Consumer complaint received 2025-10-19 00:00:00
Product: Debt collection — Medical debt
Issue: Attempts to collect debt not owed — Debt is not yours
Company: Sequium Asset Solutions, LLC
State: UT

Complaint narrative:
On XX/XX/XXXX, at XXXXXXXX XXXX MST, I received an unsolicited automated text message from short code XXXX stating : Hi XXXX XXXX. Sequium Asset Solutions , LLC is a debt collector collecting upon your XXXX XXXX XXXX XXXX XXXX account ending in XXXX. Included with this message is your Model Validation Notice providing pertinent information concerning this matter. This is an attempt to collect a debt by a debt collector. Any information obtained will be used for that purpose. # of Messages Varies. Message & Data Rates May Apply. Payments and Info : XXXX XXXX XXXXsequiumXXXX XXXX and XXXX. Please use reference number XXXX to access your account. If you are not this person or wish to opt out of text messages from Sequium Asset Solutions , LLC, reply STOP. This one-way text is not monitored for responses except STOP and HELP. Under binding federal law interpretation, this conduct violates 15 U.S.C. 1692g ( a ) and 1692e ( 10 ).

This filing marks the beginning of my formal administrative process in preparation for litigation against Sequium Asset Solutions , LLC. I am documenting each statutory violation as part of a structured pre-suit record. My intent is to fulfill the courts requests and offer the opportunity to settle privately before pursuing civil action for Sequiums willful and repeated violations of federal and state law. 
I have never had any prior relationship with Sequium Asset Solutions , LLC, nor have I provided express written consent for them to contact me via text message. Upon information and belief, this message was delivered through an automated system, as shown by the short code, opt-out commands, and embedded payment link. Immediately after receiving the text, I sent a statutory notice citing their violations. Sequiums platform instantly generated a second text stating : This is a one-way text. Text responses containing images/attachments are not viewable. For more contact options, reply HELP. To Opt out, reply STOP.

This confirmed the use of an autodialed short-code platform, constituting a second unlawful transmission.

This alleged debt had previously been disputed with another collector, who admitted in a prior CFPB response that they could not validate the account through their actions and confirmed they would cease collection activity. Sequium has unlawfully re-initiated collection without obtaining validation, authorization, or legal standing. This constitutes a continuation of collection activity on an unvalidated debt in violation of 15 U.S.C. 1692g ( b ). Courts have consistently held that continuing collection efforts without proper validation violates the FDCPA. See XXXX v. XXXX XXXX. XXXX, XXXX XXXX XXXX XXXX ( XXXX Cir. XXXX ) ; XXXX v. XXXX XXXX & XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ). Sequium also violated 1692e ( 2 ) ( A ) by falsely representing the legal status of the debt and 1692e ( 10 ) by using deceptive means, specifically, implying that a text message and linked electronic PDF constituted a lawful validation notice. By contacting me via unconsented electronic means, Sequium violated 1692c ( a ) ( 1 ), and by using an automated system for debt collection, it engaged in conduct whose natural consequence was harassment under 1692d. Sequiums use of an electronic Model Validation Notice form was itself a deceptive practice under 1692j. These actions together constitute willful and knowing violations of the FDCPA, entitling me to statutory damages of {$1000.00} plus actual damages and attorneys fees.

Sequiums delivery of a legally required debt-collection notice electronically, without documented consumer consent, also violates the Electronic Signatures in Global and National Commerce Act ( E-SIGN Act ), 15 U.S.C. 7001 ( c ), which requires clear consumer consent and disclosure before transmitting legally required notices electronically. Sequium provided neither, rendering the notice void and deceptive. 
Additionally, Sequiums first and second text messages each violate the Telephone Consumer Protection Act ( TCPA ), 47 U.S.C. 227 ( b ) ( 1 ) ( A ) ( iii ), which prohibits the use of autodialed or prerecorded text messages to a cell phone without prior express written consent. Courts have confirmed that each separate text transmission constitutes a distinct violation. See XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) ; XXXX XXXX v. XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ). Sequium therefore committed at least two TCPA violations, each carrying statutory damages of {$500.00} to {$1500.00}, for a total exposure of {$1000.00} to {$3000.00}.

At the state level, Sequium committed two separate deceptive acts under the Utah Consumer Sales Practices Act ( UCSPA ), Utah Code 13-11-4 ( 2 ) ( a ). The first deceptive act occurred when Sequium re-initiated collection on a previously disputed and unvalidated debt, misrepresenting both the debts legal status and its right to collect. The second deceptive act occurred when Sequium falsely represented that an unsolicited text message and attached electronic PDF constituted lawful validation under federal law. Under Utah law, each deceptive act carries statutory damages of up to {$2000.00}, for a total of {$4000.00}. See XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX ( misrepresentation of legal rights constitutes a deceptive act ). Sequium also violated the Utah Telephone and Facsimile Solicitation Act ( XXXX ), Utah Code 13-25-101 et seq., which prohibits unsolicited automated text messages to consumers without consent, adding an additional {$500.00} to {$1000.00} in statutory exposure. Sequiums own published policies confirm its misconduct. Its Privacy Policy claims to protect consumer information yet expressly limits those protections to online information gathering and dissemination practices and excludes any practices conducted offline. In other words, Sequium publicly represents itself as privacy-compliant while simultaneously disclaiming responsibility for protecting consumer information in its actual debt-collection operations. Despite this contradiction, Sequiums Compliance page asserts that it integrates all regulatory requirements into daily process flows, provides FDCPA and state-law training, and maintains the highest levels of compliance and reliability. These representations are materially false and deceptive given Sequiums conduct. Specifically, sending automated debt-collection texts without consent and falsely implying that a link to an electronic PDF constituted a lawful Model Validation Notice. This contradiction between Sequiums promises and its actions constitutes false and deceptive representations under 15 U.S.C. 1692e ( 10 ) and the Utah Consumer Sales Practices Act, Utah Code 13-11-4 ( 2 ) ( a ) ( b ).

Sequiums Terms of Use also apply solely to website visitors and explicitly disclaim that unsolicited communications create any relationship. Therefore, the company can not rely on those terms to justify an automated text contact. By holding itself out as PCI- and SOC-2-certified, privacy-compliant, and FDCPA-trained while breaching those same obligations, Sequium engaged in deceptive and misleading business practices warranting enforcement and statutory damages.

This complaint also serves as a formal debt-validation request under 15 U.S.C. 1692g ( b ). Sequium Asset Solutions , LLC is required to provide, by physical mail, full proof of ownership, the complete assignment chain, and the original contract. Until proper validation is mailed, Sequium must cease all collection activity and ensure that no credit reporting occurs related to this account. Sequiums cumulative statutory exposure for its federal and state violations ranges from approximately {$7000.00} to {$9000.00}, excluding actual damages and attorneys fees. Its actions were not accidental or technical ; they were deliberate, knowing, and repeated. This behavior demonstrates reckless disregard for consumer protection law and ongoing patterns of misconduct. 
I reserve the right to forward this complaint and evidence to the Federal Communications Commission, the Federal Trade Commission, and the Utah Division of Consumer Protection for additional enforcement under the TCPA, FDCPA, and UCSPA.

Company response to consumer: Closed with non-monetary relief