Consumer complaint received 2025-04-22 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: EQUIFAX, INC.
State: FL

Complaint narrative:
UNITED STATES DISTRICT COURT NOTICE OF PRE-LITIGATION & FORMAL LEGAL DEMAND From : XXXX XXXX. XXXX Address : XXXX XXXX XXXX XXXX XXXX XXXXXXXX, FL XXXX To : Experian Information Solutions , Inc. XXXX XXXX XXXX XXXXXXXX, TX XXXX To : Equifax XXXX XXXX XXXX XXXX. XXXX XXXX, XXXX, GA XXXX Date : XX/XX/XXXX RE : Formal Legal Complaint Criminal, Civil, and Regulatory Violations | FCRA, FTC Act, and Federal Criminal Code Violations | Pre-Litigation Cease and Desist & Final Demand for Immediate Action To Whom It May Concern, This notice is submitted under federal legal authority and constitutes a formal pre-litigation complaint for extensive and ongoing violations by Experian and Equifax. This complaint is being submitted in advance of the filing of a federal lawsuit in the XXXX XXXX XXXX Florida. All conduct described below will be presented before the court in a full verified complaint seeking monetary and injunctive relief. 



SUMMARY OF LEGAL VIOLATIONS Both Equifax and Experian have knowingly and willfully engaged in the following : 1. Sham Investigations : Disputes have been closed within 14 days with no evidence of actual reinvestigation. Confirmation screenshots attached show disputes closed within 2472 hours in blatant violation of FCRA 1681i ( a ) ( 1 ) ( A ) and 611 ( a ). These are not reasonable reinvestigations by any legal standard.

2. Failure to Remove Fraudulent Accounts : Despite repeated notices, both bureaus are knowingly reporting accounts that are unverifiable, rescinded, or already removed by the other major bureaus ( e.g., XXXX  ). XXXX XXXX XXXX XXXX account ending in XXXX, for example, is still being reported by Equifax, despite no signed loan, no valid debt, and removal by Experian and XXXX. 
XXXX. Misrepresentation of Debt Type : Equifax falsely lists the XXXX XXXX XXXX XXXX account as an auto loan, when it was in fact a retail installment contract between buyer and seller. This constitutes consumer deception and creates false impressions of installment lending that never occurred. 
XXXX. Contradictory Reporting Between Bureaus : Experian and Equifax are reporting accounts as delinquent that are listed as current or deleted by XXXX. This violates FCRA 1681e ( b ) and 1681s-2 ( a ) ( 3 ), which require accuracy and consistency. 
XXXX. False Certification of Dispute Verifications : Experians response falsely states that XXXX  XXXX, XXXX, and XXXX XXXX accounts were verified, when no such contracts or documentation were provided. These verifications are pure fiction and violate FCRA 1681i ( a ) ( 6 ) and FTC Act 5 ( 15 U.S.C. 45 ).

6. Failure to Notify of Negative Reporting : Both agencies failed to provide the legally mandated 30-day notice under FCRA 623 ( a ) ( 7 ) before reporting adverse information, depriving the consumer of a chance to dispute. 
XXXX. Furnishing Without Permissible Purpose : The accounts reported do not meet the standards for a permissible purpose under FCRA 604 ( a ). No signed agreement, no valid extension of credit, and no verification = no authority to report. 
XXXX. Criminal Misconduct Collusion and Fraud : The continued publication of false accounts appears to be influenced by undisclosed commercial arrangements between the CRAs and furnishers such as XXXX and XXXX XXXX. This collusion may amount to : 1. Wire Fraud 18 U.S.C. 1343 Statute Summary : Whoever, having devised a scheme to defraud, transmits or causes to be transmitted any writings, signs, signals, or sounds by wire ( telephone, internet, etc. ) in furtherance of the scheme, shall be fined or imprisoned up to 20 years. 

Application to Experian/Equifax and Furnishers : Credit bureaus transmit consumer data over interstate wires to banks, lenders, and employers. 
When that data includes false delinquencies, unverifiable tradelines, or disputed accounts verified without documentation, that becomes a scheme to defraud the consumer and third parties. 
XXXX, XXXX, and others benefit financially from this scheme when they maintain derogatory accounts to pressure payments, reduce credit limits, or block access to loans. 

Key Point : Furnishing knowingly inaccurate data and transmitting it across state lines is textbook wire fraud, especially when tied to financial injury or gain. 



XXXX. Conspiracy to Defraud 18 U.S.C. 371 Statute Summary : If two or more persons conspire either to commit an offense against the United States or to defraud the United States ( including its agencies like XXXX XXXX XXXX and take any act to effect the object of the conspiracy, each shall be fined and/or imprisoned. 

