Consumer complaint received 2026-03-01 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: Experian Information Solutions Inc.
State: IL

Complaint narrative:
I, XXXX XXXX, am the consumer as defined under XXXX U.S.C. XXXX ( c ) whose credit file is the subject of this dispute. I have never resided at, received mail at, or had any residential connection to the XXXX XXXX XXXX I am disputing. pursuant to the Consumer Financial Protection Act ( CFPA ), XXXX U.S.C. XXXX et seq., and FCRA XXXX ( b ) ( XXXX ) ( H ), XXXX U.S.C. XXXX ( b ) ( XXXX ) ( H ), which grants the CFPB exclusive enforcement authority over FCRA violations by covered persons including mortgage companies, credit reporting XXXX, and any entity offering or providing consumer financial products or services. Respondents as Covered Persons : Each respondent XXXX ( acting as a tri-merge mortgage credit reporting intermediary for XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX, and XXXX Mortgage operates in the mortgage XXXX XXXX XXXX and is a 'covered person ' under XXXX XXXX ( XXXX ), XXXX U.S.C. XXXX ( XXXX ), subject to CFPB supervision and enforcement for FCRA violations. XXXX XXXX : Under XXXX XXXX, XXXX U.S.C. XXXX, the CFPB may act against covered persons engaging in unfair, deceptive, or abusive acts or practices. The pattern of redundant, unauthorized hard inquiries within a XXXX window pulling the same consumer 's credit file 6 times constitutes an unfair practice causing substantial consumer harm that could not reasonably be avoided, with no countervailing consumer benefit. A. FCRA XXXX ( b ) Respondents Are 'Persons ' Bound by All FCRA Duties Statutory Text : " The term 'person ' means any individual, partnership, corporation, trust, estate, cooperative, association, government or governmental subdivision or agency, or other entity. '' XXXX U.S.C. XXXX ( b ). Each respondent is a corporation or business entity and therefore a 'person ' under XXXX ( b ), subject to all FCRA obligations governing permissible purposes for accessing consumer reports. This definitional provision, read in conjunction with XXXX ( a ) 's mandate that these definitions apply to the entire FCRA subchapter, establishes that there are no carve-outs or exceptions for mortgage credit reporting XXXX or tri-merge report requestors. XXXX FCRA XXXX The Permissible Purpose Requirement Statutory Text : A consumer reporting agency may furnish a consumer report under the following circumstances and no other ... [ including ] in response to ... a person [ with ] a legitimate business need for the information in connection with a business transaction that is initiated by the consumer. XXXX U.S.C. section XXXX ( a ) ( XXXX ) ( F ). The Legal Standard : Access to a consumer 's credit report requires a specific, current, and non-redundant permissible purpose at the time of each pull. The key phrase is 'initiated by the consumer ' a single mortgage application by the consumer initiates a single permissible purpose event. That event does not multiply simply because multiple XXXX, brokers, or lenders are involved in processing the same application. The XXXX / Rate Shopping Window : Under FCRA XXXX and the XXXX scoring model 's rate-shopping provisions ( codified in practice through FCRA 's XXXX framework ), multiple mortgage inquiries within a XXXX window may be deduplicated for scoring purposes. However, this rate-shopping provision is a scoring deduplication rule it does NOT grant independent permissible purpose to each redundant pull. Each inquiry must still have its own distinct permissible purpose under XXXX. The fact that inquiries are deduplicated for scoring does not mean they are authorized ; it means the credit bureaus attempt to minimize score damage from inquiries that XXXX or XXXX not have been lawfully obtained. The Critical Distinction : The permissible purpose belongs to the consumer 's single credit transaction XXXX mortgage application. It does NOT renew or replicate for each party downstream who chooses to pull the report. As the FTC has stated in its FCRA XXXX, a permissible