Consumer complaint received 2025-04-07 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: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: MN

Complaint narrative:
Summary of Demand Please take notice that I hereby demand the immediate deletion of multiple charged-off and late-payment accounts from my credit files. These accounts ( identified in detail below ) are inaccurately reported and unlawfully retained on my credit reports despite : Debt Cancellation : The debts were canceled/discharged, triggering IRS reporting of canceled debt as income ( 26 U.S.C. 61 ( a ) ( 12 ) ) and implicating IRS Publication 4681 on canceled debts. A canceled debt is no longer an enforceable obligation, and continuing to report it as owed is false. ( Indeed, IRS Pub. 4681 notes that a taxpayer may not have to include canceled debt in income under certain conditions underscoring that the debt is treated as extinguished. ) UCC Public Filings : I have filed and perfected UCC-1 Financing Statements ( Delaware Filing XXXX XXXX ; Minnesota Filing XXXX XXXX ) accompanied by executed security agreements. These filings are public records that put all parties on notice that the referenced debts have been secured and settled. Under the Uniform Commercial Code, an account is defined as a right to payment of a monetary obligation ( including credit card or loan receivables ). The above filings establish my secured interest and rights in these accounts, meaning any remaining debt obligations have been resolved via security interest or set-off. Continuing to report these accounts as delinquent ignores the UCC Article 9 rights and the fact that the obligations have been addressed.

Apostilled Documents : The relevant security agreements and affidavits have been apostilled pursuant to the 1961 Hague Convention, confirming their authenticity as public documents internationally. This means the discharge of debt and transfer of rights in those accounts are not only recorded domestically but also recognized internationally. The Credit Bureaus have constructive and actual notice of these apostilled public filings, yet have failed to adjust my reports accordingly. 
Prior Disputes FCRA Non-Compliance : I have disputed these accounts, yet you have failed to investigate and correct the information as required. Under the Fair Credit Reporting Act ( FCRA ), you are obligated to maintain maximum possible accuracy and to promptly delete or correct information that can not be verified or is inaccurate. However, the accounts remain, showing months of false derogatory information. This is a blatant violation of 15 U.S.C. 1681e ( b ), 1681i, and 1681s-2 ( b ). The FCRA and its implementing regulations also require furnishers and bureaus to ensure information reflects the true status of the debt. For example, CFPB regulations define accuracy to mean that furnished information correctly reflects liability and performance on the account Reporting a canceled or otherwise settled debt as a charge-off with a balance due is inaccurate by definition under these standards.

Demand : I demand that each Credit Bureau delete the accounts listed below in full from my credit reports. Written confirmation of deletion and updated credit reports should be provided within 5 calendar days of your receipt of this letter ( note : FCRA also requires that upon deletion after a dispute, the consumer be notified and provided a copy of the updated report within 5 business daysFailure to comply will result in immediate legal action, regulatory complaints, and pursuit of all available remedies against you.

________________________________________ 2. Legal Basis for Removal of These Accounts 2.1 Debt Cancellation IRS Treatment and Federal Law Under federal law, a debt that is canceled or forgiven is treated as income to the debtor, because it is no longer an obligation to repay ( 26 U.S.C. 61 ( a ) ( 12 ) ). I have received IRS Form 1099-C for the relevant accounts ( or the creditors were obligated to issue them ), meaning the creditors formally canceled the debts. Once a debt is canceled, the creditor writes off the debt, and the IRS considers it discharged. In fact, IRS Publication 4681 explicitly notes that a taxpayer may exclude canceled debt from income in cases of insolvency or other exceptions reinforcing that the debt itself has been extinguished.

Implication : If a debt no longer exists for purposes of collection ( and is only an IRS reportable event ), it is patently inaccurate for the Credit Bureau to continue reporting the account as an outstanding balance, past-due, or charge-off. Doing so misrepresents the consumers obligations and creditworthiness. By reporting a canceled debt as a live delinquency, you are furnishing false credit information. This runs afoul of the FCRAs accuracy mandate and also potentially constitutes deceptive conduct, since the true status ( discharged debt ) is not reflected. It also may violate 15 U.S.C. 1681s-2 ( a ) ( 1 ) ( A ), which prohibits furnishers from reporting information they know or have reason to know is inaccurate.

