Consumer complaint received 2025-06-26 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: NJ

Complaint narrative:
2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 1 of 40 Page ID # :1 XXXX XXXX, Mass. Bar No. XXXX ( Application for Pro Hac Vice Admission Pending ) Email : XXXX CONSUMER FINANCIAL PROTECTION BUREAU XXXX XXXX XXXX, XXXX Washington , DC XXXX Phone : XXXX Fax : ( XXXX ) XXXX XXXX XXXX, Cal. Bar No. XXXX Email : XXXX CONSUMER FINANCIAL PROTECTION BUREAU XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX, CA XXXX Phone : ( XXXX ) XXXX Fax : ( XXXX ) XXXX Attorneys for Plaintiff Consumer Financial Protection Bureau UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) Case Number : XXXX COMPLAINT FOR INJUNCTIVE RELIEF, REDRESS, DISGORGEMENT, AND CIVIL MONEY PENALTIES ACTION SEEKING NATIONWIDE RELIEF INTRODUCTION 1. The Consumer Financial Protection Bureau ( Bureau ) brings this action against Experian Information Solutions , Inc. ( Experian or the Company ) under the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., and the Consumer Financial Protection Act of 2010 ( CFPA ), 12 U.S.C.

Consumer Financial Protection Bureau, Plaintiff, vs.

Experian Information Solutions , Inc., Defendant. 
COMPLAINT 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 2 of 40 Page ID # :2 5536 ( a ) ( 1 ) ( a ) ( b ), 5564, and 5565. This action alleges that Experian violated both Acts by failing to reasonably reinvestigate consumer disputes challenging the accuracy or completeness of information in consumer reports, including by failing to forward all relevant information to furnishers, failing to provide adequate or accurate notice to consumers of the outcome of their disputes, and failing to utilize reasonable procedures to ensure the accuracy and completeness of information in consumers files.

2. Experian is one of the largest consumer reporting agencies ( CRAs ) in the country. A primary aspect of its business is collecting and organizing data on most adult Americans to generate consumer reports, consumer file disclosures, and credit scores that reflect consumers credit activity and history. As Experian acknowledges, its consumer reporting services play an integral part in the financial lives of millions of people.

3. This is because Experian sells its consumer reports to creditors and businesses who are evaluating whether to offer a consumer various products, services, and opportunities, such as a loan, a job, or housing.

4. Information reflected in consumer reports is provided to CRAs by data furnishers, such as banks, credit card companies, or debt collectors, and other sources. Errors in consumer reports can be significant for consumers, resulting in the denial of credit, employment, or housing, or being offered less favorable credit terms.

5. Recognizing the serious consequences borne by consumers when their consumer reports contain inaccurate information, Congress enacted the FCRA in 1970 to, in part, [ e ] nsure that consumer reporting agencies [ like Experian ] COMPLAINT 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 3 of 40 Page ID # :3 exercise their grave responsibilities with fairness, impartiality and a respect for the consumers right to privacy. 15 U.S.C. 1681 ( a ) ( 1 ) - ( 4 ).

6. The FCRA demands that CRAs use reasonable procedures to assure maximum possible accuracy of information contained in consumer reports, 15 U.S.C. 1681e ( b ), and provides a mechanism for consumers to dispute any incomplete or inaccurate information in their report. 15 U.S.C. 1681i.

7. When a consumer disputes the accuracy or completeness of information in their consumer report, the FCRA requires Experian to conduct a reasonable reinvestigation of the disputed information and report the results of the reinvestigation to the consumer, all within certain timelines. 15 U.S.C.

1681i ( a ). At the conclusion of the reinvestigation, Experian must modify or delete any item of information found to be inaccurate or incomplete, or that it could not verify. 15 U.S.C. 1681i ( a ) ( 5 ). For any information deleted as a result of a dispute, the FCRA imposes specific obligations on Experian that must be satisfied before that information may be reinserted into a consumers file. 15 U.S.C. 1681i ( a ) ( 5 ) ( C ).

