Consumer complaint received 2025-11-02 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: CCS Financial Services, Inc.
State: CA

Complaint narrative:
I dispute a collection tradeline that XXXX XXXX is furnishing to XXXX  ( and through XXXX  to other CRAs ). The account was paid on XX/XX/XXXX, yet the tradeline shows a new Status/Report Date of XX/XX/XXXX, indicating a re-reporting / reinsertion or refresh. I never authorized re-reporting of a paid debt that would re-age or otherwise injure my credit. I have an active dispute with XXXX  ( filed online on XXXX ) and have demanded validation and documentation from XXXX XXXX. XXXX XXXX ( the furnisher ) has failed to : ( a ) validate the debt with original-source documents ; ( b ) provide chain-of-assignment or authority from the original creditor ( XXXX ) ; ( c ) explain or produce any reinsertion certification or consumer notice that would lawfully justify re-reporting a paid debt after deletion ; and ( d ) cease reporting this tradeline pending validation ( e ) provide proof they have legal jurisdiction to collect debts in Orange County/California. This information must be furnished in this forum as well as XXXX  and deleted immediately if this information isn't furnished in the time accorded by law. 

FACTS ( TIMELINE ) XX/XX/XXXX Date of First Delinquency ( DOFD ) shown on tradeline. 
XX/XX/XXXX Date Assigned to collector ( shown on tradeline ). 
XX/XX/XXXX Last Payment Date ( shown on tradeline ) ; tradeline shows balance {$0.00} ( PAID ). 
XX/XX/XXXX Status Date / Date Reported updated on XXXX  ( tradeline shows refreshed status ). 
XX/XX/XXXX I filed an online dispute with XXXX  ( screenshot attached ). 
XXXX I sent a ( XXXX ) certified validation/documentation demand to XXXX XXXX ( copy attached ) requesting original-source proof, assignment, DOFD documentation, and proof of any reinsertion certification and/or notice ( if reinserted ). No adequate substantiation has been produced. 

WHY I AM COMPLAINING LEGAL & REGULATORY GROUNDS I am requesting CFPB investigation and enforcement because XXXX XXXX conduct violates the FCRA, FDCPA, and CFPB/FTC guidance and Regulation F in the following ways : 1. Furnisher duties Failure to investigate and verify disputes ( FCRA 623 ( b ), 15 U.S.C. 1681s-2 ( b ) ) Once a CRA ( XXXX ) forwarded my dispute, XXXX XXXX had an affirmative duty to investigate, review all relevant information, and report the results back to the CRA. Furnishers must provide complete and accurate information or instruct the CRA to delete the tradeline if they can not substantiate the debt with original-source documentation ( see 15 U.S.C. 1681s-2 ( b ) ). XXXX XXXX has not produced original-source evidence of the debt ( original creditor agreement/policy, itemized ledger, or chain of assignment ). 

2. Reinsertion / re-reporting violations FCRA 611 ( a ) ( 5 ) ( B ), 15 U.S.C. 1681i ( a ) ( 5 ) ( B ) If an item was deleted, aged out, or otherwise previously removed, the furnisher must certify in writing the accuracy of the information prior to reinsertion, and the CRA must provide the consumer written notice within five business days of reinsertion. The fresh status date of XX/XX/XXXX for a debt paid XX/XX/XXXX indicates re-reporting or re-insertion without any written notice to me. Failure to produce reinsertion certification and proof of notice violates 611 ( a ) ( 5 ) ( B ). 

Cases supporting the reinsertion theory and requirement for meaningful verification include : XXXX XXXX XXXX, XXXX, XXXX XXXX XXXX ( XXXX XXXX XXXX ) ( reinsertion without proper verification/certification violates FCRA ) ; XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX. XXXX. ) ( re-reporting deleted items without notice violates 611 ).

3. Failure to ensure maximum possible accuracy FCRA 607 ( b ) / 1681e ( b ) Furnishers must not provide information to CRAs that they know or have reason to believe is inaccurate or incomplete. Continued reporting of a paid, small-dollar debt without original-source corroboration, with a refreshed status date, is misleading and violates the accuracy requirement. See : XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) ; XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ). 

4. FDCPA validation and deceptive reporting failures 15 U.S.C. 1692g ( b ) ; 1692e ( 8 ) Under FDCPA 809 ( b ) ( 15 U.S.C. 1692g ( b ) ), upon a timely dispute a debt collector must provide verification of the debt. Continued furnishing of disputed information, or failure to flag the tradeline as disputed in the furnishers reporting, violates FDCPA provisions including 15 U.S.C. 1692e ( 8 ) ( furnishing to CRA an item known to be disputed ) and 1692g obligations. Additionally, CFPB Regulation F ( 12 C.F.R. 1006.34 ) reinforces modern validation standards. 

5. Re-aging / Date of First Delinquency manipulation FCRA 605 ( c ) and 623 ( a ) ( 5 ) Re-aging a debt ( altering the DOFD or otherwise creating a later reporting date ) to extend the time an item can be reported is impermissible under FCRA. A furnisher must be able to produce documentation from the original creditor establishing the DOFD ; absent such documentation, continued reporting or alteration is unlawful. 

