Consumer complaint received 2024-12-16 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:
Complainant has submitted multiple direct disputes to XXXX XXXX XXXX XXXX ( " XXXX '' ) and indirect disputes through credit reporting agencies ( CRAs ) regarding an alleged collection account attributed to Complainant. XXXX first responded to Complainant on or around XXXX XX/XX/XXXX, providing a purported debt validation letter that listed an alleged balance of {$740.00}. However, the billing statement enclosed as " validation evidence '' from the purported original creditor listed a different alleged balance of {$940.00}. The validation letter also stated that XXXX had requested the account be marked as " disputed '' with the CRAs. 
Following Complainant 's initial CFPB complaint ( XXXX XXXX. XXXX ), XXXX responded XXXX XXXX XX/XX/XXXX, asserting that the account had been placed in " restrictive status '' to prevent further collection. XXXX reiterated its validation efforts but did not address significant discrepancies in the information furnished to the CRAs, including : XXXX. Inconsistent Dates of First Delinquency ( " DoFDs '' ) : XXXX reported discordant DoFDs to the CRAs. 
XXXX. Unsubstantiated Debt Balances : Continued to report the alleged {$740.00} balance, even though TSIs own validation evidencea billing statement from the purported original creditorlisted a different balance of {$940.00}, thereby rendering the furnished information for the account inaccurate and materially misleading under the FCRA ; and XXXX. Failure to Address Evidence Provided by Complainant : Complainant submitted evidence, including an image of a draft payment the original creditor failed to apply, further demonstrating the alleged balance was inaccurate.

While the FDCPA ( 15 U.S.C. 1692g ) requires validation limited to confirming the debt with the original creditor, the FCRA ( 15 U.S.C. 1681s-2 ( b ) ) imposes more stringent duties on furnishers of information. Under the FCRA, XXXX is required to : 1. Conduct a reasonable and independent investigation of disputes ; 2. Correct, delete, or block inaccurate or unverifiable information ; and 3. Ensure that furnished information is accurate and complete.

TSI 's continued reliance on its FDCPA validation to justify the alleged debt fails to meet the investigatory standard required by the FCRA. Despite receiving direct disputes from Complainant and indirect disputes via the CRAs, XXXX has : Verified each discordant DoFD as accurate with the respective CRA ; Continued to report the alleged {$740.00} balance without addressing the evidence provided; and Ignored documentation submitted by Complainant, which demonstrated that the balance was materially misleading due to the unprocessed draft payment. 
By failing to meet its investigatory obligations under the FCRA, XXXX has furnished materially inaccurate and incomplete information, causing harm to Complainants credit profile and violating federal law. 
By failing to adhere to its statutory obligations under both the FDCPA and the FCRA, XXXX has : XXXX. Failed to provide Complainant with a validation notice within XXXX days of its initial communication, in violation of the FDCPA 809 ( a ), 15 U.S.C. 1692g ( a ).

2. Continued to report information about the alleged collection account to CRAs after failing to verify the debt in response to Complainants validation request, in violation of the FDCPA 809 ( b ), 15 U.S.C. 1692g ( b ).

3. Engaged in unfair and unconscionable means to collect the alleged debt, including furnishing inaccurate and misleading information to CRAs and failing to correct known inaccuracies, in violation of the FDCPA 808, 15 U.S.C. 1692f.

4. Furnished information to CRAs about an alleged collection account it attributed to Complainant but failed to furnish consistent Dates of First Delinquency ( DoFDs ) for that account to the CRAs. This inconsistency constitutes a violation of the FCRA 623 ( a ) ( 5 ), 15 U.S.C. 1681s-2 ( a ) ( 5 ).

5. Failed to conduct reasonable investigations in response to Complainants direct disputes communicated to Respondent by Complainant, in violation of the FCRA 623 ( b ) ( 1 ) ( B ), 15 U.S.C. 1681s-2 ( b ) ( 1 ) ( B ). Instead, Respondent substituted its investigatory obligations under 15 U.S.C. 1681s-2 ( b ) with its debt validation process under 15 U.S.C. 1692g, which is limited to confirming the debt with the original creditor and does not require an independent investigation into the accuracy or completeness of the information furnished to CRAs. 
This conduct by XXXX is not new, as it has a documented history of engaging in similar violations of consumer protection laws. Under the XXXX CFPB Consent Order ( In re XXXX XXXX XXXX XXXX, File No. XXXX ), XXXX was found to have engaged in similar conduct involving systemic failures to comply with federal laws governing debt collection and credit reporting. Specifically, XXXX : 1. Filed false or misleading affidavits in state and federal court proceedings to substantiate debt collection claims it could not verify.

2. Provided inaccurate or incomplete testimony regarding the validity of debts it pursued.

3. Attempted to collect debts without sufficient documentation or evidence to demonstrate the debts were owed.

4. Engaged in practices that the CFPB explicitly deemed unfair and deceptive under federal law, including pursuing collection actions and reporting to CRAs based on unreliable or misleading information.

These violations demonstrate TSIs systemic disregard for legal obligations and highlight its continued reliance on deceptive practices to minimize its compliance burdens under the FDCPA and FCRA.

TSIs actions in this case are consistent with its documented history of disregarding legal obligations and engaging in deceptive and unfair practices. Despite being subject to the CFPBs XXXX Consent Order, XXXX has continued to furnish inaccurate and misleading information, failed to conduct reasonable investigations into disputes, and violated its obligations under the FDCPA and FCRA. This conduct has caused significant harm to the complainant, including financial instability and reputational damage, and has further undermined the integrity of the credit reporting system.

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