8. Despite its obligations under the FCRA, Experian fails consumers who dispute information in their consumer reports at every stage of the dispute process.

9. First, Experians faulty intake procedures fail to accurately convey all relevant information regarding the dispute to the original furnisher of the disputed information, and, at times, Experian simply fails to provide furnishers with consumer-submitted documentation that supports the dispute.

COMPLAINT 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 4 of 40 Page ID # :4 10. Second, Experian uncritically accepts the original furnishers response to the disputed information, even when that response was improbable or illogical on its face or when Experian has other information in its possession that alerts or should alert Experian to the possibility that the furnisher might be unreliable.

11. Third, at the conclusion of its reinvestigation, Experian sends consumers notices that fail to inform them of the reinvestigation results, and instead provides information that is confusing, ambiguous, incorrect, and internally inconsistent.

12. Additionally, Experians problematic dispute resolution processes have resulted in several other issues, including Experians outright failure to reinvestigate a significant number of disputes within the timeline required by the FCRA, its ongoing refusal to reinvestigate hard inquiry disputes, and its routine failure to ensure that previously deleted tradelines are not improperly reinserted into a consumers file.

13. Experians faulty dispute intake procedures and failure to provide furnishers with consumer-submitted documentation, uncritical deference to furnishers response to the disputed information, and failure to inform consumers of the results of reinvestigations also violate the CFPAs prohibition on unfair acts or practices. 12 U.S.C. 5531 ( c ) ( 1 ).

14. Experians failures are an abdication of its obligations under the FCRA and the CFPA, and the Bureau brings this action to rectify these failings and impose civil money penalties.

COMPLAINT 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 5 of 40 Page ID # :5 XXXX XXXX. XXXX  is proper in this district because the Defendant resides and does business in this district. 12 U.S.C. 5564 ( f ).

PARTIES 16. The Bureau is an independent agency of the United States created by the CFPA. 12 U.S.C. 5491 ( a ). The Bureau has independent litigating authority and is authorized to initiate civil actions in federal district court to secure appropriate relief for violations of Federal consumer financial law, 12 U.S.C.

5564 ( a ) - ( b ) and 5565, including the FCRA and the CFPA, 12 U.S.C.

5481 ( 12 ) ( F ) and ( 14 ).

17. Experian is a nationwide consumer reporting agency with its North American Headquarters in XXXX XXXX, California. At all times material to this Complaint, Experian transacted business in this district and nationwide. 
18. Experian collects, analyzes, maintains, or provides consumer report information or other account information, including information related to the credit history of consumers. This information is used or expected to be used in connection with any decision regarding the offering or provision of a consumer financial product or service. These products or services are consumer financial products or services covered by the CFPA. 12 U.S.C. 5481 ( 5 ) and ( 15 ) ( A ) ( ix ).

19. Further, Experian offers consumer reports, consumer file disclosures and credit scores, which are consumer financial products or services because they are or relate to consumer reports or other account information, including information relating to the credit history of consumers that Experian collects and maintains about a consumers account. Experian offers or provides these financial COMPLAINT XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Case XXXX Document 1 Filed XX/XX/XXXX Page 6 of 40 Page ID # :6 products and services to consumers primarily for personal, family, or household purposes, and delivers, offers, and provides them in connection with consumer financial products or services such as consumer credit. These products or services are therefore consumer financial products or services covered by the CFPA. 12 U.S.C. 5481 ( 5 ) and ( 15 ) ( A ) ( ix ).

20. Because Experian engages in offering or providing a consumer financial product or service, Experian is a covered person under the CFPA. 12 U.S.C. 5481 ( 6 ).

21. Experian is a consumer reporting agency as defined by the FCRA.

See 15 U.S.C. 1681a ( f ). Experian compiles and maintains files on consumers on a nationwide basis as that term is defined in the FCRA, 15 U.S.C. 1681a ( p ).

Experian is therefore subject to the FCRA.

BACKGROUND 22. The FCRA imposes a variety of obligations on CRAs like Experian to ensure that they report accurate information in consumer reports.

