Since that time, multiple collection agencies have reported accounts in a way that appears to stem from incorrect, incomplete, or outdated bankruptcy-related information. Several tradelines appear to incorporate false dates, incorrect charge-off timelines, and re-aged information, inconsistent with what occurred before or after the XXXX dismissal. 

Between XXXX and XXXX, I disputed these accounts multiple times with all three credit bureaus and also filed disputes and complaints through the CFPB. Despite repeated disputes, the accounts continued to be verified without documentation. 

Two furnishers involvedXXXX XXXX XXXX and XXXX XXXX XXXX XXXXare not registered to conduct business in the State of XXXX, as required by XXXX. XXXX and XXXX. Because they are not registered, they can not legally collect debts in XXXX  and can not legally furnish or verify credit information. Despite this, the credit bureaus continue publishing and verifying their data. 

Multiple tradelines were also re-aged, meaning that the Date of First Delinquency ( DOFD ) was shifted to a newer date, which is prohibited under FCRA 1681c ( a ) ( 4 ). One XXXX  tradeline, for example, appears to have been re-aged by approximately XXXX years. Charge-off dates, payment histories, and last payment fields were all inconsistent between credit bureaus. 

I identified additional Metro-2 violations, including : Missing dispute code XB Wrong account type ( coded as Revolving instead of Debt Buyer ) False balance reporting False last payment dates Incorrect status byte ( XXXX charge-off ) Missing furnisher contact block Inconsistent reporting between TransUnion, XXXX XXXX XXXX My personal identifying information was also compromised in the Change Healthcare data breach , affecting health and insurance records. Due to this, I requested heightened verification before any negative item was verified. The credit bureaus did not implement enhanced verification procedures, despite documented identity compromise. 

I repeatedly requested documentation from the credit bureaus and furnishers, including original account agreements, billing histories, charge-off records, assignment documents, and chain-of-title. None of this documentation has been produced by any furnisher. 

Despite the lack of documentation, and despite the involvement of unregistered furnishers, the credit bureaus repeatedly marked items as verified as accurate. This contradicts XXXX XXXX XXXX XXXX requiring furnishers and CRAs to actually review underlying documentation : XXXX XXXX XXXX Funding, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) A furnisher can not verify a debt without possessing supporting records. 
XXXX v. XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) Re-reporting inaccurate information constitutes willful FCRA violation. 
XXXX v. XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) Furnishers must do more than rely on automated e-Oscar responses. 
XXXX v. XXXX XXXX XXXX Vacations, XXXX XXXX XXXX ( XXXX Cir. XXXX ) CRAs must conduct meaningful investigations, not rubber-stamp verifications. 
XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. ) Unverifiable information must be deleted. 
XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) Reckless disregard equals willful violation. 

TransUnion and the furnishers verified data without reviewing documentation, without correcting re-aged DOFD fields, and without fixing multiple Metro-2 errors. They also accepted data from two companiesXXXX XXXX XXXX and XXXX XXXX XXXX XXXXXXXX are not authorized to do business in Georgia, which makes their ACDV verifications invalid. 

I am requesting a full correction and reinvestigation under all applicable FCRA provisions. 


I am requesting : 1. A complete reinvestigation of the disputed tradelines consistent with FCRA 1681i. 
2. Deletion of any tradeline that is inaccurate, incomplete, unverifiable, re-aged, or furnished by a company that is not registered to conduct business in Georgia.

3. Written documentation used to verify each account, including : original creditor agreements charge-off statements payment history assignment/chain-of-title DOFD source documents 4. Application of the correct Metro-2 dispute code XB and compliance codes. 
5. Block and removal of any information related to identity compromise in accordance with FCRA 1681c-2. 
6. Correction of any DOFD, charge-off date, status, or payment history that is inaccurate or inconsistent with the original creditors records.

7. Permanent deletion of any information that can not be fully validated under XXXX v. XXXX, XXXX XXXX XXXX, and FCRA XXXX ( a ) ( XXXX ) ( A ). 
8. Notification to all third parties who received inaccurate information within the last six months. 

If the credit bureaus or furnishers can not verify the accuracy of the information or can not provide documentation, the items should be deleted immediately. 



