Consumer complaint received 2025-08-05 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: MO

Complaint narrative:
CFPB COMPLAINT MISSOURI XXXX XXXX XXXX XXXX ( XXXX ) This is a supplemental complaint regarding XXXX unlawful disclosure of my personal and educational loan data, inaccurate credit reporting, conversion of my contract into a security without consent, and misrepresentation to the Consumer Financial Protection Bureau ( CFPB ). 

XXXX previously stated to the CFPB : XXXX is not permitted to copy, delete, archive, or transfer borrower data without prior written consent from the U.S. Department of Education ( ED ).

We do not report to third-party agencies without authorization.

However, MOHELAs own Indenture of Trust Series 2021-1 Asset-Backed Notes directly contradicts these statements.

From the Indenture of Trust, Granting Clause C & E : The Issuer does hereby grant, bargain, sell, convey, transfer, assign, and pledge all obligations of the obligors under the Financed Eligible Loans, together with all Accounts, General Intangibles, Payment Intangibles, Promissory Notes, and Instruments to the Indenture Trustee This is a clear transfer of borrower data and contractual rights to a third-party trustee ( U.S. Bank ) for investors, without my consent, violating the Privacy Act of 1974 ( 5 U.S.C. 552a ( b ) ) and the Family Educational Rights and Privacy Act ( FERPA, 20 U.S.C. 1232g ; 34 CFR Part 99 ).

From Section 4.19 Statements to Noteholders and Rating Agencies : The Servicer shall provide periodic statements containing loan performance information to the Indenture Trustee, Noteholders, and Rating Agencies.

From Section 4.07 Delegation of Duties : The Servicer may delegate duties and obligations to subservicers and backup servicers These provisions show XXXX regularly reports borrower information to private, non-governmental entities such as rating agencies, investors, and third-party servicers, contradicting their claim that they do not report to third-party agencies. 

Additionally, XXXX has securitized my loan by placing it in the Trust Estate that secures {>= $1,000,000} in Student Loan Asset-Backed Notes, converting my application and contract into a security without my consent, violating the Securities Act of 1933 ( 5, 12 ), the Securities Exchange Act of 1934 ( 13, 15 ( d ) ), and the Trust Indenture Act of 1939 ( 310314 ). These are material omissions from XXXX CFPB response. 

XXXX is also inaccurately reporting my loan across the three major credit bureaus. My XX/XX/XXXX credit reports show the same XXXX tradeline with different delinquency descriptors : Over 120 Days Past Due ( Equifax ), 120 Days Past Due ( TransUnion ), and 120+ Days Past Due ( Experian ). This violates FCRA ( 15 U.S.C. 1681s-2 ( a ) ( 1 ) ( A ), 1681s-2 ( a ) ( 2 ) ) and 12 CFR 1022.42. 

DEMAND : XXXX is hereby given ten ( 10 ) calendar days from receipt of this complaint to make all necessary corrections, deletions, and provide documentary proof of compliance, including EDs written consent for all third-party disclosures. 
Failure to fully comply within this period will result in my filing of formal complaints with the Better Business Bureau ( BBB ), Federal Deposit Insurance Corporation ( FDIC ), Missouri Attorney General, and the U.S. Securities and Exchange Commission ( SEC ).

Additionally, I will initiate a federal securities fraud lawsuit against XXXX and all associated entities for the unlawful conversion and securitization of my personal loan contract. 

REQUESTED RELIEF : I request that the CFPB ( 1 ) order immediate deletion of my XXXX tradeline from all CRAs due to unlawful disclosure, ( 2 ) require XXXX to produce EDs written consent authorizing CRA and investor reporting, ( 3 ) refer this matter to the SEC, DOJ, and ED Inspector General for investigation of securities and privacy violations, and ( 4 ) mandate XXXX to correct and standardize all CRA reporting. 

XXXX XXXX

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 non-monetary relief