Application to CRA/Furnisher Misconduct : Experian and Equifax have ongoing, revenue-based relationships with furnishers like XXXX, XXXX, XXXX, where accuracy is ignored in favor of retention of derogatory tradelines. 
When the CRA verifies without requesting contracts or actual documentation, and furnishers certify accuracy knowing the account is fraudulent or disputed, that is a joint action to defraud regulatory protections. 
Together, they obstruct the FCRA dispute system, which is federal in nature that triggers a conspiracy to defraud the United States. 

Key Point : Their coordinated suppression of disputes and refusal to comply with 15 U.S.C. 1681i and 1681s-2 evidences a joint scheme to undermine federal law.

3. False Statements 18 U.S.C. 1001 Statute Summary : It is a federal offense to knowingly and willfully : falsify or conceal a material fact ; make any materially false, fictitious, or fraudulent statement or representation ; or make or use any false writing or document knowing it contains materially false information, in any matter within the jurisdiction of the United States government.

Application to Credit Reporting Entities : CRAs routinely issue dispute investigation results claiming verified as accurate, often without any supporting contract or documentation, and furnishers submit verification statements. 
These dispute verifications are then reported to the CFPB when a consumer files a complaint meaning they fall under federal jurisdiction. 
Any falsification or misrepresentation in that process is a direct violation of 1001.

Key Point : When Experian or Equifax tells the CFPB the account is accurate, without verifying source contracts, they are committing a federal felony.

4. Extortionate Credit Practices 18 U.S.C. 894 Statute Summary : It is a crime to knowingly participate in the collection of an extension of credit by extortionate means meaning using threats, harm, or false information to coerce repayment.

Application to Credit Reports : Maintaining false, negative information to pressure a consumer into paying a disputed or fraudulent debt is an extortionate act especially if the consumer is denied housing, credit, or employment due to that false report. 
If furnishers and CRAs refuse to delete an unverifiable account, despite clear evidence of inaccuracy, and use that account to suppress or manipulate consumer behavior, theyre engaging in credit extortion. 

Key Point : This law applies when financial injury is used as coercion, even if no physical threat exists which is exactly what credit suppression does. 



Additional Supporting Points : CRAs are not exempt from criminal law. While their actions are typically regulated civilly by the CFPB, the intentional use of false data for financial gain is a criminal act if proven. 
You can cite the CFPBs own lawsuits ( e.g., CFPB v. Experian, XXXX ) where the Bureau accused Experian of deceptive practices and misleading consumers. 



If CRA agents are knowingly participating in the continued publication of fictitious data, for compensation or favor, this becomes a matter of federal criminal liability. Individuals within Experian and Equifax may be held personally accountable. 



UNAUTHORIZED ACCOUNTS STILL BEING REPORTED : XXXX  XXXX Auto Finance XXXX XXXX  XXXX XXXX XXXX XXXX  XXXX XXXX XXXX XXXX / XXXX XXXX XXXX  XXXX FTC Report and CFPB Evidence An FTC Report citing unfair and deceptive acts and business collusion has been filed. This evidence will be submitted with a supplemental complaint to the CFPB, FTC Bureau of Consumer Protection, and U.S. Attorneys Office if immediate remedy is not provided.

LEGAL DAMAGES DEMAND Pursuant to FCRA 1681n and 1681o, the following damages are currently claimed : $ XXXX in willful and actual damages, including : {$1000.00} per violation ( XXXX disputes total ) Emotional and reputational harm Out-of-pocket losses from credit denials Punitive damages under 1681n ( b ) Legal fees and pre-litigation costs FINAL DEMAND FOR RESOLUTION To avoid immediate federal court action, the following must be completed within 10 business days : 1. Permanent deletion of the above-listed accounts from Equifax and Experian credit files.

2. Written confirmation of all deletions and confirmation that these accounts will not be reinserted unless verified by original signed contracts.

3. Sworn statement from the head of dispute operations detailing steps taken to reinvestigate and delete the accounts.

4. Full compliance log showing timestamps, methods, and personnel involved in prior verifications.

5. Immediate cessation of all future reporting activity from these furnishers unless proper documentation is produced. 



NOTICE OF IMMINENT LITIGATION If no resolution is received by the deadline above, I will immediately file suit in the United States District Court for the XXXX XXXX of Florida, citing : FCRA 1681i Failure to Investigate FCRA 1681e ( b ) Inaccurate Reporting FCRA 623 ( a ) ( 7 ) No Notice FTC Act 45 Deceptive Acts 18 U.S.C. 1001 False Representations 18 U.S.C. 894 Extortionate Credit Practices This will include subpoenas for back-office dispute logs, employee records, and data-sharing contracts between CRAs and furnishers. Additional parties may be named. 



Respectfully submitted, XXXX XXXX. XXXX XXXXXXXX XXXX XXXX XXXX XXXX, FL XXXX Legal Action Pending Immediate Response Required

Company response to consumer: Closed with explanation