6. Potential willful and negligent violations 15 U.S.C. 1681n & 1681o If XXXX XXXX knowingly or recklessly furnished inaccurate information or reinserted a deleted item without certification and notice, it is liable for willful or negligent violations under 616617 ( civil liability in 1681n & 1681o ), including statutory damages, actual damages, punitive damages, and attorney fees. 

AUTHORITIES & LEADING CASES ( for CFPB reference ) Statutes and regulations : Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., including : 607 ( b ) / 1681e ( b ) ( maximum possible accuracy ) 611 ( a ) / 1681i ( reinvestigation ; reinsertion ; method of verification requirements ) 623 ( b ) / 1681s-2 ( b ) ( furnisher duties upon notice of dispute from CRA ) 605 / 1681c ( reporting time limits ; DOFD rules ) Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692 et seq., including : 809 ( b ) / 1692g ( b ) ( validation on dispute ) 807 / 1692e ( false or misleading representations ; furnishing disputed information ) CFPB Regulation F ( 12 C.F.R. 1006.34 ) validation and dispute handling guidance. 

FTC and CFPB consumer-reporting guidance and enforcement precedent on reinsertion and vendor reliance. 

Representative case law : XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) CRA duties ; no parroting furnisher. 

XXXX v. XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) reinvestigation standards. 

XXXX XXXX XXXX, XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) reinsertion and vendor verification issues. 

XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) vendor reliance and accuracy duties. 

XXXX v. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  XXXX ) deletion required if verification lacking. 

XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX ) accuracy and database reliance contexts. 
( These cases are representative of judicial treatment of reinvestigation, reinsertion, and vendor reliance issues under the FCRA and are cited to show the legal landscape CFPB enforcement should consider. ) WHAT I REQUEST CFPB TO DO ( REMEDY & RELIEF ) Investigate XXXX XXXX for : a. Failure to validate/verify the debt with original-source documentation ( original creditor records from XXXX Specialty California ) XXXX 
b. Failure to perform required investigation and to timely instruct CRAs to delete unverified information after notice. 
c. Improper reinsertion/re-reporting of previously paid/deleted tradeline absent furnisher certification and consumer notice under FCRA 611 ( a ) ( 5 ) ( B ).

d. Potential FDCPA violations related to failure to validate and furnishing disputed data. 

Require XXXX XXXX to produce and provide to me and to the CFPB the following documentation : a. Complete account ledger and original creditor account documentation showing how the {$93.00} debt was incurred ; b. Chain of assignment or bill of sale showing XXXX XXXX authority to collect and to furnish the account ; XXXX The original-source proof the furnisher furnished to Equifax supporting DOFD XXXX XX/XX/XXXX ; d. Any reinsertion certification and proof of written consumer notice required by 611 ( a ) ( 5 ) ( B ) if the tradeline was reinserted or refreshed after deletion ; e. All communications XXXX XXXX claims to have sent me ( validation letters, notices ) with dates and delivery method. 

Order immediate deletion of the tradeline from Equifax and any other CRA if XXXX XXXX can not produce the required original-source documentation and reinsertion proofs. If deletion has already occurred and the item was later reinserted improperly, order permanent deletion and corrective notices to all affected CRAs. 

Require XXXX XXXX to certify to CFPB and to me, within 30 days, that they have corrected their reporting practices and will cease furnishing unverified or improperly reinserted items. If CFPB finds willful violations, pursue appropriate enforcement remedies including civil penalties. 

Provide me an investigation report and closure letter describing findings and remedies. 

DAMAGES & POTENTIAL CONSUMER HARM The tradelines refreshed status date ( XX/XX/XXXX ) has or will continue to cause financial and emotional harm : reduced credit scores, denial or higher cost of credit, lost opportunities, and increased anxiety and time spent to resolve the matter. I reserve the right to pursue statutory and actual damages under FCRA, FDCPA, and state consumer protection laws. 

EXHIBITS/ DOCUMENTS ATTACHED Screenshot of XXXX  tradeline showing XXXX XXXX XXXX XXXX XXXX California ( showing DOFD, last payment, Status Date XX/XX/XXXX ). 

Proof of online dispute filed with XXXX  ( screenshot of dispute confirmation ). 

Copy of the validation/documentation demand letter I sent to XXXX XXXX XXXX certified-mail receipt if available ). 

Any correspondence or responses received from XXXX XXXX ( none to date / copy of insufficient response if received ). 

Government-issued photo ID and proof of address ( to verify identity in connection with the disputed tradeline ). 

Timeline notes ( dates of dispute, letters sent ). 

SUMMARY STATEMENT / CERTIFICATION I certify that I did not authorize any re-reporting that would extend the impact of a paid account nor did I receive any reinsertion notice as required by law. I request CFPB assistance to investigate and to require deletion if XXXX XXXX can not substantiate the furnisher claims with original-source documentation and proper reinsertion certification. 

Thank you for your timely attention to this matter.

Company public response: Company believes it acted appropriately as authorized by contract or law
Company response to consumer: Closed with explanation