Consumer complaint received 2025-08-13 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Credit monitoring or identity theft protection services — Problem with product or service terms changing
Company: Experian Information Solutions Inc.
State: NE

Complaint narrative:
Experian Information Solutions , Inc . 

XXXX  XXXX XXXX  XXXX XXXX, XXXX This is a formal complaint against Experian, TransUnion, and Equifax for suspicious, substantial, and unjustified fluctuations in my credit scores over the last XXXX months, in apparent violation of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., and related regulatory rulings.

Despite no material changes in my credit history, payment patterns, utilization rates, or new derogatory entries, my credit scores have shifted by as much as [ 8 month range, 50 points ] in short intervals. These shifts are inconsistent across bureaus, suggesting systemic errors, flawed algorithmic application, or deliberate scoring manipulation.

Such conduct constitutes a failure to follow reasonable procedures to assure maximum possible accuracy under FCRA 1681e ( b ), and a failure to conduct reasonable reinvestigation as required under FCRA 1681i.

The FCRA imposes clear, affirmative duties on Credit Reporting Agencies ( CRAs ) : Accuracy Obligation 15 U.S.C. 1681e ( b ) : CRAs must follow procedures to assure the maximum possible accuracy of consumer reports. Arbitrary score swings absent legitimate data changes do not satisfy this standard.

Investigation Requirement 15 U.S.C. 1681i ( a ) : Upon notice of dispute, CRAs must conduct a reasonable reinvestigation. Cushman v. Trans Union Corp., 115 F.3d 220 ( 3d Cir. 1997 ) held that reasonable reinvestigation requires more than parroting data from furnishers ; it demands independent verification.

Full Disclosure 15 U.S.C. 1681g : CRAs must provide all information in the consumer file upon request. Any undisclosed scoring algorithm changes or internal adjustments that materially impact a consumers creditworthiness without disclosure is a violation.

Recent Enforcement Guidance The CFPB and FTC have repeatedly warned CRAs against opaque scoring methodology changes without clear, consumer-facing disclosure ( see CFPB Bulletin 2013-09, CFPB v. TransUnion, No. 1:22-cv-01880 ( N.D. Ill. 2022 ) ).

Arbitrary Score Variations : Credit score changes of [ X points ] over weeks with no factual basis.

Cross-Bureau Inconsistency : Identical credit files producing significantly different scores across the three CRAs.

Potential Algorithmic Manipulation : Possible alteration of score weighting models without regulatory notification or consumer consent, resulting in artificially depressed scores.

Financial Harm : These manipulations have caused concrete damages, including [ e.g., higher interest rates, denied credit, adverse action notices ]. 

I respectfully demand that the CFPB : Investigate whether Experian, XXXX, and XXXX  have modified scoring algorithms or reporting procedures in the last XXXX months in a manner that violates the FCRA.

Compel Disclosure of any algorithmic scoring model changes or internal procedural modifications affecting score calculations during this period. 

Order Correction of any scores adversely impacted by inaccurate or unfair scoring adjustments. 

Pursue XXXX actions and civil penalties against the CRAs for willful noncompliance with FCRA obligations, as provided in XXXX XXXX. XXXX. 

This pattern of unexplained, inconsistent score changes is incompatible with the FCRAs mandate for maximum possible accuracy and transparency. Absent corrective action, these practices erode consumer trust and create unjust economic harm. I request immediate CFPB review, enforcement, and remedial measures.

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 explanation