Furthermore, federal regulations and banking guidelines require that creditors charge off delinquent accounts ( e.g. credit cards after 180 days of non-payment ) and cease treating them as assets. Once charged off, the debt is no longer carried on the creditors books, and if its also canceled ( with a 1099-C issued ), it is effectively resolved from a legal standpoint. Continuing to report such an account as if its an enforceable debt is not only inaccurate but also undermines the purpose of those regulations ( which is to accurately reflect when a debt is uncollectible ).

In summary, the presence of a 1099-C or charge-off on an account means the debt should not be reported as owed. I have included in prior disputes copies of relevant 1099-C forms and affidavits of debt cancellation. Your failure to remove these accounts despite evidence of cancellation is a willful violation of FCRAs requirement to follow reasonable procedures to assure maximum possible accuracy XXXX. 
XXXX UCC Financing Statements and Security Agreements I have taken the additional step of securing my rights through the Uniform Commercial Code ( UCC ) filings mentioned above. These UCC-1 Financing Statements, filed with the Delaware Secretary of State and the Minnesota Secretary of State, give public notice of a security interest in the accounts/debts at issue. In the underlying security agreements ( duly executed and notarized ), the original creditors agreed ( by acquiescence or contract ) to transfer rights and title in the accounts to me, the secured party, as part of a settlement and discharge of the debt. These documents have been apostilled for authenticity under the Hague Convention of 1961, making them valid for recognition internationally.

Under UCC Article 9, an account is broadly defined as a right to payment of a monetary obligation, including those arising from loans or credit card transactions The debts being reported by your agency fall squarely within this definition. As the secured party of record on these accounts, I hold the senior rights to those obligations. In effect, the obligations have been assigned to me and discharged they are no longer owed by me to the original creditors. Therefore, from the perspective of any third-party ( including a CRA ), there is a XXXX balance and no delinquency the original creditor has been made whole or has relinquished its claim, and I, as the secured party, am not reporting any claim of delinquency on myself ( obviously ). 
Your reporting of these accounts as charge-offs or past-due ignores the UCC record and the reality that the debts have been settled via a security interest exchange. This not only violates FCRA ( by reporting fundamentally inaccurate account status ) but also interferes with my rights under UCC law. Minnesotas adoption of the UCC ( Minn. Stat. 336.9-101 et seq. ) and Delawares UCC provisions both dictate that a perfected security interest puts the world on notice of the secured partys rights. By continuing to report the debt as owed to the original creditor ( and in default ), you are publishing information that is inconsistent with public records and derogatory to the secured partys interest.

I remind you that federal law ( 15 U.S.C. 1681s-2 ( b ) ) requires furnishers to update and correct information that is no longer accurate. Here, the furnishers ( original creditors ) have documentation of these UCC filings and should have instructed deletion ; if they failed to do so, both they and you are liable for willful FCRA violations.

The existence of a publicly filed UCC-1 Financing Statement is easily verifiable evidence that the debt status is disputed and transferred failing to consider or investigate that is a violation of your duty under 15 U.S.C. 1681i ( a ).

2.3 FCRA Violations by the Credit Bureaus and Furnishers The FCRA imposes strict duties on credit reporting agencies ( CRAs ) like Experian, XXXX, and XXXX, as well as on the furnishers of information ( the creditors ). Your handling of these accounts breaches multiple FCRA provisions : Failure to Assure Accuracy ( 15 U.S.C. 1681e ( b ) ) : Every time you prepare a consumer report, you must have reasonable procedures to assure maximum possible accuracy of the information. Reporting a debt as outstanding when it was canceled ( or continuing to report a charge-off with a balance that was forgiven ) is not accurate, let alone maximally accurate. The law requires you to do more than simply parrot whatever a furnisher sent in the past you must ensure the info remains current and correct. Given the ample notices and disputes I provided, your procedures ( or lack thereof ) have clearly failed this standard. This is a textbook violation of 1681e ( b ).

