Consumer complaint received 2025-07-23 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: CashRepublic Holdings, Inc.
State: CA

Complaint narrative:
XXXX XXXX XXXX, XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, CA XXXX Email : XXXX Phone : ( XXXX ) XXXX XXXX XXXXXXXX XXXX Member XXXX XXXX ( XXXX, XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX : XX/XX/XXXX To : Omni Financial of Nevada , Inc . 
P.O. XXXX XXXX XXXX XXXX, NV XXXX XXXX And : Consumer Financial Protection Bureau XXXX XXXX Box XXXX Washington, XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX, GA XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX. XXXX XXXX XXXX, PA XXXX Subject : Formal Rebuttal Dispute of Account # XXXX ( Omni Financial ) Under FCRA, MLA, and SCRA Request for Immediate Deletion and Cease Reporting CFPB Complaint Reference : # 25XXXX To Whom It XXXX Concern : I am writing in formal response to Omni Financials letter dated XX/XX/XXXX, concerning Account # XXXX and the related dispute filed with the Consumer Financial Protection Bureau XXXX I reject Omni Financials position and reassert my demand for the immediate deletion of this account from all consumer reporting agencies and the permanent cessation of collection activities.

Omnis response fails to recognize the broader legal protections afforded under federal law, including the Fair Credit Reporting Act ( FCRA ), the Servicemembers Civil Relief Act ( SCRA ), and the Military Lending Act ( MLA ). Below is my detailed rebuttal : 1. Misapplication of SCRA 50 U.S.C. 3937 Omni incorrectly asserts that I am not entitled to SCRA protections because the loan originated during active duty. However, courts have repeatedly held that SCRA should be interpreted liberally in favor of servicemembers ( see Le Maistre v. Leffers, 333 U.S. 1 ( 1948 ) ; Brewster v. Sun Trust Mortg., 742 F.3d 876 ( 9th Cir. 2014 ) ). The stress, limited legal access, and unique vulnerabilities of military life warrant SCRA protection when : The loan structure causes undue financial burden ; Consent is obtained under duress or distraction ; The enforcement or collection efforts interfere with active service.

Even if originated during service, I maintain that this loan meets the threshold for SCRA relief due to its terms, enforcement tactics, and military impact.

2. MLA Violations 10 U.S.C. 987 & 32 C.F.R. Part 232 Omni admits that the loans MAPR is 35.948 %, just below the statutory cap of 36 %. However, compliance with the cap alone does not negate other MLA violations, including : Use of a Third Party Disclosure Agreement that allows contact with my employer and relatives ; Failure to provide clear written MAPR disclosures, as required under 32 C.F.R. 232.6 ; Possible forced allotment mechanisms and waiver of rights, contrary to 10 U.S.C. 987 ( e ) ( f ).

The MLA prohibits covered lenders from requiring any terms that undermine servicemember protections. Any ambiguity must be resolved in favor of the servicemember.

3. FCRA Violations 15 U.S.C. 1681s-2 ( b ) Despite notice of this dispute through the CFPB, Omni has continued furnishing negative data to consumer reporting agencies without demonstrating : A reasonable investigation into the dispute ; Verification of the debts accuracy ; Correction or deletion of disputed information.

This constitutes a violation of FCRA 1681s-2 ( b ) and opens Omni to civil liability under 1681n and 1681o.

4. Improper Reporting After Charge-Off Deceptive Practices Omnis continued reporting of interest and balances after charge-off ( XX/XX/XXXX ) conflicts with guidance from the Federal Trade Commission and rulings such as FTC v. Asset Acceptance , LLC, No. 8:14-cv-1615. These practices may mislead consumers and constitute unfair or deceptive acts under the FTC Act and CFPBs UDAAP doctrine.

5. Lack of Informed Consent The alleged contract was electronically signed during a period of active military duty. Given the power imbalance and unique demands on servicemembers, I dispute the validity of the alleged consent and authorization to furnish credit data. The burden of proof lies with the furnisher to show that consent was : Freely given, Fully informed, and Not undermined by undue influence.

Under FCRA 1681b ( b ) ( 2 ) ( A ) and case law, any such authorization may be withdrawn and is not irrevocable.

Demand for Immediate Relief I hereby demand that Omni Financial, all credit bureaus, and the CFPB take the following actions : 1. Immediate deletion of Account # XXXX from all consumer credit files. 
2. Cessation of collection activities and all third-party contact.

3. Written confirmation of the accounts deletion and closure of this matter.

4. A complete accounting of all fees, interest, and charges applied post-charge-off.

Notice of Legal Intent Failure to resolve this matter within 15 days of receipt will result in escalation, including : Legal action under FCRA 1681n and 1681o ; Complaint filings with the Department of Justice SCRA/MLA Unit , JAG, and California DFPI ; Class action exploration for systemic abuses under MLA/SCRA. 

This serves as a formal legal notice of dispute and demand for resolution. 



Sincerely, XXXX XXXX XXXX XXXX, XXXX United States XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, CA XXXX XXXX ( 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 explanation