purpose is specific to a particular transaction ; once that transaction is evaluated, subsequent pulls by different XXXX require independent justification. XXXX hard inquiries for what appears to be a single mortgage application process in XXXX XXXX can not all independently satisfy XXXX. XXXX FCRA XXXX and XXXX Civil Liability for Impermissible Access XXXX ( Willful Violations ) : Any person who willfully fails to comply with the FCRA is liable for : ( XXXX ) actual damages or statutory damages of {$100.00} {$1000.00} per violation ; ( XXXX ) punitive damages ; and ( XXXX ) attorney fees and costs. XXXX U.S.C. XXXX ( a ). XXXX ( Negligent Violations ) : Any person who negligently fails to comply is liable for actual damages and attorney fees. XXXX U.S.C. XXXX. With XXXX impermissible inquiries, willful violation exposure alone is {$6000.00} in statutory damages minimum, with punitive damages and fees on top. XXXX. THE DISPUTED INQUIRIES FACTS AND PATTERN OF VIOLATION A. Complete List of Disputed Inquiries # Inquiring Entity Date of Inquiry Business Type Expiration XXXX XXXX XXXX XXXX XX/XX/XXXX Mortgage Reporters XX/XX/XXXX XXXX ADVANTAGE CREDIT XXXX XX/XX/XXXX Mortgage Reporters XX/XX/XXXX XXXX EQUIFAX/EMS XXXX XXXX XX/XX/XXXX Mortgage Reporters XX/XX/XXXX XXXX CREDCO/UWM XX/XX/XXXX Mortgage XXXX XX/XX/XXXX XXXX CREDCO/UWM XX/XX/XXXX Mortgage XXXX XX/XX/XXXX XXXX XACTUS-AVANTUS/ROCKET XX/XX/XXXX Mortgage Companies XX/XX/XXXX B. The Clustering Pattern Evidence of Impermissible Redundancy XXXX Cluster : XXXX of the XXXX inquiries occurred within a XXXX window between XX/XX/XXXX and XX/XX/XXXX. This is not coincidental it is the direct result of multiple mortgage XXXX, credit reporting vendors, and lenders each pulling a separate hard inquiry for what was, from the consumer 's perspective, a single mortgage transaction. Duplicate Entities XXXX XXXX XXXX XXXX This entity pulled Complainant 's Experian report TWICE on XX/XX/XXXX and again on XX/XX/XXXX, just 6 days apart. A single loan application does not require the same credit reporting intermediary to pull the same consumer 's credit twice within XXXX week. The second pull by XXXX XXXX XXXX XXXX XXXX independent permissible purpose distinct from the first the consumer had not initiated a new credit transaction in the 6 days between pulls. This second pull is facially impermissible under FCRA XXXX. Duplicate Entities CREDCO/UWM : XXXX ( acting on behalf of XXXX XXXX XXXX Mortgage XXXX also pulled Complainant 's report TWICE on XX/XX/XXXX and XX/XX/XXXX, just XXXX DAY APART. No legitimate credit evaluation purpose requires pulling the same consumer 's file on consecutive days. A credit report is valid for XXXX to 120 days in mortgage underwriting pulling again the very next day demonstrates either a process failure or a deliberate disregard for the consumer 's rights under FCRA XXXX. The Legal Effect of Same-Entity Duplicate Pulls : Under XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX ( XXXX XXXX. XXXX ), a permissible purpose must exist at the exact time of each credit report access. It does not carry forward or authorize a second pull by the same entity on a separate date, absent a new consumer-initiated transaction. Both XXXX 's XXXX pulls and XXXX 's XXXX repeat XXXX XXXX this standard. The XXXX XXXX : XXXX hard inquiries for a single mortgage transaction process is excessive and harmful by any standard. Each hard inquiry can reduce a consumer 's FICO score by XXXX points ; with XXXX inquiries, the cumulative impact to XXXX 's score and creditworthiness is material, ongoing, and entirely avoidable. Complainant did not authorize XXXX separate credit pulls she initiated a mortgage process that was exploited by downstream XXXX each seeking their own independent data access. IV. SPECIFIC LEGAL VIOLATIONS A. FCRA XXXX No Independent Permissible Purpose for Each Pull Violation : Each of the XXXX inquiries must independently satisfy XXXX 's permissible purpose requirement. A single mortgage application by XXXX created XXXX permissible purpose event. That event did not