Consumer complaint received 2025-08-12 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:
The central issue that Ive raised in more than five separate disputes is that neither XXXX XXXX nor XXXX  has provided legally sufficient documentation proving they have current legal ownership or the lawful right to collect or report this debt.

Equifax has knowingly reframed my legal ownership dispute as if I claimed the account is not mine, which is false, and deliberately avoids addressing the actual dispute. 

This is a supplemental submission to CFPB Complaint # XXXX challenging Equifaxs XX/XX/XXXX response regarding the XXXX  XXXX XXXX XXXX XXXX ) tradeline tied to a XXXX  XXXX account ending in XXXX. The evidence below proves that Equifaxs reinvestigation is incomplete, legally inaccurate, unverifiable and violates multiple provisions of the Fair Credit Reporting Act ( FCRA ). 

XXXX. SEC Proven Lack of Legal Ownership I have provided SEC filed legal documents specifically the XXXX Omnibus Securitization Agreement ( EX-4.1.1 ) proving XXXX XXXX XXXX  XXXX XXXX ) XXXX XXXX. transferred all receivables into the XXXX  XXXX XXXX XXXX and the XXXX  XXXX Multi-Asset Execution Trust, making them trust property. Trust receivables can not be sold, assigned, or transferred to third-party debt buyers without lawful removal from the trust, a process that requires documented proof. 

No such proof has been provided by either XXXX XXXX or XXXX XXXX XXXX. Without a lawful removal, XXXX XXXX had no legal right to sell this account to XXXX, and XXXX has no legal right to report or collect it. 

Despite this, Equifax marked the account verified without obtaining : A bill of sale identifying my account. 
A complete chain of title from XXXX XXXX to XXXX. 
Proof of lawful removal from the trust. 

This alone makes the account legally unverifiable under the FCRA. 

XXXX. XXXX Equifax Investigations On XX/XX/XXXX, XXXX investigation results claimed this account was not on my credit file. 
On XX/XX/XXXX, Equifax verified the same account as belonging to me.

These two results are mutually exclusive. If the account was not on my credit file in XXXX, there is no lawful explanation for it being verified in XXXX without : Written notice of reinsertion under FCRA 611 ( a ) ( 5 ) ( B ), and Complete documentation proving the tradelines accuracy and ownership.

No such notice or documentation was provided.

Proof of Unverifiability : Without proper reinsertion notice and supporting ownership documentation, this tradeline is legally unverifiable under the FCRA and must be deleted.

3. Equifaxs Misrepresentation of My Dispute At no point have I disputed the account based on identity. 
My dispute concerns legal ownership, enforceability, and reporting rights. 

Equifax reframed my dispute as an identity issue by claiming they simply verified that the account belongs to me. This reframing allowed Equifax to sidestep the ownership question the core of my dispute and close the investigation without obtaining the documentation the law requires. 
This tactic constitutes a knowing and willful misrepresentation of the nature of my dispute, violating FCRA 611 ( a ) ( 4 ) and undermining the dispute process entirely.

Proof of Unverifiability : Since the ownership question was never addressed, and no chain-of-title or bill of sale was produced, the tradeline remains unverifiable by law.

4. FCRA 611 ( a ) ( 5 ) ( A ) Requirement to Delete or Modify Information That Can not Be Verified Citation : 15 U.S.C. 1681i ( a ) ( 5 ) ( A ) If disputed information can not be verified during a reinvestigation, the CRA must promptly delete it from the file.

This includes cases where the furnisher can not produce documentary proof of ownership ( bill of sale, chain of title, lawful transfer ).

CRAs have no discretion to retain unverifiable information just in case.

Deletion must occur immediately after the reinvestigation. 

Why this applies here : XXXX has provided no proof of legal ownership. 
XXXX XXXX has provided no proof of lawful transfer to XXXX. 
Equifax had a legal duty to delete the tradeline and instead marked it verified.

Proof of Unverifiability : Without documentary proof of ownership, Equifaxs continued reporting violates 611 ( a ) ( 5 ) ( A ) and makes the tradeline legally unverifiable.

5. Point-by-Point Rebuttal to Equifaxs XX/XX/XXXX CFPB Response Equifax stated XXXX Equifax verified that this item belongs to you.

Rebuttal : Misrepresentation of my dispute. I never claimed the account was not mine. The dispute concerns ownership rights, not identity.

Proof of Unverifiability : No bill of sale, chain of title, or lawful transfer documentation means ownership remains unproven and the account is unverifiable.

