Consumer complaint received 2025-08-13 00:00:00
Product: Debt collection — Medical debt
Issue: Threatened to contact someone or share information improperly — Talked to a third-party about your debt
Company: W&A Intermediate Co., LLC
State: OR

Complaint narrative:
Failure to Comply with FCRA 1681t ( a ), SB 605, SB 619, and the Oregon Unlawful Trade Practices Act ( UTPA ) To Whom It May Concern, This correspondence serves as formal notice of non-compliance regarding your failure to uphold obligations under 15 U.S. Code 1681t ( a ) of the Fair Credit Reporting Act ( FCRA ), in conjunction with Oregon SB 605, SB 619, and the Oregon Unlawful Trade Practices Act ( ORS 646.608 ).

________________________________________ FEDERAL PREEMPTION FCRA 1681t ( a ) Under 1681t ( a ) : " Except as provided in subsections ( b ) and ( c ), this subchapter does not annul, alter, affect, or exempt any person subject to the provisions of this subchapter from complying with the laws of any State with respect to the collection, distribution, or use of any information on consumers, or for the prevention or mitigation of identity theft. '' This section makes clear that state laws offering greater protection to consumers are not preempted by the FCRA. Oregons SB 605 and SB 619 meet and exceed these protections.

________________________________________ SB 605 ( XXXX  ) MEDICAL DEBT PROHIBITION ORS 646A.677 ( as amended by SB 605 ) prohibits debt collectors and CRAs from reporting or collecting medical debt owed by Oregon residents.

SB 605, now enrolled as Chapter 343, Oregon Laws XXXX, explicitly bans credit reporting of medical debt for Oregon residents, effective XX/XX/XXXX. 
Refusal to honor removal requests prior to this date violates the spirit and intent of the law, particularly when good-faith deletion requests have been made and documented. 
________________________________________ SB 619 ( 2023 ) CONSUMER PRIVACY RIGHTS ACT ORS 646A.406646A.414 grant Oregon residents the right to request deletion of personal data, including collection accounts.

Under ORS 646A.410, companies must respond without undue delay and within 45 days to deletion requests. Extensions require written justification, which has not been provided.

________________________________________ OREGON UNLAWFUL TRADE PRACTICES ACT ( UTPA ) ORS 646.608 ( 1 ) ( u ) defines it as an unlawful trade practice to fail to comply with state consumer protection laws or misrepresent a consumers legal rights.

ORS 646.638 authorizes private actions for damages against any company engaging in deceptive trade practices, which includes the continued reporting of unlawful or unenforceable debts.

________________________________________ FAILURE TO ACT IS NON-COMPLIANCE Despite receiving valid legal requests and all supporting documentation including proof of Oregon residency, copies of SB 605, and SB 619 all three credit reporting agencies have delayed or refused to comply.

I should not have to escalate to the : Consumer Financial Protection Bureau ( CFPB ) Oregon Attorney Generals Office ( OAG ) Federal Trade Commission ( FTC ) just to have these organizations perform their basic legal duties.

________________________________________ FINAL DEMAND You are hereby instructed to : 1. Immediately delete all medical debt tradelines on my file.

2. Confirm compliance in writing within 15 days.

3. Cease all deceptive practices or delay tactics under the UTPA.

Failure to comply will result in formal complaints, regulatory escalation, and pursuit of civil damages under FCRA 1681n, ORS 646A.410, and ORS 646.638.

Company response to consumer: Closed with non-monetary relief