create XXXX separate authorization tokens XXXX for each entity that chose to access the file independently. Respondents CREDCO/UWM ( XXXX ), Equifax/EMS XXXX XXXX XXXX XXXX XXXX, Advantage Credit XXXX, and XXXX Mortgage can not each claim XXXX same consumer transaction as independent permissible purpose for separate hard inquiries. Impermissible Same-Entity Duplicate Pulls : The duplicate pulls by CREDCO/UWM ( XX/XX/XXXX and XXXX ) and Equifax/EMS XXXX XXXX ( XX/XX/XXXX and XX/XX/XXXX ) are per XXXX impermissible no new consumer transaction was initiated between those dates. Under XXXX v. XXXX, XXXX XXXX XXXX, XXXX ( XXXX Cir. XXXX ), accessing a consumer 's credit report without a permissible purpose is an actionable FCRA violation regardless of whether actual damages are proven. Under XXXX XXXX. XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX ( XXXX ), reckless disregard of permissible purpose requirements satisfies the willfulness standard, triggering statutory damages. XXXX FCRA XXXX ( b ) CRA Duty to Prevent Impermissible Furnishing Experian 's Independent Obligation : Experian , as a consumer reporting agency, has an independent duty under FCRA XXXX ( b ) to 'maintain reasonable procedures designed to ... limit the furnishing of consumer reports to the purposes listed under section XXXX. ' Experian 's furnishing of XXXX 's report XXXX times to mortgage entities within 13 days including twice to the same entities within days of each prior pull demonstrates that Experian failed to maintain reasonable procedures to prevent impermissible access. Experian is therefore independently liable for each furnishing that lacked a valid permissible purpose. XXXX XXXX : XXXX v. XXXX XXXX XXXX XXXX. XXXX, XXXX XXXX XXXX, XXXX ( XXXX Cir. XXXX ) ( CRA liable under XXXX ( b ) for failing to maintain procedures that prevent impermissible report furnishing ) ; XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX ( XXXX XXXX. XXXX ) ( CRA must verify existence of permissible purpose before furnishing report ). XXXX FCRA XXXX Willful Violation by Each Respondent Willfulness Standard : XXXX XXXX. XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) ( willfulness encompasses reckless disregard of known legal requirements ). Each respondent operates in the mortgage credit reporting industry and is or should be fully aware of FCRA XXXX 's permissible purpose requirements. Pulling a consumer 's credit report twice in XXXX day ( CREDCO/UWM ) or twice within 6 days ( XXXX XXXX XXXX XXXX XXXX XXXX new consumer-initiated transaction demonstrates reckless disregard of XXXX 's clear requirements. Statutory Damages Exposure : At {$100.00} {$1000.00} per willful violation, XXXX impermissible inquiries creates statutory exposure of {$600.00} {$6000.00} per respondent entity, plus punitive damages and attorney fees under XXXX ( a ) ( XXXX ) - ( XXXX ). This does not include actual damages from XXXX XXXX suppression affecting XXXX 's mortgage rate and terms. XXXX XXXX XXXX XXXX Unfairness Three-Prong UDAAP Unfairness Analysis : An act or practice is unfair under XXXX U.S.C. XXXX ( c ) if it : ( XXXX ) causes or is likely to cause substantial injury ; ( XXXX ) the injury is not reasonably avoidable; and ( XXXX ) the injury is not outweighed by countervailing benefits to consumers or competition. Prong XXXX XXXX XXXX : XXXX hard inquiries suppress XXXX 's XXXX score by an estimated XXXX points cumulatively. In the mortgage lending context, even a XXXX score reduction can increase the interest rate offered by 0.25 % to 0.50 %, costing Complainant thousands of dollars over the life of a loan. This is substantial, quantifiable, ongoing injury. Prong XXXX Not Reasonably Avoidable : Complainant did not separately authorize XXXX distinct credit pulls. She initiated a mortgage application process. The proliferation of downstream XXXX each pulling independent hard inquiries is entirely outside the consumer 's control she had no opportunity to prevent or limit these pulls once the process began. Prong XXXX XXXX XXXX XXXX : There is no consumer benefit to