Consumer complaint received 2025-07-06 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: EQUIFAX, INC.
State: MI

Complaint narrative:
This complaint is a formal challenge to Equifaxs ongoing failure to reasonably reinvestigate and correct the inaccurate reporting of my XXXX XXXX XXXX and XXXX XXXX credit card accounts. I am not disputing the existence of these accounts, but rather challenging the following : False and Unverifiable Ownership Claims Improper Billing After Account Closure Deceptive Settlement Practices Misreporting of Payment Activity Failure to Verify Information with Competent Evidence Refusal to Correct or Delete Unverifiable Data Supporting evidence previously submitted in full. This complaint includes only updated investigation results, creditor letters, and SEC ownership documents to avoid duplication. 

The issues outlined in this challenge apply to all three reinvestigation attempts, as they reflect a systemic failure by Equifax to conduct a good faith and meaningful investigation in accordance with FCRA 611 ( a ) and Metro 2 compliance standards.

The sections that follow will outline specific discrepancies, timeline contradictions, ownership concerns, and regulatory violations supporting my request for full deletion or immediate correction of both accounts.

1. Unverifiable Ownership Supported by SEC Filings ( EX-10.2 ) XXXX XXXX XXXX XXXX is not the legal owner of the debts associated with XXXX XXXX XXXX XXXX XXXX accounts. As shown in the attached Amended and Restated Receivables Sales Agreement ( EX-10.2 ) between XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( a subsidiary of XXXX XXXX XXXX ) : Bank hereby agrees to sell, transfer, assign, set-over, and otherwise convey to Receivables Purchaser, without recourse one hundred percent ( 100 % ) of the Receivables generated by Bank EX-10.2, Section 2 ( a ) This agreement confirms : 100 % of credit card receivables are sold by XXXX XXXX XXXX XXXX 
The sale is without recourse and structured as a true sale, not a secured loan. 
The Bank retains only servicing duties, not ownership. 
As a result, XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX lack legal standing to furnish tradeline data or pursue settlement collection after sale. Therefore, XXXX XXXX and XXXX XXXX as brands under this structure are not legally reporting with verified ownership authority. Any credit reporting after the transfer constitutes a violation of the FCRA and must be corrected. 

XXXX. Illegally Billing After Account Closure Contradictory letters and billing statements reveal that both XXXX XXXX XXXX  XXXX XXXX XXXX continued to charge fees and send billing statements for months after the accounts were officially closed. This is deceptive and violates federal consumer protection standards, including the Credit CARD Act and FCRA. 
XXXX XXXX Account closed on XX/XX/XXXX, per creditor response letters. 
Despite this, XXXX XXXX continued billing late fees through at least XX/XX/XXXX, disguised as settlement activity. 
Their XX/XX/XXXX, letter explicitly admits : The fees continued to bill on the unpaid balance correctly.This is legally questionable. Once the account is closed and restricted, the creditor should not be billing additional monthly fees unless expressly permitted in a settlement contractwhich they refused to provide. 
Key Timeline & Amounts : XX/XX/XXXX email : Account balance stated as {$390.00} XX/XX/XXXX email : Account balance increased to {$430.00} a {$41.00} increase in under 3 weeks without explanation XX/XX/XXXX : I paid a total of {$400.00} Remaining amount due ( based on {$430.00} ) : {$34.00}, or at most {$75.00} if you consider the higher balance Despite this, I made additional payments : {$41.00} on XX/XX/XXXX {$50.00} on XX/XX/XXXX Yet on XX/XX/XXXX, I received another email stating I owed {$100.00}, with {$73.00} due to bring the account current XX/XX/XXXX email : Claimed account was past due {$150.00} XXXX paid {$120.00} over the {$75.00} potentially remainingyet continued receiving emails stating I was past due and being forced into an unverifiable settlement arrangement with no written terms, no proof of what the fees represented, and no disclosure of why my balance continued increasing. 
Summary : I made four post-closure payments, totaling {$520.00}, on an account they admitted was closed. The additional billing was deceptive, lacked transparency, and had no legal or contractual justification. 
XXXX XXXX Account closed on XX/XX/XXXX, per creditor response letters. 
Yet XXXX XXXX also continued charging fees and requiring payments through XX/XX/XXXX, with the same vague language as XXXX XXXX. 
In the XX/XX/XXXX, letter, they stated the account continued to bill on the unpaid balance correctly after closuredespite no legal or contractual authority to do so. 
Key Timeline & Amounts : XX/XX/XXXX email : Balance stated as {$440.00} XX/XX/XXXX email : Balance increased to {$450.00} XX/XX/XXXX : I paid {$400.00} Remaining amount should have been no more than {$54.00} {$50.00} payment on XX/XX/XXXX made under pressure from phone agents claiming fees would continue even though the account was closed Yet : XX/XX/XXXX email : Balance claimed was {$160.00}, with {$110.00} due XX/XX/XXXX email : Account reported as {$200.00} past due In total, I paid {$450.00} after closure on an account that XXXX only had a {$54.00} balance. There was no explanation for how balances increased to over {$200.00} after closure. I received monthly billing statements for 7 consecutive months with no activity, and againwas never provided with written settlement terms despite multiple requests. 

