Consumer complaint received 2025-10-24 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Improper use of your report — Reporting company used your report improperly
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: FL

Complaint narrative:
Summary of Complaint I am filing this formal complaint against Transunion Credit Bureau for unlawful and unverifiable reporting of late payments on the following accounts appearing on my Transunion credit file : XXXX XXXX Account No. XXXX XXXX XXXX XXXX Account No. XXXX XXXX XXXX XXXX XXXX  Account No. XXXXXXXX XXXX XXXX XXXX XXXX XXXX Account No. XXXX Transunion, and the furnishers listed above, have failed to comply with their legal duties under the Fair Credit Reporting Act ( FCRA ) and the Fair Debt Collection Practices Act ( FDCPA ) by reporting derogatory payment history data that is unverifiable, inaccurate, and unsupported by documentation. 

Factual Basis Upon review of my Transunion credit report, I identified alleged late payments reported on the accounts listed above. I promptly filed disputes under FCRA 611 ( 15 U.S.C. 1681i ), requesting that Transunion and the furnishers provide documented proofsuch as payment records, account ledgers, or authenticated statementssubstantiating the alleged delinquencies.

In response, Transunion failed to provide any substantive evidence or verifiable documentation. Instead, Transunion relied solely on generic codes and automated responses derived from the Metro 2 reporting format, which are not sufficient to verify the accuracy of reported data. The Metro 2 system itself is a reporting guidelinenot proof of factual payment history or legal evidence of debt delinquency. 

Legal Basis and Violations 1. Violation of FCRA 607 ( b ) ( 15 U.S.C. 1681e ( b ) ) Transunion failed to maintain reasonable procedures to ensure maximum possible accuracy of information. Reliance on unverifiable and unsubstantiated coding data violates the bureaus duty under 607 ( b ).

2. Violation of FCRA 611 ( 15 U.S.C. 1681i ) Upon receiving my disputes, Transunion failed to conduct a reasonable reinvestigation as required by 611 ( a ). A reasonable investigation requires actual verification through reliable evidence, not mere reliance on the same unverifiable information previously supplied by the furnisher. 
3. Violation of FCRA 623 ( a ) ( 1 ) ( A ) Each furnisher listed above continued to report alleged late payments despite lacking evidence of delinquency, thereby furnishing information knownor that should have been knownto be inaccurate. 
4. Violation of FDCPA 807 ( 8 ) ( 15 U.S.C. 1692e ( 8 ) ) Reporting or communicating credit information that is false, or that should be known to be false, including failing to communicate that a disputed debt is disputed, constitutes a deceptive practice under 807 ( 8 ).

Supporting Case Law In Cushman v. TransUnion Corp., 115 F.3d 220 ( 3d Cir. 1997 ), the court held that a credit reporting agencys reinvestigation must be more than a mere rubber-stamping of the original information. The bureau must independently verify the accuracy of disputed information. Transunions reliance on non-documentary verification through Metro 2 coding directly contravenes this precedent, demonstrating that Transunions process was neither reasonable nor compliant with the FCRA. 

Unverifiable Reporting Under Metro 2 The Metro 2 format is a data-transmission standardnot legal proof. Codes such as L for late or XX/XX/XXXX days past due are merely designations, not evidence. When a consumer disputes a late payment, Transunion and the furnisher are required to substantiate the information with contemporaneous business records, not unverifiable codes. Without documented proof, the data is legally unverifiable under FCRA 607 ( b ) and 611.

Demand for Relief Given that Transunion and the furnishers have failed to produce any documented evidence substantiating the alleged late payments, and instead relied solely on unverifiable codes and automated systems, I hereby demand that : 1. All unverified late payment notations on the accounts listed above be permanently deleted from my Transunion credit file in accordance with the FCRA and FDCPA. 
2. Transunion provide a written confirmation of deletion and a revised copy of my credit report.

3. The CFPB investigate Transunions repeated failure to conduct reasonable investigations and reliance on unverifiable Metro 2 coding as proof. 

Conclusion Transunions actions constitute willful and negligent noncompliance with the FCRA and FDCPA, resulting in inaccurate credit reporting and consumer harm. The CFPBs intervention is requested to ensure compliance, compel deletion of unverifiable data, and prevent further violations.

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