Consumer complaint received 2025-05-24 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: CLGF Holdco 1, LLC
State: MI

Complaint narrative:
Follow-up to XX/XX/XXXX & XX/XX/year> response Destiny Card account reported by First Electronic Bank / Concora Credit Inc .

This is a formal follow-up to the XX/XX/year> response issued by First Electronic Bank ( FEB ) and its servicing agent, Concora Credit Inc. ( CCI ) , regarding the Destiny Card account currently reporting on my XXXX XXXX XXXX credit reports. 

Despite multiple disputes and documentation, the investigation failed to resolve serious issues concerning ownership transparency, billing practices, and inaccurate credit reporting. I am requesting regulatory review and full removal or correction of the tradeline. 

1. Ownership and Furnishing Authority Are Still Unverified My credit reports list the account as FEB DESTINY/CCI, but all billing statements, the cardholder agreement, and payment instructions come solely from Concora Credit Inc.not First Electronic Bank . In their XX/XX/year> response, FEB confirmed that Concora is the servicer, but failed to provide : Proof of current ownership A chain of title or servicing agreement Documentation verifying that either party is legally authorized to furnish credit data First Electronic Banks letter states : We are happy to confirm what was furnished, and my billing statement promises : Once we receive this information, we will investigate promptly and respond with our findings. I complied with those instructions, yet no supporting documents were provided. 

Additionally, my billing statement includes a debt collection disclosure from Concora Credit Inc., with their California Collection Agency License listed. This presents a conflict : the account is listed as open on my credit report, yet the entity managing it operates under debt collection rules and language. If the account is open and current with FEB, why is Concora involved as a licensed collector? If Concora is the true servicer or owner, why havent they validated their furnishing rights?

This lack of transparency directly violates : FCRA 623 ( a ) Incomplete and unverifiable reporting FDCPA 809 Failure to disclose the true creditor or validate the debt UDAAP For deceptive servicing and
misrepresentation of account status 2. Excessive and Abusive Fee Practices As of XX/XX/year>, the account shows a balance of {$1100.00} despite a {$700.00} credit limit. In XXXX alone, I was charged : {$340.00} in fees {$130.00} in interest Additional amounts for monthly maintenance, late fees, and credit protection I was never provided with a clear, itemized accounting of how these fees were calculated or justified. The account has remained over the limit for months while charges continued. Their own correspondence acknowledges an overlimit fee was assessedand later refunded as a courtesywithout addressing the legal basis for such fees on a past-due account. 

These practices violate the CARD Act and UDAAP standards by allowing post-delinquency fees to accumulate without consumer disclosure, consent, or clarity.

3. Misleading and Inaccurate Credit Reporting My credit
report shows : Status : Open. {$94.00} past due as of XX/XX/year> Last payment date : XX/XX/year> Balance updates reported through XX/XX/year> FEBs letter claims they havent furnished data to the bureaus for May, but my XXXX  report says otherwise. Meanwhile, XXXX also shows updated derogatory status, despite my dispute. 

My billing statements Credit Bureau Reporting section acknowledges they report to credit bureaus, and instructs disputes be submitted in writing. I followed those steps, yet the dispute was marked resolved without any documentation returned. 

Additionally, I question how XXXX XXXX XXXX have verified this account as accurate when neither furnisherFirst Electronic Bank nor Concora Credit Inc.has produced any chain of title, assignment documentation, or proof of legal ownership or furnishing authority.

Under FCRA 611 ( a ) ( 5 ) ( A ), credit reporting agencies must delete or modify any information that can not be verified during a reinvestigation. If no validation of ownership or servicing rights has been presented, the bureaus have no legal basis to continue labeling this tradeline as accurately verified. 

Failure by XXXX XXXX XXXX to Identify or Verify the Actual Furnisher This section is directed specifically to XXXX XXXX XXXX both of whom have reported the Destiny Card account as FEB DESTINY/CCI and marked my disputes as verified as accurate.

However, under FCRA 611 ( a ) ( 7 ), I am entitled to receive a clear disclosure of the method of verification, including the name and contact information of the party that verified the account. Neither bureau has provided that. Instead, they continue to rely on a response from an ambiguous furnisher that combines three separate entities : First Electronic Bank the original issuing bank Concora Credit Inc. the servicer and payment processor Destiny a brand name with no legal furnishing authority How is it possible for XXXX XXXX XXXX  to claim this account was verified if they can not confirm who the rightful owner is and did not receive or provide a chain of title or assignment?

Simply stating that the furnisher verified it is not legally sufficient under the FCRA when the identity of the furnisher itself is in question.

If Concora Credit Inc. furnished or verified the data, the credit bureaus must disclose that. If First Electronic Bank furnished it, they must validate their continued ownership. If neither has provided a chain of title or documented servicing agreement, then this account can not be legally verified and must be removed.

By continuing to report an account where the furnishing authority is unclear, and by failing to disclose the verification method or responsible entity, XXXX XXXX XXXX are in direct violation of FCRA 611 ( a ) ( 5 ) and 611 ( a ) ( 7 ).

To XXXX XXXX XXXX XXXX You have reported the Destiny Card account as verified without disclosing who furnished or validated the data, in violation of FCRA 611 ( a ) ( 7 ). The account is listed under the hybrid name FEB DESTINY/CCI, which does not identify a single, verifiable furnisher.

Because neither you nor the reporting entity has provided a chain of title, assignment agreement, or documented ownership, the account can not be legally verified. Under FCRA 611 ( a ) ( 5 ) ( A ), any information that can not be verified must be deleted from the credit file.

I am requesting full removal of this account due to your failure to verify its accuracy, origin, and legal basis for furnishing. 

Preemptive Response to Anticipated Furnisher Defenses In anticipation of a generic response from the furnisher claiming that the account is accurate based on internal records, or that Concora is merely a servicer, I am asserting the following : 1. This is not a dispute of account existenceit is a dispute of legal authority and compliance.

Under FCRA 623 ( a ) ( 1 ), furnishers must report complete and accurate information. Once a dispute is submitted, they are obligated to conduct a reasonable investigation and validate the informationnot simply rely on internal records.

2. If Concora is acting as a third-party servicer, the burden is on them to prove their legal right to furnish data and collect payments.

They are issuing billing statements, processing payments, and using debt collection disclaimers. These actions go far beyond passive servicing. Without documentation of the servicing agreement or authority delegation, the dual label FEB DESTINY/CCI is misleading and non-compliant.

3. The open status of the account does not exempt the furnisher from verification requirements.

Whether the account is open or closed, any entity furnishing information to a credit bureau must be able to prove the accuracy and legal basis of the data when challenged. The lack of ownership clarity, conflicting disclosures, and failure to provide supporting documentation is a direct violation of both the FCRA and the FDCPA.

Relief Requested : 1. Immediate deletion of the tradeline from all credit bureaus due to unverifiable ownership and billing violations 2. In the alternative, removal of all delinquency notations, correction of excessive fees, and status update to reflect Closed Paid as Agreed 3. Refund of charges imposed after the account exceeded the credit limit and fell into delinquency 4. Regulatory enforcement and civil penalties as appropriate under the FCRA, FDCPA, UDAAP, and CARD Act This complaint is not about avoiding a legitimate debt. It is about correcting illegal, unverifiable, and misleading activity from entities who have refused to document their legal authority while continuing to harm my credit profile and collect fees under abusive conditions. 

If these violations are not resolved, I will escalate this matter to legal counsel, arbitration, and regulatory agencies beyond the CFPB.

Company response to consumer: Closed with explanation