Legal Concern According to federal billing standards and the Credit CARD Act, once a credit card account is closed and restricted : No further interest or fees should accrue unless transparently disclosed Creditors can not bill as if the account is still open without violating consumer rights Neither XXXX XXXX XXXX XXXX XXXX met these standards. They failed to explain what fees were being charged, how balances increased post-closure, or why settlement terms could not be documented. This pattern of ongoing billing on closed accounts, paired with refusal to provide settlement confirmation, constitutes deceptive, unfair, and abusive practices under UDAAP, the FCRA, and the CARD Act. 

3. Contradictory Statements by Furnishers The written responses provided by Total Visa and First Access Visa contain multiple contradictions, making it clear that the information reported to Equifax was not only unverifiable but based on inconsistent and unreliable records. These contradictions reinforce the conclusion that Equifax failed to properly investigate under the FCRA.

1. Payment Denial vs. ConfirmationIn the CFPB responses dated XX/XX/XXXX and XX/XX/XXXX, XXXX XXXX claimed that only a {$55.00} payment had been received, and XXXX XXXX  claimed only a {$54.00} payment had been received. However, in subsequent responses dated XX/XX/XXXX and XX/XX/XXXX, both furnishers confirmed that all payments from XX/XX/XXXX through XX/XX/XXXX had been received and properly posted. These are the exact payments I referenced in my initial disputes, including the {$300.00} and {$100.00} payments made in XX/XX/XXXX, that they also stated to have never received. 

This directly contradicts their earlier denial of those same payments and clearly demonstrates that their recordkeeping is flawed, and their credit reporting can not be relied upon. Equifaxs decision to mark these tradelines as verified based on such conflicting information shows a failure to review or assess the accuracy of the evidence provided by the furnishers. 

2. Post-Closure Billing In multiple lettersincluding the XX/XX/XXXX responsesboth furnishers acknowledge that the accounts were closed due to delinquency in XX/XX/XXXX ( XXXX XXXX ) and XX/XX/XXXX ( XXXX XXXX ). Despite this, both companies continued to bill fees and send monthly statements well into XX/XX/XXXX. This contradicts their own closure dates and suggests that they improperly treated the accounts as active long after they were legally closed and restricted. The billing of late fees and continued monthly updates during this period is misleading, unlawful, and unsupported by any transparent contractual basis. 

3. Settlement Completed After Closure In the XX/XX/XXXX XXXX XXXX letter, the creditor states that the settlement was completed on XX/XX/XXXX. However, they had already confirmed that the account was closed on XX/XX/XXXX. This means they continued billing, collecting, and reporting the account for over seven months after it was no longer open. This timeline is inherently contradictoryan account can not simultaneously be closed and restricted and active and accruing fees toward a settlement. These contradictions show that no accurate or consistent account history exists.