Failure to Reinvestigate and Delete ( 15 U.S.C. 1681i ) : When I disputed these accounts, you were obligated to conduct a reasonable reinvestigation. If information is found inaccurate or can not be verified, you must delete it from the file. In my case, either the information was not verified ( e.g., the creditor failed to prove the debt was still owed, especially in light of a 1099-C or UCC filing ), or the reinvestigation was not reasonable. In fact, the continued presence of these accounts indicates you willfully ignored the evidence. Notably, 1681i ( a ) ( 5 ) requires that disputed information that is inaccurate or unverifiable shall be promptly deleted from the credit file. Your refusal to delete is unlawful. Even worse, your own records ( as shown on my credit report ) indicate that some of these accounts were updated in response to my disputes rather than deleted an inadequate response since the only proper outcome was deletion, not an artificial update that left the derogatory mark in place.

Furnisher Duties ( 15 U.S.C. 1681s-2 ( b ) ) : After you received my dispute, you were required to notify the furnishers ( creditors ) within 5 business days ( which I believe you did ). Then each furnisher must investigate and report back to you the results, including correcting or deleting any information found to be inaccurate or unverifiable. If the furnisher confirms the info is inaccurate or can not verify it, they must instruct you to modify, delete, or permanently block the information ( 15 U.S.C. 1681s-2 ( b ) ( 1 ) ( E ) ) .Either the furnishers failed to do their job or you failed to implement their instructions, but either scenario is a violation : furnishers are liable under 1681s-2 ( b ) and you, the CRA, are liable under 1681e ( b ) and 1681i. The law even provides a fee-shifting provision for consumers to sue on these violations, which I will utilize if needed.

Failure to Mark Accounts as Disputed : Additionally, under 15 U.S.C. 1681i ( c ) and 1681s-2 ( a ) ( 3 ), any information under dispute must be noted as disputed in a consumers file if it is not deleted. My credit reports did not consistently show a dispute notation on these accounts after my disputes ( some show generic comments, others do not ). This is another FCRA violation failing to flag a disputed debt can itself give rise to liability ( its seen as furnishing incomplete information, which courts have held as actionable ).

Continuing to Report After Notice of Error : FCRA 1681s-2 ( a ) ( 1 ) ( B ) forbids a furnisher from reporting information after they have been notified of its inaccuracy, if it is in fact inaccurate. My disputes and provided documentation were such notice. Therefore, each month that the furnishers ( creditors ) allowed these tradelines to remain and update on my reports, they violated this section. While direct consumer enforcement of 1681s-2 ( a ) is limited ( primarily enforceable by regulators ), those violations underpin the willfulness of the 1681s-2 ( b ) and 1681i violations, strengthening my case for damages. Moreover, I reserve the right to report those furnishers to the CFPB and banking regulators for regulatory action.

In short, the FCRA has been violated on multiple counts. Your agencies have willfully reported inaccurate data and failed to correct it after disputes, and the furnishers have failed to conduct proper investigations or inform you of necessary deletions. The law provides for civil liability for willful noncompliance up to {$1000.00} in statutory damages per violation, plus actual damages and punitive damages ( 15 U.S.C. 1681n ). I have enumerated each month of false reporting as a separate violation below for damage calculation purposes.

2.4 Violations of Minnesota Law and Federal Regulations Your conduct also implicates state law and other federal rules : Minnesota Statutes Chapter 47 : Minnesota law ( Chapter 47, Financial Corporations ) reflects a strong policy against false reporting by financial entities. For example, Minn. Stat. 47.26 makes it a felony for any officer or agent of a corporation to willfully violate the law and continue such violation for over 10 days. Reporting patently false credit information about a Minnesota consumer and stubbornly refusing to correct it after repeated notice ( for months on end ), could be construed as the type of willful, continued violation that the state considers criminal. Whether or not a prosecutor pursues such charges, this statute underscores the seriousness of your misconduct.

Additionally, to the extent the furnishers are financial institutions, providing false information to credit bureaus may violate Minnesotas banking laws ( Chapter XXXX ) and could invite action from the Minnesota Department XXXX XXXX. I will be forwarding a complaint to state authorities to review whether your actions constitute any breach of Minnesota law or regulations ( including but not limited to any unfair or deceptive practice statutes or regulations on reporting obligations ).