23. A core obligation is that if a consumer disputes the completeness or accuracy of information in their consumer report, the CRA must conduct a reasonable reinvestigation to determine whether the disputed information is accurate. 15 U.S.C. 1681i ( a ) ( 1 ) ( A ).

24. Within five business days of receiving the dispute, the CRA must provide notice of the dispute to the furnisher of the disputed information. A furnisher is any entity that provides financial information about a consumer to a CRA, such as a bank, credit card company, or debt collector. The notice to the COMPLAINT 6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 7 of 40 Page ID # :7 furnisher must include all relevant information received by the CRA regarding the dispute. 15 U.S.C. 1681i ( a ) ( 2 ) ( A ).

25. The CRA must complete the reinvestigation within 30 days after the dispute is received unless an extension is sought. 15 U.S.C. 1681i ( a ) ( 1 ) ( A ).

26. After the reinvestigation, the CRA must provide the consumer written notice of the results of the reinvestigation no later than five business days after its completion. 15 U.S.C. 1681i ( a ) ( 6 ) ( A ).

27. The FCRA further requires that the furnisher maintain reasonable procedures to prevent the reinsertion of previously deleted information, notify consumers within five business days if previously deleted information was reinserted, and ensure maximum possible accuracy of consumer reports. 15 U.S.C.

1681i ( a ) ( 5 ) ( B ), ( C ), 1681e ( b ).

e-OSCAR and the ACDV Process 28. When a CRA receives a consumer dispute, the primary way information about the dispute is communicated to furnishers is on a web-based platform called e-OSCAR. Information about the disputed information is transmitted over the e-OSCAR platform via an Automated Credit Dispute Verification form ( ACDV ).

29. The ACDV is a one-page form that contains identifying information about the consumer such as name, address, social security , and date of birth. The ACDV also reflects the disputed account ( also known as a tradeline ) as it is currently reported. The ACDV provides limited information about the consumers dispute, including a three-digit dispute code that indicates the basis of the dispute. There is sometimes a short free-form description of the dispute, based on COMPLAINT 7 Case XXXX Document 1 Filed XX/XX/XXXX Page 8 of 40 Page ID # :8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 information provided by the consumer. The ACDV may also have other relevant information attached to it, including consumer-submitted documentation supporting the dispute.

30. Below is a reproduction of an Experian ACDV : 31. After the furnisher reviews the information provided in and attached to the ACDV, it returns the ACDV to the CRA, indicating with a two-digit response code whether the disputed information is accurate or should be modified or deleted.

32. The ACDV is typically the only way CRAs and furnishers communicate during a reinvestigation.

COMPLAINT 8 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 9 of 40 Page ID # :9 FACTUAL ALLEGATIONS Experian Fails to Adequately Convey All Relevant Information to Furnishers 33. Consumers who identify inaccurate or incomplete information in their Experian consumer report can submit disputes to Experian by mail, over the telephone, or electronically through Experians website ( its Online Dispute Center ) or mobile application. Experian typically processes over a million consumer disputes per month.

34. When submitting a dispute, consumers can, and frequently do, support their disputes by submitting relevant documentation, such as bank statements, canceled checks, or settlement agreements, among other things. Consumers can submit supporting documents via mail or electronically.

35. For disputes accompanied by consumer-submitted documentation, Experians policies require that its agents determine whether the documents are sufficiently conclusive for Experian to make the change requested by the consumer. Experian refers to this as making an internal update.

36. Experian resolves a minority of disputes via an internal update. If Experian does not make an internal update, it prepares an ACDV to transmit to the furnisher through e-OSCAR. Experians policy directs its agents to attach any consumer-submitted documentation that contains additional relevant information to the ACDV, although in some cases its agents fail to do so.

37. The dispute codes included in the ACDV are integral to the dispute resolution process. As explained above, dispute codes are used by Experian to communicate the underlying basis of the dispute to the furnisher.

COMPLAINT 9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 10 of 40 Page ID # :10 38. Because Experian relies on the ACDV to communicate with furnishers about consumer disputes, it is important that Experians selected dispute code accurately conveys the basis of the dispute to the furnisher. But Experian routinely sends dispute codes to furnishers that mischaracterize or fail to convey highly relevant information about consumers disputes.