4. Claims of Original Creditor StatusNeither First Access nor XXXX XXXX clearly identify XXXX XXXX XXXX XXXX as the original creditor in their CFPB responses. Instead, they repeatedly state that no third party is involved, which is false and misleading by omission. This omission is significant, because it misrepresents the true ownership structure of the accounts and conceals the securitization and sale of the receivables. 
SEC-filed documentationspecifically the Amended and Restated Receivables Sales Agreement ( EX-10.2 ) proves that XXXX XXXX XXXX XXXX  sells 100 % of its receivables ( credit card debt ) to XXXX XXXX, XXXX XXXX XXXX subsidiary of XXXX XXXX XXXX, without recourse . The agreement states : Bank hereby agrees to sell, transfer, assign, set-over, and otherwise convey to Receivables Purchaser, without recourse one hundred percent ( 100 % ) of the Receivables generated by Bank EX-10.2 , Section 2 ( a ) This confirms that XXXX XXXX XXXX XXXX  does not retain ownership of the accounts and has no legal standing to furnish derogatory tradelines or collect post-sale. Its role is limited to servicing. Therefore, by failing to acknowledge the role of XXXX or XXXX, and by denying any third-party involvement, the furnishers have provided materially false and misleading information. 
This misrepresentation of ownership and reporting authority directly violates the Fair Credit Reporting Act ( FCRA ) and undermines the legal basis for Equifaxs verification of these tradelines. 

Why These Contradictions Are Legally Significant and Undermine Verification Each of the contradictions outlined above represents a direct violation of the Fair Credit Reporting Act ( FCRA ) and the Credit Reporting Agencies ' duty to ensure the maximum possible accuracy of consumer credit information. According to FCRA 611 ( a ), Equifax is legally obligated to conduct a reasonable reinvestigation of any disputed account. That includes evaluating whether the information furnished is consistent, supported by documentation, and based on accurate account records. None of those conditions were met here. 
The payment denial vs. confirmation issue proves that furnishers initially misrepresented the facts of payment history. This means material account data was falseyet Equifax still marked the information as verified, despite having my bank records and the creditors later confirmations that all payments were received. 
The post-closure billing contradiction shows that both furnishers treated the accounts as active months after closure, billing fees and updating balances. This is not just misleadingit is illegal under federal law, including the Credit CARD Act, which restricts new charges or fees after closure unless properly disclosed and contractually agreed. Equifax 's failure to question or investigate this ongoing billing activity on closed accounts shows gross negligence in their reinvestigation. 
The settlement completion after account closure contradiction makes clear that the furnishers were applying settlement terms to accounts that were no longer legally collectible in the same way. The fact that balances were still increasing and being reported as past due months after closure, without written settlement documentation, renders the reporting inherently unverifiable. 
The claim that no third party was involved, despite clear evidence from SEC documents that all receivables were sold to a third-party entity ( XXXX XXXX ), represents an intentional concealment of the actual creditor structure. This omission invalidates any claim that the furnishersor XXXX XXXX XXXX XXXX ongoing legal authority to report or collect on the debt. The FCRA requires accurate reporting of both account status and ownership, and Equifax had a duty to investigate the ownership when I provided this documentation. 
Given these contradictions, Equifax could not have reasonably verified the accuracy of these accounts without either ignoring or disregarding the conflicting evidence and lack of supporting documentation. Therefore, Equifax is in violation of FCRA 611, and the continued reporting of these tradelines is unlawful. These accounts must be corrected to reflect their true post-settlement statusor deleted entirely as unverifiable, misleading, and harmful to the consumer. 


