Consumer complaint received 2025-04-14 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Problem with a company's investigation into an existing problem — Problem with personal statement of dispute
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: LA

Complaint narrative:
# FORMAL DISPUTE AND REGULATORY VIOLATION NOTICE XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXXXXXX ( XXXX ) XXXX XXXX Date : XX/XX/XXXX TransUnion Consumer Solutions XXXX XXXX XXXX XXXXXXXX XXXX XXXXXXXX **RE : MULTIPLE REGULATORY VIOLATIONS AND DEMAND FOR IMMEDIATE CORRECTION** **Reference : Credit File # : XXXX **ATTN : Legal Department, Compliance Officer, and Chief Executive Officer** To Whom It May Concern : This correspondence serves as formal notice of multiple, severe regulatory violations in my TransUnion consumer report dated XX/XX/XXXX, and in your dispute processing systems. These violations span numerous federal statutes including but not limited to the Fair Credit Reporting Act ( FCRA ), Federal Trade Commission Act ( FTCA ), Truth in Lending Act ( TILA ), Equal Credit Opportunity Act ( ECOA ), Fair and Accurate Credit Transactions Act ( FACTA ), Gramm-Leach-Bliley Act ( GLBA ), Driver 's Privacy Protection Act ( DPPA ), and the Dodd-Frank Wall Street Reform and Consumer Protection Act. 

# # XXXX XXXX TRANS UNION, LLC PRECEDENT I specifically direct your attention to the landmark case of XXXX XXXX Trans Union, LLC ( Case No. XXXX, XXXX. XXXX ), which established critical precedents directly applicable to my situation : 1. The court certified a class of plaintiffs who received TransUnion 's standard " 502 Letter '' in response to disputes, finding TransUnion 's practices constituted systematic FCRA violations 2. The court explicitly rejected TransUnion 's argument that technical accuracy alone satisfies FCRA requirements, ruling that misleading information that " adversely affects credit decisions '' still constitutes an " inaccuracy '' under the law 3. The court determined that TransUnion 's failure to conduct meaningful reinvestigations demonstrated " an artificially narrow view of its obligations '' that was fundamentally " inconsistent with the text and structure '' of the FCRA 4. The court confirmed that when a consumer reporting agency performs no reinvestigation at all, requiring the consumer to prove the inaccuracy themselves " would be inconsistent with the structure of the FCRA, which squarely places the burden of determining accuracy on the credit reporting agency after a dispute has been lodged '' 5. TransUnion recently agreed to a {$23.00} XXXX settlement in this case for the exact type of violations present in my situation # # DOCUMENTED TECHNICAL BARRIER TO STATUTORY RIGHTS I have documented evidence ( attached screenshot ) showing your " Active Dispute or Update Requests '' system has been perpetually displaying a " Loading '' status with error code " 411 '' for multiple days. This technical failure constitutes an absolute barrier to my federally protected dispute rights and represents a willful violation of multiple consumer protection laws. This evidence will be preserved for potential regulatory complaints and legal proceedings. 

# # PERSONAL AND FINANCIAL HARM SUFFERED As a direct result of these violations, I have suffered tangible harm including : 1. Multiple denials of credit cards and financing options that were necessary to provide essential items for my one-year-old daughter 2. Persistent stress-induced headaches from repeated unsuccessful attempts to correct these errors 3. Inability to secure needed financing due to false information and Metro 2 compliance failures in my file 4. Emotional distress from seeing false employment information that misrepresents my identity and circumstances These concrete damages demonstrate that TransUnion 's violations are not merely technical but have caused actual, compensable harm to me and my family. 

# # DETAILED METRO 2 FORMAT SEGMENT VIOLATIONS My TransUnion report ( File # XXXX ) contains multiple severe violations of the Metro 2 Format standards established by the XXXX XXXX XXXX XXXX ( XXXX ) XXXX XXXX XXXX XXXX ( XXXX ). These violations render my entire credit report substantively inaccurate under FCRA standards : # # # Base Segment Violations : 1. Contradictory Payment History Ratings : My credit report shows conflicting payment histories for XXXX XXXX XXXX with multiple inconsistent 30-day, 60-day and OK ratings across different time periods, despite accounts being closed. 
2. Internally Inconsistent Payment Status Information : The same creditor ( XXXX XXXX XXXX ) appears twice with different account numbers ( # XXXX and # XXXX ) with contradictory payment histories for overlapping time periods. 
3. Future-Dated Payment Information : Account for XXXX XXXXXXXX XXXX shows a `` Last Payment Made '' date of XX/XX/XXXX, which is impossible and violates Metro 2 date reporting requirements. 
4. Account Status and Remark Inconsistencies : Accounts marked " CLOSED '' still appear under " Accounts with Adverse Information '' without proper status code indication. 
5. Double-Reported Tradelines : The same XXXX XXXX XXXX creditor appears multiple times with different account numbers but identical address and balance information, violating Metro 2 duplicate reporting standards. 