having the same credit report pulled 6 times by XXXX entities within 13 days. A single comprehensive tri-merge report serves the purpose of mortgage underwriting. The additional pulls benefit only the intermediary entities seeking current data for their internal processes, not the consumer. XXXX Additional Case XXXX XXXX Impermissible Purpose Cases : XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX ( XXXX XXXX. XXXX ) ( permissible purpose must exist at the exact moment of access ; can not be assumed from prior authorization ) ; XXXX v. XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX. XXXX XXXX, XXXX ( XXXX. Ky. XXXX ) ( accessing credit report without clear permissible purpose violates XXXX regardless of industry practice ) ; XXXX XXXX Attorney XXXX XXXX, XXXX XXXX XXXX. XXXX, XXXX ( XXXX Md. XXXX ) ( FCRA permissible purpose provisions are strictly construed ; good faith belief is insufficient if the legal standard is not met ) ; XXXX v. XXXX, XXXX XXXX XXXX, XXXX ( XXXX Cir. XXXX ) ( FCRA provisions protecting consumers from unauthorized access are strictly enforced ). V. HARM TO COMPLAINANT XXXX XXXX Suppression : XXXX hard inquiries XXXX within 13 days have artificially depressed Complainant 's XXXX score. Complainant 's current score of XXXX ( Very Good ) could have been at XXXX ( Exceptional ) without these impermissible inquiries, qualifying her for better mortgage rates and terms. XXXX XXXX from XXXX Mortgage XXXX : A suppressed XXXX XXXX in the mortgage application process directly results in higher interest rates. On a {$420000.00} mortgage ( as appears on XXXX 's Experian report ), even a 0.25 % rate increase resulting from score suppression adds approximately {$20000.00} {$25000.00} in interest over a XXXX loan term. This is real, quantifiable monetary harm caused by these impermissible inquiries. XXXX XXXX XXXX Damage : All XXXX inquiries remain scheduled on XXXX 's credit report through XXXX XXXX continuing to suppress her score and misrepresent her credit-seeking activity to future creditors for over a year. Privacy Violation : Each impermissible inquiry constitutes an unauthorized access to XXXX 's private financial data. The FCRA was specifically enacted to protect consumers from exactly this type of unauthorized disclosure of their credit information. See FCRA XXXX, XXXX XXXX. XXXX ( Congressional findings on privacy rights in consumer credit data ). Inability to Reasonably Avoid Harm : XXXX had no mechanism to prevent downstream mortgage XXXX from independently pulling her credit file once the application process was initiated. The harm is systemic, consumer-unfair, and directly traceable to the respondents ' disregard for XXXX 's permissible purpose requirements. Active Fraud Alert on File : My Experian credit report dated XX/XX/XXXX, confirms that an active Identity Security Alert has been placed on my file since XX/XX/XXXX ( Reference No. XXXX ), which states : 'FRAUDULENT APPLICATIONS XXXX BE SUBMITTED IN MY NAME OR MY IDENTITY XXXX HAVE BEEN USED WITHOUT MY CONSENT TO FRAUDULENTLY OBTAIN GOODS OR SERVICES. ' The presence of XXXX Illinois addresses neither of which I have ever occupied is directly consistent with identity theft activity and must be treated with heightened urgency in light of this active fraud alert. FCRA XXXX ( XXXX ) Experian Is a 'Person ' Bound by All FCRA Duties : Experian Information Solutions XXXX XXXX XXXX a corporation and therefore a 'person ' as defined under XXXX U.S.C. XXXX ( b ), which provides that 'the term person means any individual, partnership, corporation, trust, estate, cooperative, association, government or governmental subdivision or agency, or other entity. ' Under XXXX U.S.C. XXXX ( a ), this definition applies to the entire FCRA subchapter, making Experian subject to the maximum accuracy requirements of XXXX ( b ), the reinvestigation obligations of XXXX, and the civil liability provisions of XXXX and XXXX. Disputed Address PO BOX XXXX, XXXX XXXX, IL XXXX Nature of Entry : This is a Post Office XXXX not XXXX residential address. A P.O. Box can