39. Many of these failures stem from Experians Online Dispute Center.

When consumers submit a dispute on the Online Dispute Center, they select a dispute description from a prepopulated list to categorize the nature of their dispute, which Experian then translates into a formal e-OSCAR dispute code that it inputs into the ACDV. Experians Online Dispute Center presents consumers with a significantly smaller set of dispute descriptions than Experian uses when consumers have submitted mail and telephone disputes. On the Online Dispute Center, for example, there are no dispute descriptions that correspond to formal e- OSCAR codes for account settled, date of first delinquency disputed, paid by insurance, consumer stated company will delete, and consumer stated company will change.

40. As an illustration, Experians Online Dispute Center instructs consumers to select a dispute description of Account paid in full if consumers believe [ they ] have paid the account in full or that it was paid in settlement. A separate dispute description for account settled is not available to consumers on the Online Dispute Center, even though it would more precisely describe the nature of the dispute.

41. When Experian then notifies the furnisher about these disputes via an ACDV, it translates the dispute description selected by the consumer to the formal COMPLAINT 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 11 of 40 Page ID # :11 e-OSCAR dispute code indicating that the consumer is disputing the accounts status ( i.e., whether the lender or creditor considers the account current or in collections ), even though a separate, more precise e-OSCAR dispute code exists that would indicate to the furnisher that the consumer is claiming the disputed account has been settled. Indeed, Experian makes no use of the e-OSCAR settlement dispute code for disputes received through the Online Dispute Center.

42. This is just one example of how furnishers receive either a mischaracterization or a less precise description of the basis for disputes submitted via the Online Dispute Center.

43. Other failures stem from Experians frequent use of an inaccurate or confusing dispute code when processing disputes submitted via telephone or mail.

For example, when a consumer lodges a dispute claiming that an account was paid, Experian inserts into the ACDV the e-OSCAR dispute code labeled Claims account closed instead of an appropriate dispute code for paid accounts.

44. As another example, Experian inserts into the ACDV the intentionally generic e-OSCAR dispute code labeled Claims inaccurate information. Did not provide specific dispute. even where the consumer provides specific information pertaining to the dispute, such as disputing the date of first delinquency or the payment of an account, and for which a more specific dispute code, such as Disputes Date of First Delinquency and Disputes present/previous Account Status, History is available and appropriate.

45. And as another example, Experian agents apply dispute codes requesting updates that are already reflected on consumers tradelines and therefore do not correspond to the actual substance of consumers disputes. As one COMPLAINT 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 12 of 40 Page ID # :12 illustration, agents apply the Claims account closed dispute code to tradelines that already display as closed. The fact that the update requested is already reflected on the tradeline suggests that the basis for the underlying dispute differs from the dispute code selected by Experian, and that Experian has not accurately described the nature of the dispute to the furnisher.

46. By failing to select appropriate dispute codes, Experian fails to accurately convey the basis of the consumers disputes to furnishers in what is usually the only communication Experian has with the furnisher during its reinvestigation. By using inaccurate or misleading dispute codes, Experian fails to provide the furnisher with all relevant information about the consumers dispute and fails to fulfill its reasonable reinvestigation obligations.

47. In addition to transmitting misleading, confusing, or inaccurate dispute codes to furnishers, Experian also fails to always include relevant consumer submitted documentation with the ACDV transmitted to the furnisher, despite Company policy requiring agents to do so. Relevant consumer documentation often contains information that is not conveyed elsewhere on the ACDV, including probative evidence that supports the merits of the consumers dispute. As a result, Experian fails to provide the furnisher with all relevant information about the consumers dispute and fails to fulfill its reasonable reinvestigation obligations.

48. These failures hinder the reinvestigation.

49. As a result of the above, Experian fails to conduct a reasonable reinvestigation and convey all relevant information to furnishers, which causes or increases the risk that inaccurate information remains in consumers files.