# # # XXXX Segment Violations ( Supplementary Consumer Information ) : 1. ECOA Code Missing : No codes are present indicating account ownership type ( individual, joint, authorized user, etc. ). 
2. XXXX XXXX XXXX ( CII ) Codes Absent : No indicators for special circumstances despite the incorrect military status designation. 

# # # XXXX Segment Violations : 1. Original Creditor Information ( XXXX Segment ) Missing : No proper linkage between original and current creditors for collection accounts XXXX. Address/Contact Information ( XXXX Segment ) Irregularities : Inconsistent creditor address information across duplicate tradelines # # # Associated XXXX Segment Defects : 1. Payment Profile Start Date inconsistencies with XXXX XXXX reporting periods 2. Failure to properly populate Consumer Account Number field with masked identifiers 3. Absence of required Special Comment Codes for accounts with unusual status # # # Structural Format Issues : 1. Date Reporting Errors : Multiple future-dated information instances : - Employer verification shows " XX/XX/XXXX '' XXXX XXXX XXXX XXXX  shows Last Payment Made " XX/XX/XXXX '' 2. Contradictory Employment Information : My report simultaneously shows employment with " THE UNITED STATES XXXX XXXX '' ( XX/XX/XXXX ) and " NOT APPLICABLE '' ( XX/XX/XXXX ), demonstrating fundamental record structure violations. 
3. Conflicting Rating Systems : The Rating Key indicates specific delinquency codes ( XXXX, XXXX, XXXX, etc. ) but these are inconsistently applied across accounts, with some showing " OK '' ratings alongside numerical ratings within the same reporting periods. 

These Metro 2 Format violations fundamentally undermine the accuracy and utility of my entire credit report. Without proper segment field compliance, my information is not being reported according to industry standards established by XXXX, making my entire credit report substantively defective under FCRA standards of " maximum possible accuracy. '' # # COMPREHENSIVE REGULATORY VIOLATIONS # # # 1. FAIR CREDIT REPORTING ACT ( FCRA ) VIOLATIONS : a ) 1681e ( b ) [ 15 U.S.C. 1681e ( b ) ] Maximum Possible Accuracy Violation : Your report fails to comply with Metro 2 Format requirements established by the XXXX XXXX XXXX XXXX ( XXXX ) XXXX XXXX XXXX XXXX ( XXXX ), including missing Account Status Codes, Payment Rating codes, Payment History Profiles, and ECOA codes. These deficiencies render my entire report substantively inaccurate. 

b ) 1681i ( a ) ( 1 ) Reinvestigation Obstruction : Your malfunctioning dispute portal with error code " 411 '' constitutes a constructive denial of my right to dispute inaccuracies, violating your statutory obligation to conduct a " reinvestigation '' of disputed items. 

c ) 1681i ( a ) ( 6 ) Notification Requirement Violation : You have failed to provide the required notices following my previous dispute attempts, another indication of systemic compliance failures. 

d ) 1681c ( a ) Obsolete Information Violation : Your report contains information from XXXX without statutorily required justification for continued reporting beyond the standard reporting period. 

e ) 1681s-2 ( a ) ( 1 ) Duty to Provide Accurate Information : The contradictory payment history information for the same creditor violates the accuracy requirements imposed by this section. 

f ) 1681c ( a ) ( 5 ) [ 15 U.S.C. 1681c ( a ) ( 5 ) ] Time Limitation Violation : Your report contains multiple inquiries and adverse information beyond the 7-year statutory reporting period, specifically items from XXXX still appearing on the XXXX report without qualifying exceptions. 

g ) 1681b ( f ) Impermissible Access : Multiple entities including XXXX, XXXX XXXX via XXXX, and XXXX accessed my report claiming " WRITTEN AUTHORIZATION '' which I did not provide, constituting separate violations with statutory damages of $ XXXX {$1000.00} per occurrence. 

h ) 1681g ( a ) ( 2 ) Source Disclosure Failure : TransUnion failed to properly disclose the sources of information used to generate contradictory employment records and military status designations. 

# # # 2. FEDERAL TRADE COMMISSION ACT ( FTCA ) VIOLATIONS : a ) Section 5 Unfair Practices : Your perpetual loading screen creates substantial, unavoidable injury to consumers by preventing exercise of statutory rights without countervailing benefits, meeting the three-prong test for unfairness under FTC policy statements.

b ) Section 5 Deceptive Practices : Displaying a non-functional dispute system that appears operational constitutes a material misrepresentation likely to mislead consumers acting reasonably under the circumstances. 

c ) FTC Credit Practices Rule ( 16 CFR 444 ) : The contradictory payment information for identical creditors with different account numbers constitutes unfair credit reporting practices under FTC regulations. 

# # # 3. TRUTH IN LENDING ACT ( TILA ) VIOLATIONS : a ) Regulation Z 1026.13 Billing Error Resolution Obstruction : The technical barrier interferes with the TILA-mandated error resolution ecosystem that depends on functional credit reporting dispute mechanisms. 

b ) 1637 Account Information Integrity : Incorrect military status designations impact proper TILA disclosures that creditors must provide based on special military protections. 

c ) Regulation Z 1026.41 Periodic Statement Requirements : The conflicting payment histories shown for the same creditor interferes with proper periodic statement requirements under TILA. 