12 C.F.R. CFPB Regulations ( Regulation V ) and OCC/FDIC Guidelines : Federal regulations require robust accuracy and integrity policies. The CFPBs Regulation V ( 12 C.F.R. 1022.42 and Appendix E ) obligates furnishers to establish internal controls to ensure the accuracy and integrity of furnished information. The continued reporting of these discharged debts indicates a failure of those controls. It suggests that either the furnishers did not properly update the status to the CRAs, or the CRAs ignored or mishandled the updates. Either way, regulatory guidelines were broken. Moreover, banking regulators ( OCC, FDIC, Federal Reserve ) have issued guidelines ( e.g. the Uniform Retail Credit Classification Policy ) requiring timely charge-off of delinquent debts ( generally at 180 days past due ) and cessation of accruing interest, etc. If after charge-off a bank chooses to cancel the debt ( often to claim a tax benefit or comply with XXXX rules ), that information must be accurately reflected. By failing to note the true status ( canceled ) on credit reports, the furnishers ( and you as their conduit ) are effectively publishing a false account of the banks own credit loss ( making it look as if the bank could still collect money which it has legally discharged ). This could even raise issues with 12 C.F.R. 621.5 ( for institutions governed by the XXXX XXXX XXXX ) which requires writing off uncollectible loans, or other agency-specific rules, by creating a discrepancy between the banks books and consumer credit reports.

31 C.F.R. Treasury Regulations : Title 31 of the Code of Federal Regulations contains the Federal Claims Collection Standards and other rules regarding debt collection. When a debt is conclusively deemed uncollectible ( as is the case with these accounts ), federal policy ( e.g. 31 C.F.R. 285 and 903 under the Debt Collection Improvement Act standards ) is to stop active collection and update records accordingly. In spirit, continuing to report a canceled debt as if owed is contrary to these federal standards. It also potentially mischaracterizes the debts legal status, which could be seen as an unfair collection practice if done to pressure payment on a nonexistent obligation. 
In summary, your actions are not only violating the FCRA but also undermine state law protections and regulatory frameworks designed to ensure truthful credit reporting and financial transparency. I will not hesitate to invoke all relevant laws in a court of law to hold you accountable. 
XXXX Federal Securities Law Considerations ( Exchange Act of XXXX ) XXXX, XXXX, and Experian ( through its parent company ) are publicly traded companies subject to the Securities Exchange Act of 1934. This means you file annual reports ( Form 10-K ) and other disclosures with the Securities and Exchange Commission ( SEC ) , and you are required to disclose material legal proceedings and risks. By engaging in systemic FCRA violations and accruing significant potential liabilities to consumers like myself, you XXXX also be violating SEC disclosure requirements if you fail to adequately disclose these issues to your shareholders. 
Notably, in Equifaxs most recent Form 10-K, the company acknowledged that the number of consumer lawsuits alleging FCRA violations have increased substantially over the past several years. This indicates that these bureaus are aware of widespread non-compliance problems. TransUnions filings likewise disclosed that the CFPB issued a NORA ( Notice and Opportunity to Respond and Advise ) letter alleging TransUnion violated FCRA dispute investigation requirements.

Such an allegation from the CFPB is serious ; if TransUnion ( or any bureau ) fails to correct known FCRA issues, it could lead to enforcement action or large fines clearly material information for investors.

If you continue to willfully flout the FCRA ( as in my case ) and do not disclose the scope of this non-compliance in your SEC filings, you could be engaging in securities fraud by omission. Rule 10b-5 under the 1934 Act prohibits making any untrue statement of a material fact or omitting to state a material fact necessary to make statements not misleading. By now, it is clear that your business faces material risks due to the way you handle consumer disputes and credit reporting accuracy ( the multitude of lawsuits and CFPB inquiries is evidence of that ). Should litigation arise from my case or others like it, or should regulatory fines hit, your investors would rightfully say : why wasnt this fully disclosed?

I put this in my demand letter to underscore that your legal troubles do not exist in a vacuum they affect your duties to regulators beyond the CFPB. I fully intend to submit copies of my complaints and any eventual lawsuit to the SECs enforcement division, so they can evaluate whether you have properly disclosed the legal and compliance risks related to your credit reporting practices. Equifaxs 10-K even warns that the CFPB can seek penalties of up to {>= $1,000,000} per day for knowing violations of consumer finance laws. Consider this letter as notice that your FCRA violations are knowing and willful if you choose to ignore this and not remediate, any resulting penalties ( at potentially {$1.00} million per day per violation ) will be on your heads and will certainly interest your investors and the SEC.