not be and has never been a place of residence for any individual. No human being lives at a Post Office Box. Its presence on a consumer credit report as a residential address entry is facially inaccurate as a matter of fact and law. No residential lease, mortgage, utility account, or government record in XXXX 's name has ever been associated with this P.O. Box. Identity Theft Indicator : P.O. Boxes listed on consumer credit files as residential addresses are a well-documented hallmark of identity theft. They are used by fraudsters to receive mail, credit cards, and financial documents obtained through fraudulent applications in a victim 's name, while ensuring the victim never receives notice of the fraud at their actual address. Given Complainant 's active fraud alert, this address is consistent with ongoing identity theft activity and warrants immediate deletion and investigation. FCRA Violation : Experian 's reporting of a P.O. Box as XXXX 's residential address violates the maximum possible accuracy standard of XXXX U.S.C. XXXX ( b ). A P.O. XXXX entry where a residential address is expected is not merely inaccurate it is a categorical impossibility as a residential address. No reasonable procedure for assuring accuracy would permit a P.O. Box to be listed as a consumer 's residential address. A. FCRA XXXX ( b ) Failure to Maintain Maximum Possible Accuracy Statutory Text : XXXX U.S.C. XXXX ( b ) requires that 'whenever a consumer reporting agency prepares a consumer report it shall follow reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates. ' Violation : Experian has failed this standard in XXXX independent respects. First, a P.O. XXXX can not be a residential address any procedure that does not automatically flag and reject P.O. Box entries as residential addresses lacks the minimum reasonableness required by XXXX ( b ). Second, XXXX XXXX XXXX XXXX has never been associated with Complainant through any document she has ever executed. Experian 's procedures failed to verify the source and authenticity of these address entries before including them in her consumer file. XXXX XXXX : XXXX v. XXXX XXXX XXXX XXXX. XXXX, XXXX XXXX XXXX, XXXX ( XXXX Cir. XXXX ) ( CRA that fails to detect obvious inaccuracies violates XXXX ( b ) and can not escape liability by claiming the data came from a furnisher ). XXXX v. XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX, XXXX ( XXXX Cir. XXXX ) ( maximum accuracy standard imposes independent affirmative obligation on CRAs ; satisfaction of furnisher-supplied data does not discharge XXXX ( b ) duty ). XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX ( XXXX Cir. XXXX ) ( CRA 's accuracy obligation is not extinguished by the fact that the incorrect data was reported by a creditor the CRA must independently verify ). XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX ( XXXX Cir. XXXX ) ( CRA violated XXXX ( b ) by maintaining inaccurate information on consumer 's report that was clearly inconsistent with other data in the file ). XXXX FCRA XXXX ( a ) ( XXXX ) Prohibition on Obsolete and XXXX XXXX XXXX XXXX : FCRA XXXX broadly governs the types of information consumer reporting agencies XXXX include in consumer reports. The underlying principle reinforced by XXXX ( a ) ( XXXX ) 's prohibition on XXXX other adverse item of information ' that antedates the report by more than XXXX years reflects XXXX XXXX intent that consumer reports contain only verified, accurate, and current information directly attributable to the consumer. Address information not associated with the consumer through any verifiable, consumer-executed document is not 'information ' that belongs in the consumer 's file at all. Application : Experian maintains both disputed addresses as current, active entries in XXXX 's personal information section. Neither address has ever been verified through any document Complainant executed. The P.O. XXXX is categorically incapable of being a residential address. The XXXX XXXX XXXX address has never appeared on any lease, deed, tax return, utility account, or