Consumer complaint received 2025-04-21 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:
1. Plaintiff brings this action under the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681etseq., to remedy Experians and TransUnions repeated and willful violations of federal law. Defendants have : a.Disclosed Plaintiffs personal credit information without any permissible purpose or Plaintiffs explicit authorization, in violation of 15U.S.C. 1681b ; b.Failed to maintain reasonable procedures to assure maximum possible accuracy of Plaintiffs file, in violation of 15U.S.C. 1681e ( b ) ; c.Willfully refused to conduct meaningful reinvestigations of Plaintiffs disputes, in violation of 15U.S.C. 1681i ; d.Willfully withheld or misrepresented evidence in response to Plaintiffs CFPB complaints and direct requests for clarification and arbitration ; and e.Refused to remove demonstrably inaccurate tradelines despite clear proof, thereby causing Plaintiff substantial financial injury.

II. JURISDICTION AND VENUE 2. This Agency and applicable Courts has subjectmatter jurisdiction under 28U.S.C. 1331 ( federal question ) because Plaintiffs claims arise under the FCRA, 15U.S.C. 1681etseq.

3. Venue is proper in this District under 28U.S.C. 1391 ( b ) because Defendants regularly transact business and maintain offices in this District, and because a substantial part of the events giving rise to this claim occurred here.

III. THE PARTIES 4. Plaintiff, [ Your Name ], is a natural person and resident of [ City, State ].

5. Experian Information Solutions , Inc. ( Experian ) is a Delaware corporation with its principal place of business in XXXX XXXX, California, and regularly engages in consumer credit reporting nationwide. 
6. TransUnion LLC ( TransUnion ) is a Delaware limited liability company with its principal place of business in XXXX, Illinois, and regularly engages in consumer credit reporting nationwide. 



IV. FACTUAL ALLEGATIONS 7. At all relevant times, Plaintiff has been a consumer as defined in 15U.S.C. 1681a ( c ). 
8. Experian and TransUnion are each a consumer reporting agency ( CRA ) under 15U.S.C. 1681a ( f ).

9. Plaintiffs credit history has been reported by both CRAs inaccurately and disclosed to third parties without any statutorily permissible purpose.

10. On multiple occasions, Plaintiff filed disputes directly with the CRAs and also lodged formal complaints with the Consumer Financial Protection Bureau ( CFPB ), demanding complete files and documentation regarding items Plaintiff believed to be erroneous. 
11. Plaintiff additionally submitted multiple written requests for clarification and arbitrationfirst via the CFPBs online dispute resolution platform, and thereafter by certified mail through the United States Postal Serviceto both Experian and TransUnion, explicitly invoking his right to mandatory arbitration under the FCRA and seeking detailed explanations of each reported tradeline. Defendants completely and utterly ignored these arbitration and clarification requests, refusing to acknowledge receipt or to initiate any arbitration or meaningful dialogue.

12. Despite indisputable evidence ( bank statements, letters from original creditors, court dispositions ), Defendants refused to delete or correct false tradelines, denying removal requests outright or conducting sham investigations that never contacted original furnishers.

13. Further, Defendants repeatedly opened unauthorized inquiries and disputes on Plaintiffs reportactions taken in Plaintiffs name but without Plaintiffs knowledge or consentexacerbating the inaccuracies.

14. Defendants conduct has materially harmed Plaintiffs creditworthiness, costing Plaintiff lost credit opportunities, higher interest rates, emotional distress, and other damages.

V. CLAIMS FOR RELIEF Count I Violation of 15U.S.C. 1681b ( b ) ( Impermissible Disclosure ) 15. Plaintiff realleges paragraphs 114.

16. Under 1681b ( b ), a CRA may furnish a consumer report only for a statutorily enumerated permissible purpose. 
17. Defendants disclosed Plaintiffs credit information to third parties on several occasions without any permissible purpose or written authorization from Plaintiff.

18. As a direct and proximate result, Plaintiff has suffered actual damages.

Count II Violation of 15U.S.C. 1681e ( b ) ( Failure to Maintain Reasonable Procedures ) 19. Plaintiff realleges paragraphs 118.

20. Section 1681e ( b ) requires a CRA to follow reasonable procedures to assure maximum possible accuracy in preparing consumer reports.

21. Defendants lacked any meaningful procedures to verify disputed items, instead rubberstamping furnishers responses or ignoring objective evidence.

22. Defendants failure caused repeated misreports and unauthorized data entries.

Count III Violation of 15U.S.C. 1681i ( a ) ( Failure to Reinvestigate Disputes ) 23. Plaintiff realleges paragraphs 122.

24. Under 1681i ( a ), upon notice of a dispute by a consumer, a CRA must conduct a reasonable reinvestigation within 30 days.

25. Defendants failed to investigate in good faithdid not contact original furnishers or review evidenceand thus perpetuated false reporting.

Count IV Willful NonCompliance under 15U.S.C. 1681n 26. Plaintiff realleges paragraphs 125.

27. Defendants conduct was willful : they had actual notice of FCRA requirements, knowing of prior lawsuits, CFPB actions, and direct arbitration demands, yet continued noncompliance. 



VI. PRAYER FOR RELIEF WHEREFORE, Plaintiff respectfully requests this Agency to grant the following relief : a.Statutory damages under 15U.S.C. 1681n ; b.Actual damages, including emotional distress and lost credit opportunities ; c.Punitive damages for willful violations ; d.Preliminary and permanent injunctive relief requiring Defendants to : i.Adopt and implement procedures that comply with 1681e ( b ) and 1681i ( a ) ; ii.Permanently delete all unauthorized inquiries, disputes, and inaccurate tradelines in Plaintiffs file ; iii.Acknowledge and promptly respond to any future requests for clarification or arbitration, including those sent via CFPB and U.S. Mail ; iv.Provide Plaintiff with a certified copy of his corrected credit reports ; e.Reasonable attorneys fees and costs under 15U.S.C. 1681n ( c ) ; f.Any other relief the Court deems just and proper. 



VII. JURY DEMAND Plaintiff demands a trial by jury on all issues so triable. 

Dated : XXXX Respectfully submitted, /s/ [ XXXX A XXXX ] [ XXXX XXXX XXXX XXXX XXXX XXXX XXXX ] [ XXXX, Ga XXXX XXXX ] [ XXXX ] [ XXXX ] Statutory References 15U.S.C. 1681b ( Permissible purposes of consumer reports ) 15U.S.C. 1681e ( b ) ( Maximum possible accuracy ) 15U.S.C. 1681i ( a ) ( Reinvestigation of consumer disputes ) 15U.S.C. 1681n ( Civil liability for willful noncompliance )

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