Consumer complaint received 2025-03-19 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: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: NV

Complaint narrative:
Dear CFPB Officer, I am filing this formal complaint against TransUnion LLC, a consumer reporting agency, for a series of unauthorized, deceptive, and fraudulent practices involving my private consumer credit data. These practices have resulted in significant violations of federal law and have caused harm not only to me but potentially to countless other consumers similarly situated.

Repeat Violations and Disregard for CFPB Orders TransUnion has demonstrated a consistent and willful disregard for the laws and regulations designed to protect consumers, including previous consent orders issued by the CFPB : In XXXX, the CFPB issued a consent order against TransUnion for deceptive marketing practices. 
In XXXX, TransUnion was again sanctioned by the CFPB for violating the terms of the XXXX consent order, resulting in additional fines and restitution requirements. 
Despite these actions, TransUnion continues to engage in unauthorized and deceptive practices, including the unauthorized use, monetization, and securitization of my consumer credit data without consent. 
This pattern of behavior demonstrates TransUnions flagrant disregard for regulatory enforcement and its continuing exploitation of consumer data for profit. 
VIOLATIONS OF FEDERAL LAWS AND REGULATIONS XXXX. Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq.

604 : No permissible purpose for accessing my data 607 : Failure to maintain compliance procedures 609 & 610 : Failure to disclose data use and monetization 615 : Adverse actions impacting my credit score without proper notification XXXX. Gramm-Leach-Bliley Act ( GLBA ), 15 U.S.C. 6801-6827 Privacy Rule : Failure to provide clear notice XXXX XXXX : Failure to protect my data XXXX. Truth in Lending Act ( TILA ), 15 U.S.C. 1601 et seq.

Failure to disclose the true creditor status and misuse of data in lending practices. 
XXXX. Uniform Commercial Code ( UCC ) Article XXXX : Unauthorized securitization and monetization of my personal data. 
XXXX. Securities Act of 1933 and Securities Exchange Act of 1934 Fraudulent omissions related to the securitization of consumer data in ABS. 
VIOLATIONS AND DAMAGES CLAIMED After an extensive review of my TransUnion consumer credit report and related data, I have identified XXXX distinct violations : Type of Violation Inaccurate Addresses Reported Unauthorized Hard Inquiries Unverified/Unauthorized Accounts Reported Unverified Collections Reported Inaccurate Payment Histories Reported Total Violations Count XXXX XXXX XXXX XXXX XXXX XXXX Damages Calculation : Pursuant to FCRA 15 U.S.C. 1681n, I am entitled to {$1000.00} per violation.

19 violations {$1000.00} = {$19000.00} in statutory damages. 
This figure does not yet include actual, punitive, or emotional distress damages, which I reserve the right to pursue. 
SPECIFIC COMPLAINT DETAILS XXXX. Unauthorized Use and Monetization of My Data XXXX. Fraudulent Receivables Reporting and Accounting XXXX. Securitization of My Data Without Disclosure XXXX. Harm to My Credit Profile and Financial Despite having no lawful authorization, TransUnion has engaged in the unauthorized access, use, sale, and monetization of my personal credit data, all in direct violation of federal statutes and regulations, including : - VIOLATIONS OF FEDERAL LAWS, STATUTES, AND REGULATIONS XXXX. Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq.

- Section 604 [ 15 U.S.C. 1681b ] - Permissible Purposes of Consumer Reports - TransUnion has accessed and used my consumer credit data without any documented permissible purpose under this section.

- Section 607 [ 15 U.S.C. 1681e ] - Compliance Procedures - They failed to maintain reasonable procedures to ensure that my data is used only for lawful purposes.

- Section 609 [ 15 U.S.C. 1681g ] - Disclosures to Consumers - They have refused to provide a complete disclosure of how my credit data has been used, shared, or monetized.

- Section 610 [ 15 U.S.C. 1681h ] - Conditions and Form of Disclosure - Disclosures were not provided in a clear and accurate manner, nor have they disclosed the details of transactions involving my data.

- Section 615 [ 15 U.S.C. 1681m ] - Adverse Actions - Their actions have directly or indirectly resulted in adverse effects on my credit score, with no proper notification.

2. Gramm-Leach-Bliley Act ( GLBA ), 15 U.S.C. 6801-6827 - Privacy Rule ( 16 C.F.R. Part 313 ) - TransUnion failed to provide clear and conspicuous notice of their information-sharing practices as required under GLBA.

- Safeguards Rule - They failed to implement adequate measures to protect my data from unauthorized access and misuse.

3. Truth in Lending Act ( TILA ), 15 U.S.C. 1601 et seq.

- By failing to disclose the true creditor status and monetization of my data for underwriting purposes, TransUnion has contributed to deceptive lending practices violating TILA 's transparency requirements.

4. Uniform Commercial Code ( UCC ) - Article 9 - Secured Transactions - My personal credit data has been used as an asset for securitization and monetization without my consent.

- TransUnion acted as a secured party, profiting from my data without lawful contract or security agreement.

5. Securities Act of 1933 and Securities Exchange Act of 1934 - Fraudulent representations and omissions regarding the securitization of consumer data, contributing to deceptive practices in securities offerings where my data was part of asset-backed securities ( ABS ).

- SPECIFIC COMPLAINT DETAILS 1. Unauthorized Use and Monetization of My Data - TransUnion has accessed, shared, and sold my credit data without any express consent or lawful permissible purpose. 
- I have never signed a wet-ink contract granting TransUnion authority XXXX use my data for monetization, securitization, or receivables reporting. 
XXXX. Fraudulent Receivables Reporting and Accounting - TransUnions receivables and accounts are derived from transactions involving unauthorized use of my personal data, in direct violation of GAAP and securities laws. 
- Their XXXX XXXX filing fails to disclose these practices in full transparency, concealing material facts from consumers and regulators. 
XXXX. Securitization of My Data Without Disclosure - My credit data has been improperly included in securitization processes, with no disclosure of the financial instruments, trusts, or CUSIP numbers involved. 
- TransUnion has failed to notify or obtain consent for including consumer data in asset-backed securities ( ABS ) or other financial vehicles. 
XXXX. Consumer Harm and Credit Profile Damage - As a direct result of these practices, my credit score has been adversely affected. 
- TransUnion has failed to correct inaccuracies or restore my score, despite multiple attempts to resolve these matters directly.

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 explanation