COMPLAINT 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 13 of 40 Page ID # :13 Experian Over-relies on Furnishers ACDV Responses During its Reinvestigation Even When Presented with Information Suggesting that the Furnisher is Unreliable 50. Experian regularly over-relies on furnishers ACDV responses when conducting a reinvestigation, even when Experian possesses information that alerts or should alert Experian to the possibility that the furnisher of the disputed information might be unreliable. As a result, Experian permits inaccurate information to remain in consumers files. Experian does so even though cost- effective measures exist to resolve any outstanding factual issues.

51. Experians over-reliance on furnishers ACDV responses occurs in at least three categories of disputes : disputes where consumer documentation provides highly probative evidence about the dispute, disputes where Experian itself possesses relevant information about the dispute in its own consumer files, and disputes where Experian receives illogical and inconsistent ACDV responses from furnishers.

52. Consumers often provide documentation that, at a minimum, should put Experian on notice that reinvestigation beyond the furnishers ACDV response is necessary. For example, consumers frequently provide Experian with the date or case number of a bankruptcy petition discharging a particular debt that is still being reported on their consumer report, or documents reflecting an agreement to settle a debt for a certain amount. In other instances, consumers provide Experian documentation showing that the furnisher had previously agreed to delete or correct information in the disputed tradeline.

COMPLAINT 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 XXXX XXXX Document 1 Filed XX/XX/XXXX Page 14 of 40 Page ID # :14 53. Such documents are sufficient to put Experian on notice that the furnisher may have transmitted unreliable information. Yet, Experian regularly gives the supporting documents no weight in resolving the dispute and routinely conducts no further reinvestigation of the dispute beyond the furnishers ACDV response.

54. Next, Experian frequently possesses relevant supporting information in its own consumer files that should alert it to a furnishers unreliability. For example, Experian often possesses information confirming the existence of a bankruptcy fitting the description in the consumers dispute, or information confirming that a consumer has made a settlement payment. Often this information alerts or should alert Experian to the possibility that the tradeline disputed by the consumer might be inaccurate and the furnisher might be unreliable. Yet, Experian routinely conducts no additional reinvestigation based on this information, and instead relies solely on the furnishers ACDV response to resolve the dispute.

55. Finally, Experian frequently receives furnisher responses that contain data that is either illogical or facially and internally inconsistent, but it still accepts the furnishers response without further reinvestigation into the dispute.

56. For example, Experian receives ACDV responses with inconsistent information, such as indicating a consumers overdue balance is greater than the total amount due. Other ACDV responses state that a consumer first became delinquent on an installment debt a month after the consumer had paid the account to a XXXX  balance. 
57. Receiving an ACDV with illogical or inconsistent data is alerts or should alert Experian to the possibility that the original furnisher of the disputed COMPLAINT 14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 15 of 40 Page ID # :15 information might be unreliable and the disputed information may be inaccurate.

Yet, Experian regularly accepts the ACDV response in those circumstances and ignores the fact that it contains illogical or inconsistent information.

58. In some instances where Experian receives illogical responses from furnishers, Experian partially implements the furnishers ACDV response on the consumers tradeline, but also unilaterally alters the information in the ACDV to make it appear logical and consistent. In doing so, Experian does not take steps to ensure that the changed tradeline is in fact complete and accurate ; Experian simply changes the tradeline by applying predetermined business rules. Experian does not, for example, verify the changes with the furnisher, base the changes on another reliable source of information, or confront the furnisher with the apparent error.

59. To the detriment of consumers, in all of the above-described scenarios, Experian routinely does nothing more than send an ACDV to the furnisher and implement its response.

60. Experian does so without consulting readily available, inexpensive third-party sources of information, such as bankruptcy court records, that could accurately and definitively resolve the consumers dispute. And Experian routinely does not pose any queries to the furnisher for specific factual information, such as the authenticity of a document, the existence of a settlement agreement, or why the furnishers response appears to be internally illogical and inconsistent.