Equifax Continued Reporting After Account Closure Violates FCRA Accuracy Requirements Both the XXXX XXXX XXXX XXXX XXXX  accounts were formally closed in XX/XX/XXXX and XX/XX/XXXX, respectively. This is not speculativeit is clearly documented within Equifaxs own credit report entries, which list the closure months explicitly. 
Despite this, Equifax continued to allow furnishers to report balances, delinquencies, and settlement activity on these closed accounts well into XXXX, with past due statuses and payment updates reflected through XX/XX/XXXX. 
Most egregiously, Equifax allowed : Past due balances to be reported in months when the accounts were already closed Monthly activity updates for accounts with no legitimate post-closure usage Settlement remarks and delinquency notations based on unverifiable, post-closure charges Ongoing tradeline updates without properly marking the accounts as Closed To date, Equifax has still failed to notate either account as Closed, which creates the false impression that these are active or collectible debts. This is inaccurate and harmful, and it directly contradicts the closure information Equifax already had on file. 
Nothing should be reported on a closed accountespecially not delinquency notations or continued balance updates. Once an account is closed and restricted, it must reflect only its final resolved status. 
Violation of FCRA 607 ( b ) Under the Fair Credit Reporting Act, Equifax is legally obligated to : Follow reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates.FCRA 607 ( b ) That obligation does not permit blind reliance on furnishers, especially when : The account is documented as closed No purchases or charges occurred post-closure No written settlement documentation exists The consumer has provided contradictory evidence showing overpayment and incorrect balances By continuing to report : Post-closure delinquency and balance activity Settled status based on no formal agreement Past due amounts for periods when accounts were not even legally billable Equifax affirmatively misrepresented the nature, status, and accuracy of both accounts. 
CRA Liability Is Independent of the Furnisher Even if a furnisher continues sending data after closure, Equifax is not absolved of its responsibility under the FCRA. Regulatory guidance and case law are clear : a credit reporting agency must : Independently assess whether the data is internally consistent, Confirm that it is factually supported, And determine whether it is legally reportable. 
In this case, none of that occurred. Equifax ignored the closure dates, overpayment evidence, and contradictory furnisher statements, and chose to continue publishing derogatory data on two accounts that should have been resolved or removed. 
Conclusion Equifaxs decision to continue reporting both accounts well into XXXX, while knowing they were closed in XXXX, is a clear violation of FCRA 607 ( b ). It contradicts their own records, fails to meet basic verification standards, and further confirms that the accounts are inaccurate, unverifiable, and legally reportable only if corrected or deleted entirely. 


Equifaxs Verification Failure Despite receiving this supporting documentation, Equifax : Failed to reconcile the true account balances with the payments made Did not obtain or request any written settlement agreement to justify the settled for less remark Ignored clear evidence that I paid more than what was owed at closure This remark was accepted from the furnisher without verification, despite the fact that the furnishers themselves admitted in their XX/XX/XXXX letters that no settlement letter could be located. 
In the XX/XX/XXXX, XXXX XXXX letter, they stated : Your request for a copy of the letter confirming the settlement terms was reviewed. We do not locate a letter regarding a settlement offer dated XXXX. 
So how was Equifax able to verify a settlement occurred, let alone claim it was settled for less, if the creditor couldnt even produce documentation to support it? 
Violation of FCRA and Metro 2 Guidelines Under the Fair Credit Reporting Act ( FCRA ) and Metro 2 industry standards, Equifax is not permitted to : Rely solely on furnisher data that is contradicted by consumer evidence Report settled for less status without written, verifiable settlement terms Ignore overpayment evidence and knowingly furnish inaccurate derogatory remarks This conduct violates : FCRA 607 ( b ) failure to ensure accuracy FCRA 611 ( a ) failure to reinvestigate properly Metro 2 guidelines prohibition on reporting settlement status without documentation 4. Failure to Provide Settlement Letter Despite confirming that I was enrolled in a settlement arrangement, neither Total Visa nor First Access Visa ever provided a written agreement outlining the settlement terms, payment schedule, or total payoff amount. Instead, they both stated that a settlement letter would only be issued after all payments had been madeleaving me with no written confirmation during the active settlement period. 

This was not a one-time miscommunication. I received multiple settlement offer emails over several months, and I accepted the initial offer because the furnishers kept billing fees on a closed account and refused to stop unless a settlement was reached. However, even after I accepted that first settlement offer, I continued receiving new settlement emails each month with different amounts and terms. 

When I contacted their customer service to ask why settlement offers continued arriving after I had already accepted one, I was told they had no record of ever sending a settlement offer at all. This was deeply concerning. Their denial of the very email offers I received ( and accepted ) led me to request formal documentation proving I was enrolled in a settlement but they repeatedly refused to provide it, as clearly shown in their CFPB response letters. 

