Consumer complaint received 2025-06-04 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Information belongs to someone else
Company: Source Receivables Management LLC
State: AL

Complaint narrative:
IN THE CIRCUIT COURT OF XXXX XXXX STATE OF ALABAMA XXXXXXXX XXXX XXXX XXXX 



Source Receivables Management , LLC, Defendant. 



XXXX XXXX. XXXX COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF BASED ON FRAUD, FCRA, FDCPA, IDENTITY THEFT, AND EMOTIONAL DISTRESS COMES NOW the Plaintiff, XXXX XXXX XXXX and for his cause of action against the Defendant, Source Receivables Management , LLC , states as follows : 1. Plaintiff, XXXX XXXX, is a natural person and resident of XXXX, Alabama, residing at XXXX XXXX XXXX XXXX, XXXX, AL. 

2. Defendant, Source Receivables Management , LLC ( SRM ), is a debt collection agency headquartered in XXXX, North Carolina, and conducts business nationwide, including in the State of Alabama. 

3. On or about XX/XX/XXXX, Source Receivables Management placed a fraudulent collection account in the amount of {$280.00} on Plaintiffs XXXX  and XXXX  credit report allegedly tied to an account with XXXX XXXX XXXX XXXX XXXX 

4. Plaintiff is a verified victim of identity theft and has provided an official Identity Theft Affidavit filed with the Federal Trade Commission ( FTC ) pursuant to 15 U.S.C. 1681g and 1681s-2 ( a ) ( 6 ).

5. At no time did Plaintiff open, authorize, or consent to any account or service with XXXX XXXX XXXX XXXX XXXX and any such activity was done without Plaintiffs knowledge or permission. 

6. Despite receiving notification of identity theft, SRM has failed to investigate, validate, or remove said fraudulent account from Plaintiffs credit report. 



COUNT I VIOLATION OF THE FAIR CREDIT REPORTING ACT ( FCRA ) 15 U.S.C. 1681 et seq.

7. Defendant violated FCRA 1681s-2 ( b ) by failing to conduct a reasonable investigation after receiving notice of dispute and identity theft.

8. Defendant willfully and negligently continued to report inaccurate information to XXXX  despite Plaintiffs direct dispute and FTC filing.

COUNT II VIOLATION OF THE FAIR DEBT COLLECTION PRACTICES ACT ( FDCPA ) 15 U.S.C. 1692 et seq.

9. Defendant violated FDCPA 1692e ( 8 ) by communicating false and misleading credit information.

10. Defendant failed to validate the alleged debt as required under 1692g ( b ) after receiving proper notification.

COUNT III IDENTITY THEFT UNDER FEDERAL AND STATE LAW 11. Defendant knowingly continued to report a fraudulent debt despite having received FTC Identity Theft Affidavit and relevant documentation.

COUNT IV NEGLIGENCE AND EMOTIONAL DISTRESS 12. Defendants reckless actions have caused Plaintiff substantial harm including XXXX, emotional distress, credit denials, and financial hardship. 



CASE LAW IN SUPPORT : - XXXX XXXX XXXX XXXX XXXX  XXXX ( XXXX XXXX. XXXX ) : Failure to conduct reasonable investigation = willful FCRA violation. 

XXXX XXXX XXXX XXXX, XXXX, XXXX XXXX XXXX ( XXXXXXXX XXXX XXXXXXXX ) : Debt collector liable for false reporting and failure to verify. 

- XXXXXXXX XXXX XXXX XXXXXXXX : Punitive damages awarded for failure to remove disputed data. 



WHEREFORE, Plaintiff respectfully demands judgment against Defendant as follows : a. For compensatory and actual damages in excess of {$25000.00} ; b. For statutory damages under FCRA and FDCPA ; c. For punitive damages for willful noncompliance ; d. For an immediate injunction ordering deletion of all references to account # XXXX from all consumer reporting agencies ; e. For attorneys fees and costs of this action ; f. For such other and further relief as the Court deems just and proper.

Company response to consumer: Closed with explanation