Bottom line : It is in your own corporate and shareholder interest, as well as your legal obligation, to delete the inaccurate information immediately. Continuing to report false data not only harms me, but exposes you to mounting liability and regulatory risk, which you can avoid ( or limit ) by doing what the law requires correcting the information now.

3. Inaccurate Accounts and Damage Calculations Below is a breakdown of each inaccurate account that remains on my credit reports, the period of wrongful reporting, and the statutory damages I will seek if this matter proceeds to litigation. Each month that an account was reported with false information after it should have been removed is counted as a separate FCRA violation ( 15 U.S.C. 1681n provides up to {$1000.00} per violation for willful noncompliance ). I will also seek punitive damages and attorneys fees as allowed. The damages calculation here is an estimate of FCRA statutory damages alone, which will be adjusted as necessary.

3.1 Experian Accounts to Delete and Liability The following accounts on my Experian credit file are inaccurately reported and must be deleted. Experian failed to remove these even after disputes, in violation of the FCRA. 
Creditor ( Account ) Account XXXX. Status on Experian Inaccuracy Period Months of Violation Damages ( XXXX XXXX XXXX ) XXXX XXXX ( XXXX Bank ) Credit Card # XXXX Charged-Off, {$5600.00} balance ( should be {$0.00} debt canceled ) file- XX/XX/XXXX XX/XX/XXXX ( reported as charge-off with balance ) 17 months {$17000.00} XXXX XXXX  ( Chase ) Credit Card # XXXX Charged-Off, {$6100.00} balance, {$4000.00} past due ( debt canceled; balance should be {$0.00} ) file- XX/XX/XXXX XX/XX/XXXX ( reported as charge-off/collection ) 14 months {$14000.00} XXXX Bank Credit Card # XXXX Charged-Off, {$2300.00} balance ( debt canceled XXXX XXXX XXXX XXXX show {$0.00} ) file- XX/XX/XXXX XX/XX/XXXX ( reported as charge-off with balance ) 14 months {$14000.00} XXXX XXXX XXXX XXXX Auto Loan # XXXX ( Opened XX/XX/XXXX ) Charged-Off Auto Loan, ~ {$40000.00} balance ( XXXX XXXX XXXX XXXX XXXX XXXX set-off should show paid as agreed or {$0.00} ) file- XX/XX/XXXX XX/XX/XXXX ( reported monthly as charge-off ) 13 months {$13000.00} Santander/Chrysler Capital Auto Lease # XXXX Charged-Off, {$3800.00} past due ( lease contract terminated, balance not owed ) file- XX/XX/XXXX XX/XX/XXXX ( reported as charge-off XXXX 3 months {$3000.00} XXXX XXXX XXXX XXXX Personal Loan # XXXX ( Opened XX/XX/XXXX ) Open, {$21000.00} balance, {$4200.00} past due ( inaccurate debt was subject to UCC lien, should not be reporting as past XXXX XXXX XXXX XX/XX/XXXX XX/XX/XXXX ( reported XXXX days late continuously ) 6 months {$6000.00} Experian Total Statutory Damages : {$68000.00} for XXXX violation-months XXXX XXXX punitive damages for willful conduct. 
Notes : Each listed account should have been deleted entirely. For example, the XXXX XXXX debt was canceled in XXXX, yet Experian continued to report it as a charge-off every month into XXXX. The XXXX XXXX accounts were subject to my XXXX agreement filings in XXXX, yet Experian did not remove them and even updated them as recently as XX/XX/XXXX, showing substantial delinquency. This demonstrates willfulness Experian had notice but chose to let the damaging, false information persist. 
XXXX XXXX Accounts to Delete and Liability The following accounts remain on my XXXX credit report with similar inaccuracies ( it is expected TransUnions data mirrors Experians, as the furnishers provided the same false information to all bureaus ). XXXX has likewise failed to delete these entries after my disputes. 
