Consumer complaint received 2025-05-04 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Account information incorrect
Company: CLGF Holdco 1, LLC
State: MI

Complaint narrative:
This is a formal complaint against XXXX XXXXXXXX XXXX and Concora Credit Inc. for 26 violations of federal consumer protection laws, including the Fair Credit Reporting Act ( FCRA ), the Fair Debt Collection Practices Act ( FDCPA ), and Unfair, Deceptive, or Abusive Acts or Practices ( UDAAP ) under the Dodd-Frank Act. These violations include false and premature credit reporting, abusive fee structuring, deceptive add-on services, and failure to respond to lawful disputes. 

Despite submitting XXXX formal disputes, most recently through the CFPB on XX/XX/XXXX, I received no meaningful response, while derogatory reporting and fee accumulation continued. Most egregiously, I have already been reported XXXX days late for XX/XX/XXXX, despite the payment not being due until XX/XX/XXXX, XXXX clear factual and legal impossibility. 

I. FCRA Violations 1. FCRA 623 ( a ) ( XXXX ) Reporting delinquency during an unresolved dispute Evidence : I submitted a formal dispute via CFPB on XX/XX/XXXX. Despite that, my XX/XX/XXXX credit report from XXXX XXXXhows a XXXX late markviolating both the FCRA and the banks own billing statement, which says we may not report you as delinquent if you properly notify us of a dispute. 

2. FCRA XXXX ( a ) ( XXXX ) Inaccurate reporting of delinquency timing Evidence : My XXXX payment was not due until XX/XX/XXXXXXXX Yet XXXX XXXX XXXX XXXX all reported me XXXX days late as of early XXXX, before delinquency could have legally occurred. 

3. FCRA 623 ( a ) ( 8 ) Failing to conduct a reasonable investigation Evidence : I submitted multiple disputes ( including via CFPB ), yet derogatory marks continued and no investigation findings, updates, or responses were sent to me. 

4. FCRA 607 ( b ) & 623 ( a ) ( 1 ) ( A ) Contradictory and inconsistent reporting Evidence : XXXX : {$94.00} past due XXXX  : 30 days late XXXX : XXXX payments past due This inconsistency shows that data furnished to each bureau was inaccurate or incomplete.

5. FCRA 623 ( a ) ( 5 ) Re-aging of delinquency Evidence : The account reflects 30 days late in consecutive months even after partial or full payments. This restarts the delinquency timeline unfairly. 

6. FCRA 611 Failure to correct inaccurate information after dispute Evidence : Despite my XX/XX/XXXX dispute, the tradeline was updated with a new 30-day late entry in May. No correction or notice of resolution was provided. 

7. FCRA 609 ( a ) ( XXXX ) Failure to identify responsible parties Evidence : The account appears under multiple names : XXXX XXXXXXXX XXXX  Concora Credit IncXXXX, XXXX XXXX and XXXX XXXX. This obscures who furnishes and services the data, frustrating proper dispute handling. 

8. FCRA 623 ( a ) ( 2 ) Failure to update information known to be inaccurate Evidence : Even after providing payment screenshots and dispute details, the XXXX late mark remainedand no correction or explanation was ever made. 

II. UDAAP Violations 9. UDAAP Excessive and manipulative fee stacking Evidence : XX/XX/XXXX : {$74.00} in fees despite a {$95.00} payment XX/XX/XXXX : {$130.00} in fees despite no purchases Total fees over XXXX XXXX : {$200.00}, with interest compoundingno clear way to bring account current. 

10. UDAAP Charging for credit protection with no delivered protection Evidence : Charged {$14.00} ( XXXX ) and {$14.00} ( XXXX ) for credit protection Received no hardship support, no claim process, and no benefit activation. 

11. UDAAP Charging for over-limit coverage with no actual coverage Evidence : Monthly over-limit fees assessed without documentation or disclosure of how the service functions No opt-out available ; no actual benefit received. 