Please include : This complaint is submitted with notice that I am preparing a federal lawsuit for violations of FCRA 1681e ( b ), 1681i, 1681s-2 ( b ), FDCPA 1692e ( 8 ), and Georgia FBPA 10-1-393, based on continued re-aging, use of unverifiable information, and ACDV verifications from unregistered furnishers. This CFPB submission will be included in my court filings. 





IN THE UNITED STATES XXXX XXXX FOR THE XXXX XXXX XXXX XXXX  XXXX DIVISION * * XXXX XXXX XXXX, Plaintiff, v. 

TRANSUNION LLC, XXXX XXXX, XXXX, XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX, Defendants. 

XXXX XXXX XXXX. __________________ COMPLAINT FOR VIOLATIONS OF THE FAIR CREDIT REPORTING ACT ( FCRA ), THE FAIR DEBT COLLECTION PRACTICES ACT ( FDCPA ), AND GEORGIA XXXX XXXX PRACTICES ACT ( FBPA ) WITH JURY DEMAND * * Plaintiff XXXX XXXX XXXX ( Plaintiff ), appearing pro XXXX, files this Complaint against TransUnion LLC ( TransUnion ), XXXX XXXX XXXX ( XXXX ), XXXX XXXX XXXX XXXX ( XXXX ), and XXXX XXXX XXXX XXXX ( XXXX XXXX ), and shows the Court as follows : I. PARTIES XXXX. XXXX XXXX XXXX XXXX is a natural person and consumer residing in XXXX XXXX, XXXX. 
2. Defendant TransUnion LLC is a consumer reporting agency ( CRA ) under 15 U.S.C. 1681a ( f ). 
3. Defendant XXXX XXXX XXXX is a debt buyer, debt collector, and furnisher of information to CRAs. 
XXXX XXXX XXXX is NOT registered to do business in the State of Georgia under XXXX. XXXX. 
XXXX. XXXX XXXX XXXX XXXX XXXX is a debt collector and furnisher of information. 
XXXX XXXX XXXX XXXX is NOT registered to do business in the State of XXXX  under XXXX. XXXX. 
XXXX. Defendant XXXX XXXX XXXX XXXX XXXX is a debt collector and furnisher of information. 
XXXX XXXX is registered to conduct business in Georgia, but is reporting inaccurate and inconsistent information.

II. JURISDICTION & VENUE 6. This action arises under the Fair Credit Reporting Act, 15 U.S.C. 1681 et seq., and the Fair Debt Collection Practices Act, 15 U.S.C. 1692 et seq.

7. Federal question jurisdiction exists under 28 U.S.C. 1331.

8. Venue is proper in this District because Plaintiff resides here and the acts giving rise to this complaint occurred here. 



III. FACTUAL ALLEGATIONS A. Identity Compromise & Change Healthcare Data Breach 9. Plaintiffs sensitive personal information was compromised through the Change Healthcare data breach, including SSN, DOB, billing details, and other identifying data.

10. Plaintiff notified TransUnion and the furnishers of identity compromise and requested heightened validation. 
11. Defendants ignored this requirement and continued to furnish, report, and verify unvalidated information. 



B. Disputed Tradelines Plaintiff disputed the following derogatory tradelines : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Accounts ( indirect furnishers ) Disputes were filed through TransUnion, CFPB, and other CRAs. 



XXXX XXXX XXXX & XXXX XXXX Are NOT Registered in XXXX  XXXX. Under XXXX. XXXX, foreign LLCs must register to transact business in XXXX. 
XXXX. XXXX XXXX XXXX is not registered in XXXX. 
XXXX. XXXX XXXX XXXX XXXX is not registered in XXXX. 
XXXX. Because they are unregistered, XXXX and XXXX : can not legally collect debts in Georgia can not legally verify accounts to TransUnion can not legally furnish derogatory credit information can not legally transact business with XXXX  consumers 16. Any reporting, collection, or verification activity they performed is unauthorized, deceptive, and invalid.

17. TransUnions reliance on verification from unregistered furnishers is a per XXXX violation of FCRA 1681e ( b ) and 1681i. 