# # # 4. EQUAL CREDIT OPPORTUNITY ACT ( ECOA ) VIOLATIONS : a ) Regulation B 1002.12 ( b ) Record Retention Violation : Improperly designating my military status as " UNITED STATES XXXX XXXX '' when I am not employed by them constitutes a prohibited basis designation error under ECOA. 

b ) Regulation B 1002.9 Notification Requirements : The false military designation triggers improper notice requirements from creditors, creating downstream ECOA compliance failures. 

c ) Regulation B 1002.6 Rules Concerning Evaluation of Applications : The contradictory employment information may result in improper evaluation of credit applications, violating ECOA standards for creditworthiness determination. 

# # # 5. FAIR AND ACCURATE CREDIT TRANSACTIONS ACT ( FACTA ) VIOLATIONS : a ) Identity Theft Prevention Failures : Incorrect personal identifying information ( name listed as " XXXX XXXX XXXX '' instead of " XXXX XXXX XXXX ) violates FACTA 's identity theft prevention provisions. 

b ) Direct Dispute Rule Non-Compliance : Technical barriers to dispute submission directly violate FACTA 's direct dispute regulations ( 16 CFR 660.4 ). 

# # # 6. GRAMM-LEACH-BLILEY ACT ( GLBA ) VIOLATIONS : a ) Privacy Rule Violations : Sharing incorrect military status information constitutes improper disclosure of non-public personal information to third parties. 

b ) Safeguards Rule Violations : Your system 's persistent technical failures suggest inadequate information security protocols required under GLBA. 

# # # 7. DODD-FRANK WALL STREET REFORM AND CONSUMER PROTECTION ACT VIOLATIONS : a ) UDAAP Violations : The persistent loading error constitutes an " abusive '' practice by materially interfering with my ability to understand and exercise dispute rights. 

b ) 12 U.S.C. 5531 ( c ) Good Faith and Fair Dealing Violation : Maintaining a non-functional dispute system violates the fundamental good faith and fair dealing requirements. 

# # # 8. DRIVER 'S PRIVACY PROTECTION ACT ( DPPA ) VIOLATIONS : a ) 18 U.S.C. 2721 Unauthorized Use : If personal information from DMV records was used for any listed inquiry without explicit consent, this constitutes a DPPA violation with statutory damages of {$2500.00} per occurrence. 

b ) 2722 ( a ) Prohibition on Disclosure : The sharing of driver 's license information related to my identification verification without explicit consent violates core DPPA protections. 

# # # 9. CREDIT XXXX XXXX XXXX ( XXXX ) TECHNICAL VIOLATIONS : a ) Account Status/Date Inconsistencies : Report contains contradictory dates that violate XXXX technical requirements b ) Special Comment Code Misapplication : Required codes for specific account conditions are absent c ) Date of First Delinquency Miscalculations : Improper calculation methodologies evident in reporting timelines d ) Consumer Information Verification Failures : Misreported employment data demonstrates verification system failures e ) Payment Profile Misrepresentation : Inconsistent historical payment data across identical tradelines # # SPECIFIC INFORMATION REQUIRING IMMEDIATE CORRECTION 1. Personal Information Errors : - Legal name incorrectly listed as " XXXX XXXX XXXX '' instead of " XXXX XXXX '' - False employment with " THE UNITED STATES XXXX XXXX XXXX XXXX Improper military status designation 2. Metro 2 Format Non-Compliance : Multiple accounts lack required data fields per CDIA guidelines 3. Technical Account Errors : - XXXX XXXXXXXX inquiry ( XX/XX/XXXX ) lacks permissible purpose documentation - XXXXXXXX XXXX XXXX contains contradictory payment histories and appears twice - XXXXXXXX XXXX XXXX shows impossible future payment date ( XX/XX/XXXX ) - Future-dated timestamp errors ( XX/XX/XXXX and XX/XX/XXXX ) - Accounts marked " CLOSED '' inappropriately appearing under " Accounts with Adverse Information '' # # DEMANDED REMEDIAL ACTIONS Under the combined authority of the aforementioned statutes, I DEMAND that TransUnion : 1. IMMEDIATELY correct my legal name to " XXXX XXXX '' 2. REMOVE ALL accounts with Metro 2 compliance violations 3. DELETE all military designations and employment information related to the XXXX XXXX 4. CORRECT all timestamp errors and future-dated information 5. REMOVE all unauthorized inquiries 6. CORRECT the contradictory payment histories for XXXX XXXX XXXX accounts 7. RESOLVE duplicate reporting for the same creditor 8. PROVIDE full documentation of any previous disputes I have attempted to submit 9. REMEDY the technical barriers preventing dispute submission 10. SUPPLY written confirmation that your technical systems have been audited and corrected

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