12. UDAAP Misleading marketing of add-on protection products Evidence : I was charged protection fees monthly but never received the benefit those products claimed to offer. 

13. UDAAP  Automatically recurring charges without reauthorization Evidence : Protection and over-limit fees were applied every month without active consent, updated disclosures, or the ability to opt out. 

14. UDAAP Abusive repayment structure designed to keep account delinquent Evidence : Each payment is instantly negated by fees, making it mathematically impossible to restore the account to currenteven after overpaying. 

15. UDAAP Artificial inflation of minimum payment amount Evidence : Standard minimum is {$44.00} XX/XX/XXXX : paid {$95.00} Yet minimum due ballooned to {$160.00} due to stacked fees. 

16. UDAAP Inflating balance solely through fees, not purchases Evidence : My balance increased from {$1000.00} to {$1000.00} from XXXX to XXXX with no purchasesonly from protection, interest, and penalty fees. 

17. UDAAP Fee  escalation in response to missed/partial payments Evidence : Minimal fees in XXXX and XX/XX/XXXX ; sudden spike to {$74.00} in XXXX and {$130.00} in XX/XX/XXXX after hardshipthis appears retaliatory. 

18. UDAAP Fee structure disproportionately penalizes low-income consumers Evidence : The product targets credit rebuilders, yet makes it financially impossible to avoid delinquency, keeping users trapped in subprime status. 

19. UDAAP Obscuring creditor/servicer responsibilities Evidence : I could not tell who was responsible for disputes due to conflicting names on statements, credit reports, and billing portals. 

20. UDAAP Billing model actively undermines repayment Evidence : My payments were consumed by service fees, over-limit fees, and interestnone applied to principal or delinquency cure. 

21. UDAAP  Failure to disclose protections promised in marketing Evidence : Credit protection was promoted but never defined, explained, or activated in response to financial hardship. 

22. UDAAP No mechanism to trigger hardship assistance despite fee Evidence : There is no phone number, form, or documentation explaining how to file a protection claimrendering the service deceptive.

23. UDAAP Lack of transparency on fee assessment Evidence : Statements offer no clear breakdown of why certain fees vary or are applied. Charges change arbitrarily from month to month.

24. UDAAP Abusive billing timeline manipulation Evidence : Delinquency was reported before payment due dates. XX/XX/XXXX was marked late before XXXX XXXXthe actual due datehad even passed. 

III. FDCPA Violations 25. FDCPA 807 False or misleading representation of debt Evidence : Account statements include the phrase this is an attempt to collect a debt, even though the account is open and revolving. This falsely suggests the debt has been charged off or sold. 

26. FDCPA 808 Using unfair or unconscionable means to collect a debt Evidence : Continued monthly penalties, artificial delinquency, and false status updates are all part of a scheme to generate revenue through delinquencynot resolve debt. 


1. Specific Regulatory Citations for Add-On Products The CFPB has issued multiple enforcement actions against financial institutions for deceptive marketing and billing of optional add-on products ( e.g., credit protection, payment protection ) that failed to deliver promised benefits. My experience mirrors those patterns. See : CFPB v. XXXX XXXXXXXX XXXX ( XXXX ), CFPB v. XXXX ( XXXX ). 

This account structure and fee model reflect systemic misconduct that has already triggered prior CFPB enforcement actions, including : CFPB XXXX XXXX XXXXXXXX XXXX  ( XXXX ) deceptive credit card add-on products CFPB XXXX XXXX ( XXXX ) failure to provide promised benefits from protection services CFPB XXXX XXXX furnisher responsibility under FCRA to report accurate XXXX timely, and complete information My experience matches these patterns. Monthly protection fees are charged but no protection is provided. Over-limit coverage offers no value or opt-out. Minimum payments are artificially inflated through fee-stacking, leaving accounts falsely delinquent. 