Equifax stated : We first review and consider any relevant information you submitted regarding the nature of your dispute. 
Rebuttal : No evidence exists that my SEC filings, XXXX letters, and ownership-rights evidence were reviewed.

Proof of Unverifiability : Ignoring relevant ownership evidence invalidates the reinvestigation and leaves the account unverified.

Equifax stated : We electronically send a notification of your dispute, including a summary of the relevant information submitted, to the respective furnisher.

Rebuttal : If only a summary was sent, Equifax violated 611 ( a ) ( 2 ).

Proof of Unverifiability : XXXX could not have verified the account without receiving the ownership documentation I submitted, making the tradeline unverifiable. 

Equifaxs Dispute Process statement : We request that the reporting company verify the accuracy of the information you disputed Rebuttal : Equifax did not require XXXX to provide ownership documentation and accepted a generic response code.

Proof of Unverifiability : Without actual documentation, no lawful verification occurred the account is unverifiable.

6. FCRA Violations by Equifax ( with Supporting Evidence of Unverifiability ) 1. FCRA 607 ( b ) Failure to assure maximum possible accuracy.

Evidence : Continued reporting without proof of ownership = tradeline unverifiable.

2. FCRA 611 ( a ) ( 1 ) Failure to conduct a reasonable reinvestigation.

Evidence : No bill of sale, chain of title, or transfer documentation = tradeline unverifiable.

3. FCRA 611 ( a ) ( 2 ) Failure to forward all relevant information.

Evidence : Ownership evidence and SEC filings not sent to XXXX= tradeline unverifiable.

4. FCRA 611 ( a ) ( 4 ) Failure to review all relevant information.

Evidence : No mention of ownership documents in results = tradeline unverifiable.

5. FCRA 611 ( a ) ( 5 ) ( A ) Failure to delete unverifiable information.

Evidence : XXXX  failed to prove ownership ; tradeline left on file = tradeline unverifiable.

6. FCRA 611 ( a ) ( 6 ) ( B ) ( iii ) Failure to describe verification procedure.

Evidence : No explanation of what documents were reviewed = tradeline unverifiable.

7. FCRA 611 ( a ) ( 7 ) Failure to provide documentation relied upon.

Evidence : No copies of ownership proof provided = tradeline unverifiable.

Proof I Already Submitted In my original CFPB and Equifax dispute filings, I provided direct, documented evidence establishing that neither Capital One nor XXXX XXXX XXXX XXXX XXXXXXXX  ) holds current legal ownership rights to this account or has the lawful authority to collect or report it. This evidence included : SEC Filing EX-4.1.1 XXXX  Omnibus Securitization Agreement showing that XXXX XXXX XXXX XXXX XXXX ) XXXX XXXX. transferred all receivables into the XXXX XXXX XXXX XXXX and XXXX XXXX Multi-Asset Execution Trust. Once transferred, these receivables became trust property and could not be sold, assigned, or otherwise transferred to third-party debt buyers such as XXXX unless they were lawfully removed from the trust a process for which no proof has been provided. 
XXXX  XX/XX/XXXX Response Letter claiming they purchased the account on XX/XX/XXXX, but offering only partial account data and generic business records with no bill of sale, no complete chain of title, and no documentation linking me specifically to the debt. 
Multiple XXXX customer letters responding to my disputes that failed to provide : A signed, dated bill of sale identifying my account. 
A complete chain of title tracing ownership from XXXX XXXX to XXXX. 
Any proof that XXXX XXXX had the legal right to transfer the account at the time of sale. 
My explicit, repeated dispute statements requesting the above ownership documentation as the only legally valid means of verifying this account under the FCRA. 

Despite receiving this clear, documented evidence, Equifax ignored the absence of ownership proof and issued a generic verified result, misrepresenting my dispute as an identity issue instead of addressing the legal ownership and reporting rights.

Demand for Verification Documentation Pursuant to FCRA 611 ( a ) ( 7 ), I require Equifax to produce : 1. A full, unedited description of the procedure used to verify the XXXX tradeline. 
XXXX. Copies of all documents obtained from XXXX during this reinvestigation, including : Bill of sale or assignment identifying my account. 
Complete chain of title from XXXX XXXX to XXXX. 
Proof of lawful transfer giving XXXX reporting and collection rights. 
XXXX. Any internal Equifax notes, dispute codes, or communications with XXXX. 
XXXX. Evidence that my ownership-rights documentation and prior submissions were forwarded to XXXX. 

If these materials can not be produced, the account is legally unverifiable and must be deleted immediately under FCRA 611 ( a ) ( 5 ) ( A ).

Company response to consumer: Closed with non-monetary relief