From XXXX XXXX ( XX/XX/XXXX ) : The agent informed you a letter would be sent upon completion of the last settlement payment and to call to confirm it was completed. 
This left me without any settlement letter during the full payment period meaning I had no protection if the terms changed or if they later misapplied payments. 

From XXXX XXXX ( XX/XX/XXXX ) : Only one payment of {$54.00} has been received for the settlement... In the absence of any evidence of error in our reporting of the account, we are unable to fulfill the request to remove the account from the credit bureau reports. 
This statement dismisses the multiple payments I made and my proof of those payments and relies on the existence of a settlement they simultaneously deny ever offering or documenting. 

From XXXX XXXX ( XX/XX/XXXX ) : We did not locate a copy of a letter confirming the settlement offer you referenced. 
This contradicts their earlier acknowledgment that I was in a settlement and further demonstrates their internal records are incomplete, inconsistent, or deliberately withheld. 

From XXXX XXXX ( XX/XX/XXXX ) : On XX/XX/XXXX, you agreed to pay the account for less than the balance and agreed to the amount of {$100.00} ... On XX/XX/XXXX, the settlement was completed, and the remaining balance was written off. 
Despite this acknowledgment of a settlement arrangement and completion, no letter was ever issued confirming the agreed terms, and my repeated requests were either ignored or dismissed. I completed all settlement payments by XX/XX/XXXX, and still received no documentation to reflect this. 

From XXXX XXXX ( XX/XX/XXXX ) : Your request for a copy of the letter confirming the settlement terms was reviewed. We do not locate a letter regarding a settlement offer dated XX/XX/XXXX. 
This is particularly alarming because my payments were made based on that exact offer. Their denial of the agreements existence after accepting the payments reveals a serious procedural flaw or intentional deception. 

Why This Is Deceptive and Legally Problematic The repeated refusal to provide written confirmation of a settlementwhile continuing to bill on a closed account, furnish negative credit data, and send conflicting settlement offersdemonstrates a pattern of deceptive and abusive conduct. 
This prevented me from : Validating the terms of my agreement Disputing errors with supporting documentation Confirming completion of my obligations Protecting myself from ongoing derogatory credit reporting This conduct violates FCRA, FDCPA, and UDAAP standards by denying me the transparency and documentation I needed to resolve the account. Worse, Equifax relied on the furnishers undocumented claims to continue verifying negative tradeline data. 
A valid settlement agreement must be documented. If the furnishers can not or will not produce such documentation, the credit reporting must be considered unverifiable and deleted. 

5. Equifaxs Violations of FCRA Equifax failed to meet its duty under FCRA 611 to : Conduct a reasonable reinvestigation Provide a description of the process Verify the data using competent evidence Delete unverifiable information if the furnisher can not confirm ownership and accuracy Instead, Equifax relied on data furnishers who issued inconsistent, incomplete, and contradictory responses. 

Why Equifax 's Verification Was Inadequate and Legally Deficient Despite my submission of clear, documented contradictions and errors, Equifax closed my disputes with claims that no changes were needed or that the items had been verified. This position is not only unsupported by the evidenceit also violates the Fair Credit Reporting Act ( FCRA 611 ) and industry standards under Metro 2 guidelines, which require credit reporting agencies to ensure the maximum possible accuracy of the data they report. 
Key Errors in XXXX Verification : 1. {$400.00} XX/XX/XXXX Payment Not Reflected on Either Account I made {$400.00} in total payments across these two accounts in XX/XX/XXXX. 
These payments are missing from both tradelines in Equifaxs updated investigation results. 
The account histories fail to reflect these payments, and there is no update showing a balance reduction, paid status, or accurate application of payments in XXXX. 

If Equifax had truly verified this information with the original furnisher, these XX/XX/XXXX payments would have been included in the payment history. 

2. Continued Reporting of Scheduled Payments and Past Due Balances AFTER Account Closure The XXXX XXXX  account was closed in XX/XX/XXXX, and XXXX XXXX was closed in XX/XX/XXXX. 
Yet Equifax continues to report scheduled payments, due dates, and past due balances well into XXXX for both accounts. 
For example, both reports show activity dated through XX/XX/XXXX, which is 78 months after the official account closure. 

