Consumer complaint received 2025-07-09 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: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: MI

Complaint narrative:
I am submitting the following as supplemental evidence to support my previously filed CFPB dispute XXXX regarding the XXXX  XXXX tradeline, which has been reported under multiple entities including XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX ) XXXX and now XXXX XXXX XXXX XXXX  XXXX XXXX ) .In response to my recent dispute regarding the XXXX  XXXX XXXX, I received a letter from XXXX XXXX XXXX XXXX which provided an Account Holder Agreement as evidence of validity. 

However, this letter fails to satisfy legal or reporting standards for the following reasons : 1. No Proof of Legal Ownership or Title While XXXX included a general agreement, they did not provide any documentation showing they currently own or are legally authorized to furnish this account to the credit bureaus. 
This makes the tradeline unverifiable, as a cardholder agreement is not legal proof of account ownership under the FCRA 611.

2. No Chain of Assignment Disclosed The letter claims that the account was issued by XXXX XXXXXXXX XXXX  and later transitioned to XXXX XXXX XXXX XXXX but provides no proof of sale, assignment, or legal transfer to support this. 
This makes the account unverifiable, because data furnishers must demonstrate a valid and continuous right to report not just historical involvement. 
XXXX. XXXX XXXX ( XXXX  ) Is Not Defined or Legally Registered The credit report lists the furnisher as XXXX XXXX XXXX, but XXXX does not appear in any official legal filings, billing statements, or corporate registrations. XXXX is not a stand-alone legal entity. 
This makes the tradeline unverifiable, as furnishers must be clearly named and legally traceable under FCRA 609 ( a ) and Metro 2.

As of XX/XX/XXXX, XXXX XXXX XXXX claimed XXXX XXXX XXXX XXXX  had become the issuer of my XXXX XXXX account. However, no proof of legal ownership, assignment, or re-transfer was provided. 

At the same time, the XX/XX/XXXXXXXX  XXXX filing and XXXX  Agreed-Upon Procedures Report confirm that over XXXX XXXX XXXX-related accounts were securitized into the Perimeter Master Note Business Trust ( XXXX XXXX ), and even the auditor declined to verify ownership. 

Therefore, the account is not legally owned by any entity currently reporting to TransUnion. The lack of chain of title, along with conflicting and unverifiable issuer/furnisher identities, renders this tradeline factually and legally unverifiable under FCRA 611 .

XXXX XXXX XXXX XXXX  is not the legal owner of the XXXX XXXX account currently reporting on my credit file. XXXX agreements ( XXXX  XXXX XX/XX/XXXX ) confirm that XXXX sells 100 % of its receivables to XXXXXXXX XXXX XXXXXXXX XXXX XXXX affiliate of XXXXXXXX XXXX XXXX XXXX XXXX filings ( CIK XXXX ) show that these receivables are then securitized into trusts such as the XXXX XXXX XXXX XXXXXXXX XXXX and the Perimeter Master Note Business Trust. XXXX XXXX audits attached to these filings explicitly disclaim ownership verification. Therefore, the account is legally unverifiable, and the current reporting party has not established standing under the FCRA. 

Document XXXX Receivables Sales Agreement ( XXXX  XXXX, XX/XX/XXXX ) XXXX XXXX XXXX XXXX hereby agrees to sell, transfer, assign 100 % of the Receivables generated by Bank to XXXX XXXX XXXX. 
[ XXXX  XXXX : XXXX ] This makes the account unverifiable, because XXXX does not retain any legal interest in the account once receivables are sold. The credit bureaus can not verify information from a party who no longer owns the debt. 

Document XXXX XXXX XXXX ( XXXX XXXX XXXX XXXX XXXX XXXXXXXX ) We invest in receivables originated by lenders who utilize our technology platform and other related services including XXXX XXXX XXXX XXXX XXXX 
XXXX, XXXX, and XXXX cards are all serviced and securitized by XXXX. 
[ XXXX XXXX XXXX XXXX XXXXXXXX ] This makes the tradeline unverifiable, because the servicing entity ( XXXX  ) does not appear on the credit report, and the originating bank ( XXXX  ) does not own the account. No party on record has clear standing. 

Document XXXX XXXX Filing : XXXXXXXX XXXX XXXX XXXX XXXXXXXX ( XX/XX/XXXX ) Receivables included in Series XXXX are credit card accounts including XXXX  XXXX.No ownership verification provided by the trust or servicer. 
[ XXXX ] This makes the account unverifiable, as securitization removes legal title from the originator. TransUnion has not produced any valid documentation showing who currently owns or services the account post-securitization. 

Document XXXX XXXX Agreed-Upon Procedures Report ( XX/XX/XXXXXXXX  ) We make no representations as to the existence or ownership of the revolving credit card accounts This audit, tied to Perimeter Master Note Business Trust ( an XXXX XXXX ), reviewed over XXXX XXXX accounts including Destiny. 
[ XXXX ] This makes the account unverifiable, because even XXXX, the independent auditor disclaimed any ability to validate ownership. TransUnion can not claim the account is verified when no party involved can prove legal title. 

This Account Must Be Deleted The XXXX XXXX account can not be verified because : No party listed on my credit report holds legal title or servicing rights ; SEC filings prove receivables were sold and securitized, removing ownership from both XXXX and XXXX  ; TransUnion has not provided documentation of any current owner or authorized furnisher ; Every response contradicts Metro 2 reporting standards, FCRA 611 verification requirements, and 609 ( a ) furnisher identity standards. 

XXXX can not furnish the account if they dont legally own the receivables. 
XXXX has failed to provide a chain of assignment showing how they or XXXX regained control after the XXXX securitization. 
The XXXX securitization further removes ownership from any of the named furnishers. 
TransUnion continues reporting a tradeline under XXXX, with no disclosure of the trust or servicer making the reporting structure legally incomplete and unverifiable.

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