employment record submitted by or for XXXX. Maintaining unverified, consumer-repudiated address entries violates the spirit and letter of the FCRA 's XXXX framework. XXXX FCRA XXXX Mandatory Reinvestigation and Deletion Statutory Text : XXXX U.S.C. XXXX ( a ) ( XXXX ) ( A ) requires Experian to 'conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate and record the current status of the disputed information, or delete the item from the file ... before the end of the XXXX period beginning on the date on which the agency receives the notice of the dispute from the consumer. ' Section XXXX ( a ) ( XXXX ) ( A ) mandates that if 'an item of information disputed by a consumer is found to be inaccurate, incomplete, or can not be verified... the consumer reporting agency shall promptly delete that item of information from the file of the consumer. ' Can not Be Verified = Mandatory Deletion : Experian can not verify that Complainant ever resided at XXXX XXXX XXXX, XXXX XXXX, IL because a P.O. XXXX is not a residence and no person resides there. Experian can not verify that Complainant ever resided at XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, IL because she never did, and no document in Complainant 's name supports this address. The standard under XXXX ( a ) ( XXXX ) ( A ) is stated in the disjunctive : delete if inaccurate OR incomplete OR unverifiable. All three conditions are satisfied for both addresses. Deletion is not discretionary it is mandatory. XXXX Clock and Notice Requirements : The XXXX reinvestigation clock begins upon Experian 's receipt of this letter as documented by XXXX certified mail. Upon completion, Experian must notify Complainant in writing of the results under XXXX ( a ) ( XXXX ) ( A ). If the addresses are deleted, Experian must provide Complainant with a free revised credit report under XXXX ( a ) ( XXXX ) ( B ) ( ii ). Failure to meet any of these deadlines is itself an independent FCRA violation. Additional Basis FCRA XXXX Identity Theft Block : XXXX U.S.C. XXXX requires a consumer reporting agency to block reporting of information identified by the consumer as arising from identity theft within XXXX business days of receiving : ( XXXX ) appropriate proof of identity ; ( XXXX ) a copy of an identity theft report ; ( XXXX ) the consumer 's identification of such information; and ( XXXX ) a statement that the information does not relate to any transaction by the consumer. Complainant hereby provides items ( XXXX ) and ( XXXX ) in this letter. Upon receipt of XXXX 's government-issued ID and identity theft report ( if filed ), Experian must block both addresses within XXXX business days under XXXX. XXXX XXXX : XXXX v. XXXX XXXX, XXXX XXXX XXXX, XXXX ( XXXX Cir. XXXX ) ( CRA 's failure to delete unverifiable address information following consumer dispute is actionable under XXXX ). XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX ( XXXX Cir. XXXX ) ( reinvestigation must be substantive and meaningful CRA can not simply confirm that the address appears in its system ; it must verify that the consumer actually associated with the address ). XXXX v. XXXX XXXX Bank, XXXX, XXXX XXXX XXXX, XXXX ( XXXX Cir. XXXX ) ( rubber-stamp reinvestigation that merely confirms existing file data without independent verification fails the XXXX standard and supports willfulness finding ). XXXX FCRA XXXX and XXXX Willful and Negligent Noncompliance Willful Noncompliance ( XXXX ) : Experian is XXXX of the XXXX largest consumer reporting agencies in the world with thousands of compliance employees, decades of FCRA enforcement history, and full knowledge of its legal obligations. Maintaining a P.O. XXXX as a residential address in a consumer file is not a subtle technical error it is a facially obvious impossibility that any reasonable accuracy procedure would flag automatically. Experian 's failure to have a procedure that rejects P.O. Box entries as residential addresses constitutes reckless disregard of its XXXX ( b ) obligations under XXXX XXXX. XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, XXXX ( XXXX ). Statutory damages of {$100.00} {$1000.00} per violation plus punitive damages are available under XXXX. Negligent Noncompliance ( XXXX ) : At minimum, Experian 's failure to verify both disputed addresses before including them in XXXX 's file, and its failure to detect an obviously non-residential P.O. XXXX as a residential address, constitutes negligent noncompliance. Under XXXX, Experian is liable for XXXX 's actual damages resulting from the maintenance of these false addresses, including emotional distress, time expended in dispute, reputational harm, and any credit or background check harm caused by the presence of unrecognized addresses in her file. XXXX XXXX XXXX Unfair and Deceptive Acts or Practices ( UDAAP ) Unfairness : Maintaining false addresses including a P.O. XXXX and an address Complainant has never occupied causes substantial harm : it creates a misleading picture of XXXX 's residential history for any employer, landlord, or creditor reviewing the report ; it XXXX trigger fraud flags by lenders who see mismatched addresses ; and it undermines the integrity of XXXX 's identity verification. The harm can not be avoided by Complainant because she has no control over what Experian maintains in her file. No countervailing benefit exists to any party from maintaining demonstrably false residential information. All three XXXX unfairness prongs are satisfied. Deception : A consumer report displaying a P.O. XXXX and an unoccupied Illinois residential address as part of XXXX XXXX 's personal history is materially misleading to anyone relying on the report. Lenders, employers, and landlords use address history for identity verification false addresses undermine the accuracy of that verification and XXXX cause Complainant to be misidentified, denied services, or flagged as a fraud risk based on information she never supplied and never authorized. IV. FORMAL DEMANDS Experian is hereby formally demanded to take ALL of the following actions within the timeframes specified : IMMEDIATE DELETION ( within XXXX business days under XXXX, or 30 days under XXXX ) : Permanently delete BOTH disputed addresses from Complainant 's Experian XXXX file : ( XXXX ) XXXX XXXX XXXX, XXXX XXXX XXXX IL XXXX XXXX WRITTEN CONFIRMATION ( within XXXX business days of deletion ) : Provide Complainant with written confirmation that both addresses have been permanently removed from her consumer file. REVISED CREDIT REPORT ( within XXXX business days of deletion ) : Provide Complainant with a free, updated copy of her Experian credit report reflecting the deletion of both disputed addresses, as required under XXXX U.S.C. XXXX ( a ) ( XXXX ) ( B ) ( ii ). SOURCE INVESTIGATION : Identify and disclose to Complainant the furnisher ( XXXX ) who submitted or caused each disputed address to appear in her Experian file, consistent with Complainant 's right to know the source of information under XXXX XXXX. XXXX ( a ) ( XXXX ). V. NOTICE OF REGULATORY COMPLAINTS AND LEGAL ACTION Please be advised that concurrent with this letter, Complainant is filing formal complaints with : Consumer Financial Protection Bureau ( CFPB ) consumerfinance.gov/complaint Federal Trade Commission XXXX FTC ) XXXX and XXXX Texas Attorney General XXXX XXXX XXXX XXXX XXXX Illinois Attorney General XXXX XXXX XXXX XXXX XXXX XXXX XXXX over Illinois addresses XXXX Failure to comply with the demands herein within the statutory timeframes will result in civil litigation under XXXX U.S.C. XXXX and XXXX seeking : ( a ) actual damages for all harm caused by the maintenance of false address information ; ( b ) statutory damages of {$100.00} {$1000.00} per willful violation ; ( c ) punitive damages ; and ( d ) attorney fees and costs. The maintenance of a P.O. XXXX as a residential address a facially impossible entry supports a strong willfulness finding under XXXX XXXX. XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ), as the impossibility of a P.O. XXXX as a residence should have been detected by any reasonable accuracy procedure.

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