According to Metro 2 reporting standards and FCRA 607 ( b ), no payment activity should appear after the closure date, and no pay status should be reported as Pay As Agreed on a closed account. 

XXXX. Equifax Contradicts Its Own Data Equifaxs investigation results confirm the accounts were closed in late XXXX, yet the updated reports include : Scheduled Payment Amounts of {$41.00} each Next Payment Due Dates of XX/XX/XXXX Pay Status as Pay As Agreed instead of Paid/Closed or Closed/Paid Settled This is internally contradictory : Equifax acknowledges the closure date, but still reports the accounts as active and delinquent into XXXX. 

4. No Explanation or Verification Details Provided Under FCRA 611 ( a ) ( 6 ) ( B ), Equifax is required to provide : A description of the reinvestigation process ; The name and contact details of the furnisher ; And the documentation used to verify the disputed information. 

Equifaxs response included none of this information and simply stated the item was updated without showing any substantive correction or reconciliation with the actual payment history I provided. 

These summaries confirm that Equifax knowingly accepted and reported post-closure payment activity as settlement payments without requiring proper validation or documentation of the settlement agreements. This is not just carelessit contradicts the FCRAs requirement that data must be verifiable and accurate. 
The Legal Issues : 1. No Settlement Letter ExistsBoth furnishers refused to provide documentation proving I was under an official settlement arrangement. Without such documentation, Equifax had no legal or factual basis to verify settled for less status or any associated payment updates. Per FCRA 611 ( a ) ( 1 ) ( A ), CRAs must conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate.

2. Account Status vs. Payment Dates ConflictBoth accounts were closed in late XXXX, yet Equifax shows last payments received in XX/XX/XXXX. This proves that Equifax accepted ongoing reporting activity on closed accounts, which is a major compliance issue. No explanation was provided as to how payments made 67 months post-closure could lawfully update a closed tradelineespecially without proof of a settlement contract. 
3. Furnisher Contradictions Were IgnoredThe same furnishers that Equifax relied on to verify these accounts issued multiple CFPB responses that contradict themselves on key points, including : Payment amounts and dates Whether a settlement was ever offered Whether third parties were involved Whether accounts were still being billed post-closure 4. Equifax ignored these contradictions entirely and provided no statement of how they resolved these conflicts before declaring the tradelines verified. 
5. Equifaxs Dispute Results Do Not Satisfy FCRA 611 ( a ) ( 7 ) I was never provided with : A description of how the reinvestigation was conducted The name, address, and documentation relied on from the furnisher Any explanation of how contradictory or missing information was reconciled Legal Grounds for Immediate Removal Based on the documented record of contradictions, misrepresentations, and Equifaxs failure to lawfully reinvestigate or validate the disputed information, the continued reporting of these XXXX XXXX and XXXX XXXX tradelines is a clear violation of the Fair Credit Reporting Act ( FCRA ). Since XXXX, I have consistently provided accurate and detailed documentationincluding payment confirmations, closure notices, and regulatory filingsthat directly refute the furnishers claims. 

Despite this, Equifax has willfully ignored the facts and maintained inaccurate, misleading, and incomplete tradelines, acting in partnership with the furnishers to suppress necessary corrections that would reflect my true credit history. This conduct violates : FCRA 611 ( a ) for failure to conduct a reasonable reinvestigation, FCRA 611 ( a ) ( 5 ) for failure to delete or correct information that can not be verified, FCRA 607 ( b ) for failure to ensure maximum possible accuracy in consumer reports, And violates the principles of Metro 2 compliance and the CFPBs guidance on dispute resolution and data accuracy obligations. 

Given the overwhelming evidence that : The furnishers statements are internally inconsistent, The accounts were closed months prior to the reported payment activity, And payments were initially denied, then later acknowledged by the furnisher. 

Equifax had no legal or factual basis to validate or continue reporting these accounts as accurate or verifiable. 

Accordingly, I demand the immediate and permanent deletion of both tradelines from my Equifax credit file and request that the Consumer Financial Protection Bureau hold Equifax accountable for its failure to protect consumers from inaccurate and unverifiable credit reporting in violation of federal law.

Company response to consumer: Closed with non-monetary relief