( If account details differ slightly on XXXX, they will be identified by the creditor and account number. The same rationale from XXXX table applies. ) Creditor ( Account ) Account XXXX. Status on XXXX Inaccuracy Period Months Damages ( @ $ XXXX ) XXXX XXXX ( XXXX Bank ) # XXXX Charged-Off, balance {$5600.00} ( debt canceled ) XX/XX/XXXX Feb 2025 17 {$17000.00} XXXX Card ( Chase ) # XXXX Charged-Off, balance {$6100.00} ( debt canceled ) XX/XX/XXXX Feb 2025 14 {$14000.00} XXXX Bank # XXXX Charged-Off, balance {$2300.00} ( debt canceled ) XX/XX/XXXX Feb 2025 14 {$14000.00} XXXX Federal XXXX Auto Loan # XXXX Charged-Off XXXX XXXX XXXX XXXX XXXX balance ( debt set-off ) XX/XX/XXXX Feb 2025 13 {$13000.00} Santander/Chrysler Cap Lease # XXXX Charged-Off Lease, ~ $ XXXX past XXXX XXXX XXXX XXXX XX/XX/XXXX XX/XX/XXXX XXXX {$3000.00} XXXX Federal XXXX Pers. Loan # XXXX Open, {$4200.00} past due ( should be {$0.00} ) XX/XX/XXXX XX/XX/XXXX XXXX {$6000.00} XXXX XXXX XXXX XXXX : {$67000.00} ( estimated ). 
Notes : XXXX was included in the same disputes and received the same evidence. It is equally liable for each month it continued reporting these accounts. Notably, TransUnions own records should reflect my disputes ( including any CFPB complaint I filed ). Its failure to correct or even mark the accounts as disputed demonstrates a reckless disregard of its duties. 
XXXX XXXX Accounts to Delete and XXXX The XXXX credit report also contains these erroneous accounts. XXXX liability is calculated similarly : XXXX ( Account ) Account XXXX. Status on XXXX Inaccuracy Period Months Damages ( @ $ XXXX ) XXXX XXXX ( XXXX XXXX  ) # XXXX Charged Off, {$5600.00} balance ( canceled debt ) XX/XX/XXXX Feb 2025 17 {$17000.00} XXXX XXXX  ( Chase ) # XXXX Charged Off, {$6100.00} balance ( canceled debt ) XX/XX/XXXXXXXX XXXX XXXX XXXX {$14000.00} XXXX XXXX  # XXXX Charged Off, {$2300.00} balance ( canceled debt ) XX/XX/XXXX Feb 2025 14 {$14000.00} XXXXXXXX XXXX XXXX  XXXX XXXX XXXX XXXX Charged-Off Auto, ~ $ XXXX balance ( set-off ) XX/XX/XXXXXXXX XXXX XXXX XXXX  {$13000.00} XXXX XXXX Lease # XXXX Charged-Off XXXX XXXX XXXX XXXX XXXX past due ( not owed ) XX/XX/XXXX XX/XX/XXXX XXXX {$3000.00} XXXX XXXX XXXX XXXX XXXX XXXX  XXXX Open, past due {$4200.00} ( inaccurate, not owed ) XX/XX/XXXX XX/XX/XXXX XXXX {$6000.00} XXXX XXXX XXXX XXXX : {$67000.00} ( estimated ). 
Notes : XXXX has historically had issues with credit report accuracy ( as its risk disclosures concede and it appears the same pattern occurred here. All three bureaus are expected to coordinate deletion once one confirms an error, yet in my case none took proper action thus all three face parallel liability. 
XXXX XXXX ( All Bureaus ) : {$200000.00} in preliminary statutory damages ( Experian $ XXXX + XXXX $ XXXX + XXXX $ XXXX ), plus any actual damages to my credit and emotional distress ( to be determined ) and punitive damages for willful FCRA violations. These figures far exceed the threshold for federal litigation, and I will seek the maximum allowed, including possibly class-action remedies if applicable ( noting that the patterns here XXXX affect many consumers ). 
I highlight these amounts to make clear that ignoring my rightful demands could prove extremely costly to your companies. And these are per consumer ; regulators can and do seek even higher penalties ( as noted, CFPB can fine up to {$1.00} XXXX per day per violation, which could theoretically dwarf my private claim ). This is entirely avoidable if you simply do what the law requires now. 