D. Metro-2 Violations ( Updated ) 18. TransUnion continues to publish data with major Metro-2 formatting errors, including but not limited to : XXXX XXXX LLC DOFD falsely reported as XXXX ( correct DOFD approx. XXXX ) Re-aging by XXXX years ( illegal under 1681c ( a ) ( 4 ) ) Status Byte 25 incorrectly reported as XXXX Charge-Off Account Type incorrectly coded as Revolving ( should be Debt Buyer ) Missing XB dispute code False Last Payment Date False High Balance Missing furnisher contact block Portfolio Recovery Associates Missing dispute XXXX XXXX XXXX XXXX bureaus No validation or documentation Unregistered furnisher invalid verification XXXX XXXX Systems ( Registered XXXX but inaccurate ) Inconsistent dates Incorrect status codes Missing dispute notation Incorrect balance & payment rating Inaccurate collection/charge-off designation E. TransUnion Failed to Conduct a Reasonable Reinvestigation XXXX XXXX Plaintiff filed multiple disputes ( first dispute around XXXX, continuing into XXXX ). 
XXXX. TransUnion : Did not obtain validation Did not obtain chain-of-title Did not obtain DOFD source documentation Relied on automated e-Oscar responses Relied on unregistered furnishers Verified information no furnisher could prove XXXX. This violates FCRA 1681e ( b ), 1681i, and 1681s-2 ( b ).

IV. CAUSES OF ACTION * * COUNT I FCRA 1681e ( b ) ( TransUnion Failure to Assure Maximum Possible Accuracy ) * * 22. TransUnion published inaccurate, incomplete, and re-aged information.

23. TransUnion accepted and verified information from unregistered furnishers ( XXXX & XXXX ). 
24. This failure to implement reasonable procedures violates 1681e ( b ).

COUNT II FCRA 1681i ( TransUnion Failure to Conduct a Reasonable Reinvestigation ) * * 25. Plaintiff disputed multiple tradelines.

26. TransUnion did not conduct a reasonable reinvestigation.

27. TransUnion failed to delete unverifiable information ( required under 1681i ( a ) ( 5 ) ( A ) ).

28. Violations include : Reliance on unregistered furnishers Verification without documentation Failure to correct Metro-2 errors Failure to review DOFD Failure to address identity-theft evidence COUNT III FCRA 1681s-2 ( b ) ( Furnishers Failure to Properly Investigate Disputes ) * * 29. XXXX, XXXX, and XXXX XXXX received disputes through XXXX XXXXhannels. 
XXXX. They each : Failed to investigate Failed to validate Verified without documents Re-aged accounts Failed to correct errors Failed to mark accounts as disputed 31. This violates 1681s-2 ( b ) ( 1 ) ( A ) - ( D ).

COUNT IV FDCPA Violations ( XXXX & XXXX ) ( Only applies to unregistered debt XXXX ) XXXX. XXXX and XXXX are debt collectors under the FDCPA. 
33. They violated : 1692e ( 2 ) ( A ) false representation of debt 1692e ( 5 ) attempting to collect without legal authority 1692e ( 8 ) failure to report account as disputed 1692f unfair/illegal collection while unregistered COUNT V XXXX  FBPA ( O.C.G.A. 10-1-393 ) 34. XXXX and XXXX engaged in deceptive and unfair business practices by : Operating in XXXX without registration Furnishing unverifiable data Verifying data in XXXX disputes Misrepresenting legal standing Participating in illegal credit reporting activity V. DAMAGES Plaintiff seeks : Actual damages Statutory damages Punitive damages ( willful violations under 1681n ) Costs & attorneys fees Declaratory & injunctive relief VI. JURY DEMAND Plaintiff demands trial by jury on all issues so triable. 



PRAYER FOR RELIEF Plaintiff respectfully requests : 1. Judgment in his favor ; 2. Deletion of all inaccurate/unverified tradelines ; 3. Statutory, actual, and punitive damages ; 4. Attorneys fees ; 5. Any further relief deemed just and proper. 



Respectfully submitted, XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXXXXXX XXXX, XXXX  XXXX XXXX XXXX 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 non-monetary relief