2. Credit Harm and Denial Impact Statement I was denied pre-approval for a vehicle loan in XX/XX/XXXX due to derogatory reporting from this account. 
My credit score has dropped over XXXX points during the ongoing dispute. 
Ive had to delay critical financial planning ( e.g., housing or refinancing options ) as a direct result of these false and unresolved reports. 

3. Request for Penalties or Supervisory Oversight I request that this complaint not only result in individual account correction, but also in broader regulatory oversight of this creditors billing, servicing, and credit furnishing practices. They appear to be engaging in a pattern of behavior likely affecting thousands of subprime consumers. 

Preemptive Rebuttal to Anticipated Responses To date, no meaningful response has been received from XXXX XXXXXXXX XXXX  or Concora Credit Inc. to the CFPB complaints I submitted on or after XX/XX/XXXX, in violation of FCRA 623 ( a ) ( 8 ). However, I am proactively responding to common excuses these companies may offer in an attempt to evade accountability : 1. All fees were disclosed in the cardholder agreement. 
Rebuttal : Disclosure does not exempt a creditor from UDAAP liability. A disclosed fee structure can still be abusive if used to manipulate balances, erase payments, and disproportionately penalize consumers. Their billing model traps cardholders in continuous delinquency even after good-faith payments. 

2. Delinquency reporting was accurate and based on due dates. 
Rebuttal : My XX/XX/XXXX payment was not due until XX/XX/XXXX, yet the account was reported as 30 days late in early Maybefore delinquency could have occurred. That is objectively false and violates FCRA 623 ( a ) ( 5 ). 

3. Credit protection and over-limit services are optional. 
Rebuttal : These services were charged monthly with no benefit provided, no claims process, no hardship relief, and no documentation outlining activation procedures. Charging for a service that does nothing is deceptive. If they are optional, I was never given a way to opt out, and I was never informed about how they worked. 

XXXX. The account is not in collections, so FDCPA doesnt apply. 
Rebuttal : Monthly statements contain the language : This is an attempt to collect a debt. That triggers FDCPA obligationseven if collection is in-house. A creditor can not use collection language to pressure payment and then disclaim FDCPA coverage. 

XXXX. Inconsistencies are caused by the credit bureaus. 
Rebuttal : FCRA 623 ( a ) ( 1 ) ( A ) and 623 ( a ) ( 8 ) clearly state that furnishers are responsible for reporting accurate and consistent information. I provided screenshots showing materially different data across XXXX XXXX XXXX XXXX 

6. Consumer failed to pay on time. 
Rebuttal : I paid {$140.00} in XXXX and {$95.00} in XXXX, both exceeding the XXXX XXXX monthly minimum. Yet the account is still reported as past due due to manipulated minimum payments and aggressive fee stacking. Their system erases all progresseven after overpayments. 

7. We responded to prior CFPB complaints. 
Rebuttal : That is false. I received no formal response to either of my CFPB complaints. Any response received now would come only after additional damage and repeated complaints. 

8. You didnt properly notify us of a dispute. 
Rebuttal : I submitted my dispute via CFPB on XX/XX/XXXX, which constitutes formal notice. Additionally, their own billing statements acknowledge that delinquency can not be reported while a dispute is unresolved. If they now claim a different process was required, they failed to provide or disclose that process clearlywhich is a violation in itself under FCRA and UDAAP. 

9. Account naming differences are harmless. 
Rebuttal : The account is reported under multiple inconsistent namesXXXX XXXXXXXX XXXX XXXX XXXX XXXX Concora Credit Inc.which frustrates the dispute process and obscures liability. FCRA 609 and 611 require furnishers to be identifiable and traceable. 

Remedies Requested : Immediate and permanent correction of all inaccurate credit reporting Deletion of all XXXX late notations during active dispute periods Refund of all improperly assessed fees ( especially credit protection and overlimit charges ) Removal of all fee-driven delinquency notations and re-aging Formal acknowledgment of FCRA and UDAAP violations Full investigation with human-led reinvestigation and supporting documentation Civil penalties and regulatory enforcement as warranted

Company response to consumer: Closed with explanation