Demand for Immediate Action I hereby demand the following relief from each Credit Bureau, to be completed within XXXX calendar days of receipt of this letter : XXXX. Permanent Deletion of Listed Accounts : Remove in their entirety the above-referenced accounts from my credit file. This means deleting the trade line, not just changing the status to paid or disputed. The only acceptable outcome under law is deletion, given the circumstances ( 15 U.S.C. 1681i ( a ) ( 5 ) ( A ) ). No reinsertion is permitted unless verified by new certified information, and you must notify me if any reinsertion is attemp

ted ( 15 U.S.C. 1681i ( a ) ( 5 ) ( B ) ). However, since the facts show these accounts are not verifiable and not owed, they should not ever be reinserted.

2. Written Confirmation : Provide written confirmation on your company letterhead that each disputed account has been deleted due to inaccuracies. Pursuant to 15 U.S.C. 1681i ( a ) ( 6 ) and ( 8 ), you must send me notice of the results of my dispute and a copy of my revised credit report showing the deletions within 5 business days. I expect this confirmation by email and mail given the urgency.

3. Cease Reporting to Others : Ensure that these accounts are deleted across all your reporting and no longer provided to any third parties. Additionally, notify any other consumer reporting agency to which you furnish data ( if any, such as secondary bureaus or resellers ) of the deletions, as required by law ( furnishers must update all CRAs, and CRAs should communicate results under 1681i ( a ) ( 5 ) ( D ) ). This includes updating any data you have shared with insurance scoring companies, tenant screening, or employment screening companies that might have obtained my report with these erroneous entries. 
XXXX. Damages and Compensation ( Reservation ) : While deletion is necessary, I also demand that you preserve all records related to these accounts and my disputes, as I am evaluating further legal action for the harm already caused. My XXXX XXXX and opportunities have suffered due to your reporting of false delinquencies ( for instance, I have been denied credit and faced higher interest rates, which are provable actual damages ). I XXXX seek monetary compensation in addition to the statutory damages outlined if we proceed to court. This letter is not an offer to settle my damages claim ; it is a demand for compliance. If you wish to discuss a broader settlement ( including monetary relief to avoid a lawsuit ), you XXXX contact me in writing with an offer after you have deleted the accounts and provided proof. 
XXXX. Refrain from Retaliation or Secondary Reporting : Do not, under any circumstances, reinsert these items or replace them with any coded notation that could indirectly harm my credit ( such as labeling them as consumer disagrees or some obscure code ). The only correct action is a clean deletion. Also, do not sell or transfer information about these disputed debts to any third-party debt XXXX or data aggregators if any such activity is detected, it will be met with additional legal action for breach of the FCRA and XXXX the FDCPA if applicable. 
Response Deadline 5 Days : XXXX is of the essence. You have XXXX calendar days from receipt of this notice to complete the deletions and confirm in writing. This timeline is reasonable and in fact slightly more lenient than FCRAs own dispute timeline in cases where the information is obviously wrong or unverifiable. Given that you have had months of prior notice through my disputes, and that I have now provided a detailed legal rationale, you should need no additional time to investigate. Any delay beyond 5 days will be considered further willful non-compliance. If by the end of the XXXX day I do not have written confirmation of deletion from each of you, I will proceed with the following without further notice : File a lawsuit against each of you for violations of the FCRA ( and any other applicable laws, such as defamation and Minnesota state law ). I will seek the full $ XXXX in damages itemized above, plus attorneys fees and punitive damages. 
I will also seek injunctive relief as appropriate. Be advised that courts have awarded significant punitive damages in cases of willful FCRA violations where agencies ignored multiple dispute notices. Your conduct here is egregious and meets the standard for willfulness ( especially after this letter puts you on clear notice ). Each bureau will be sued in federal court ( with venue in my district ). 
File regulatory complaints : I will file formal complaints with the Consumer Financial Protection Bureau, the Federal Trade Commission, my states Attorney General, the Minnesota Department of Commerce, and any other relevant oversight body. These complaints 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