61. Experians failures to conduct reasonable reinvestigations negatively impact consumers.

62. First, Experians over-reliance on furnishers ACDV responses results in consumer reports maintaining inaccurate information, such as a tradeline with an COMPLAINT 15 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 16 of 40 Page ID # :16 inaccurate status or balance. This inaccurate information can have deleterious impacts on consumers, including lowering their credit score, the denial of credit, housing, employment, or other goods or services, or causing consumers to obtain less favorable credit terms.

63. Additionally, consumers waste their time and resources submitting disputes that are not adequately reinvestigated and gathering and submitting documents that are given no consideration in the dispute process.

Experian Fails to Inform Consumers of Reinvestigation Results 64. At the conclusion of a reinvestigation, Experian sends consumers written results letters intended to fulfill its statutory obligation to report the results of the reinvestigation.

65. Experians results letters include an initial section labeled How to Read Your Results which lists the possible reinvestigation outcomes of Deleted, Remains, Updated, and Processed and their accompanying definitions.

Notably, Experian defines Updated four different ways, some of which indicate information other than the disputed information was updated.

66. Below is an example of the relevant portion of an Experian results letter : 67. reinvestigation outcome for each.

Directly below that, Experian lists the disputed accounts and the COMPLAINT 16 Case XXXX Document 1 Filed XX/XX/XXXX Page 17 of 40 Page ID # :17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 68. On subsequent pages, Experian typically displays a snapshot of how the disputed account appears before and after the reinvestigation. However, the after snapshot of the account often looks nearly identical to the before snapshot, and the results letter does not explicitly identify what information was updated or changed. Instead, consumers are required to deduce that on their own.

In cases of deleted tradelines, no snapshots are provided.

COMPLAINT 17 XXXX XXXX Document 1 Filed XX/XX/XXXX Page 18 of 40 Page ID # :18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 69. Below is an example of a before and after snapshot from a letter that informed the consumer that their information was updated. The consumer was left to deduce what information was updated. This snapshot was not accompanied by any explanation of what information changed.

70. Experians results letters often provide inaccurate, contradictory, ambiguous, or confusing information to consumers regarding the outcome of their COMPLAINT 18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 19 of 40 Page ID # :19 reinvestigation, and fail to inform them of what, if anything, changed on their consumer report as a result of the dispute.

71. For example, a number of Experian results letters state the result of a reinvestigation as Outcome : Processed This item was either updated or deleted ; Please review your report for the details.

72. Although a typical results letter includes the before and after snapshots of an updated tradeline, these letters only display how the tradeline appears before the dispute.

73. In addition, these results letters use three of the four potential dispute outcomes to describe the results of the investigation ( processed, updated, and deleted ), including two potentially inconsistent outcomes updated and deleted.

74. Below is an example of the relevant portion of an Experian results letter : COMPLAINT 19 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 20 of 40 Page ID # :20 75. These results letters do not provide the result of the reinvestigation.

They are confusing and contradictory, and do not adequately inform consumers of the outcome of the reinvestigation. The letters do not identify what information was updated or deleted or even provide an updated credit report or an after snapshot for the consumer to attempt to self-identify the update or deletion. They also fail to clearly identify whether information was updated, or deleted, or both.

76. Another subset of Experian results letters pairs a reinvestigation result of Outcome : Updated with before and after snapshots of the tradeline that show no change.

77. Below is an example of the relevant portion of an Experian results letter : COMPLAINT 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 21 of 40 Page ID # :21 78. This subset of results letters fails to describe the results of the reinvestigation to the consumer. They do not identify what information was updated and they do not depict any updates in the accompanying tradeline snapshots. Consumers receiving such a notice have no way of deciphering what information was updated and why, or whether the disputed information itself was updated. Consumers also can not determine if the update was the result of the reinvestigation, or due to some other reason.

79. A third subset of Experians results letters describe the outcome of a reinvestigation as Updated and provided the following definition : Information on this item has been updated. Please review your report for the details.

COMPLAINT 21 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Case XXXX Document 1 Filed XX/XX/XXXX Page 22 of 40 Page ID # :22 80. Below is an example of the relevant por

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