Consumer complaint received 2025-09-16 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Problem with a company's investigation into an existing problem — Their investigation did not fix an error on your report
Company: Portfolio Recovery Associates, LLC
State: GA

Complaint narrative:
# # CFPB Complaint Draft : Reinsertion Violation & Regulatory Failure * * Subject : * * Repeat Dispute Mishandling, Duplicate Responses from XXXX, and Reinsertion Violations Across All Three Bureaus * * Consumer Name : * * XXXX XXXX XXXX * * Account in Question : * * PRA account ending in XXXX * * Previous CFPB Complaint IDs XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Summary of Complaint : I am submitting this third complaint regarding Portfolio Recovery Associates , LLC ( PRA ) and their continued furnishing of disputed information to XXXX XXXX XXXX XXXX XXXX Despite submitting two separate complaints through CFPB ( IDs listed above ), PRA responded with * * identical boilerplate letters * * that failed to address the core contradictions in my dispute file. 

I submitted a full contradiction archive and copies of all three credit reports showing inconsistent reporting of the same PRA account. PRA did not provide full validation, did not reconcile the contradictions across bureaus, and did not notify me in writing before continuing to report the account * * a direct violation of FCRA 611 ( a ) ( 5 ) ( B ) XXXX XXXX XXXX XXXX XXXX XXXX  Violations Documented : - * * FCRA 611 ( a ) ( 5 ) ( B ) : * * PRA continues reporting without notifying me in writing before reinsertion or correction.

- * * FCRA 623 ( a ) ( 3 ) : * * PRA furnishes information they know is disputed and potentially inaccurate.

- * * FDCPA 807 : * * Misrepresentation of resolution status and failure to cease collection activity.

- * * CFPB Oversight Failure : * * CFPB closed both prior complaints despite unresolved contradictions and duplicate responses. XXXX XXXX XXXX XXXX XXXX Requested Action : 1. * * Reopen both prior complaints * * and investigate PRAs duplicate responses.

2. * * Audit PRAs certification of accuracy * * and reinsertion logs across all three bureaus.

3. * * Require PRA to provide full validation documentation * *, including chain of custody, billing history, and signed agreements.

4. * * Investigate CFPBs internal handling of repeat complaints * * and failure to escalate systemic contradictionXXXX XXXX XXXX XXXX XXXX XXXX  Supporting Documents : - PRAs duplicate response letters- Credit reports from XXXX XXXX XXXX XXXX  - Contradiction archive submitted via CFPB - Timeline of disputes and bureau responses To Whom It XXXX Concern, I am submitting this formal contradiction and override demand regarding the PRA Group account # XXXX, which has been inaccurately and inconsistently reported across Experian, Equifax, and TransUnion, and misrepresented by PRA Group in their response to the Consumer Financial Protection Bureau ( CFPB ). Below is a full forensic breakdown of the contradictions and breaches, followed by PRAs full response to the CFPB for direct comparison. 
EXPERIAN REPORT Provided by Me Account opened XX/XX/XXXX, status frozen since XX/XX/XXXX Balance updated XX/XX/XXXX, with no status refresh Monthly C ( Collection ) status from XX/XX/XXXX to XX/XX/XXXX No payments, no resolution, no verified activity Disputes logged : XX/XX/XXXX to XX/XX/XXXX, XX/XX/XXXX to XX/XX/XXXX Reinvestigation processed only in XX/XX/XXXX Consumer statement : THIS ACCOUNT SHOULD NOT BE IN COLLECTIONS AND SHOULD BE REMOVED FROM MY REPORT Bureau comment : Completed investigation of FCRA dispute consumer disagrees Contradiction : PRA claims resolution, yet Experian shows unresolved dispute, delayed reinvestigation, and frozen status for 4 years. 
XXXX REPORT Fully Expanded Date of Last Reported Update : XX/XX/XXXX Balance Amount : {$790.00} Date of First Delinquency : XX/XX/XXXX Date of Last Payment : Blank Actual Payment Amount : Blank Scheduled Payment Amount : Blank Date of Last Activity : Blank Charge-Off Amount : Blank Deferred Pay Start Date : Blank Balloon Pay Date : Blank Balloon Pay Amount : Blank Date Closed : Blank Status : Blank Type of Account : Open Type of Loan : Debt Buyer Whose Account : Individual Portfolio Indicator : Original Creditor Portfolio Status : XXXX XXXX XXXX XXXX XXXX XXXX 
Account History Status Codes : Collection from XX/XX/XXXX to XX/XX/XXXX Dispute Status : Disputed from XX/XX/XXXX to Present Resolution Comment : Consumer disagrees after resolution Final Status Before Deletion : Collection account remains on report Current Status : dispute active Contradiction : PRA claimed no dispute was received and that validation resolved the issue. Equifax shows a continuous dispute for 2+ years, unresolved status, confirming the data was unverifiable and or improperly furnished. 
XXXX REPORT Provided by Me Account opened XX/XX/XXXX, balance {$790.00} Status frozen since XX/XX/XXXX, balance updated Sep 12, 2025 Monthly C ( Collection ) status from XX/XX/XXXX to XX/XX/XXXX Balance history : Static from XX/XX/XXXX to XX/XX/XXXX, {$0.00} paid Disputes logged : XX/XX/XXXX to XX/XX/XXXX, XX/XX/XXXX to XX/XX/XXXX Reinvestigation processed only in XX/XX/XXXX Consumer statement : THIS ACCOUNT SHOULD NOT BE IN COLLECTIONS AND SHOULD BE REMOVED FROM MY REPORT Bureau comment : Completed investigation of FCRA dispute consumer disagrees Contradiction : PRA claims resolution, yet XXXX continues reporting the account with no payment activity or verified updates. 
PRAs FULL CFPB RESPONSE both times the same boilerplate response provided by me Thank you for bringing this matter to our attention. Portfolio Recovery Associates , LLC ( PRA ) takes compliance with all applicable Federal, State and local laws very seriously. We investigated the complaint and found no records supporting the allegation of misconduct, including, without limitation, that PRA violated the Fair Debt Collection Practices Act ( FDCPA ), the Fair Credit Reporting Act ( FCRA ) and/or any other misconduct cited in this complaint regarding the PRA account XXXX in XXXX. We will continue to honor the request to cease all communications regarding the PRA account unless otherwise permitted or required by applicable law. PRA is a " Debt Buyer '' ; PRA purchases delinquent debt from creditors to whom such debt is owed and seeks to collect such debt from those who owe such debt. In so doing, PRA is committed to : obtain and maintain appropriate licenses and registrations to engage in its business practices in each jurisdiction in which it collects ; provide appropriate notifications ; validate account information ; investigate and resolve account-related disputes ; verify the integrity and accuracy of account information furnished to the consumer reporting agencies, XXXX XXXX XXXX XXXX  ; investigate and resolve credit reporting and identity theft related disputes ; and safeguard information, all in accordance with the Fair Debt Collection Practices Act, the Fair Credit Reporting Act as amended, the Gramm-Leach-Bliley Act ; implementing regulations of the Consumer Financial Protection Bureau ; and other Federal , State and local law, and industry guidelines. PRA purchased the XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX credit card account ending in XXXX from XXXX XXXXXXXX, together with the right to receive payment of the balance due on the account, on or about XX/XX/XXXX, XXXX Business records provided to PRA by XXXX XXXX at the time of our purchase verify that the account was opened on XX/XX/XXXX, for XXXX XXXX XXXX XXXX social security number ends in XXXX  and that a balance of {$790.00} was due on the account at the time of XXXX purchase. We sent our initial notification letter to the consumer on or about XX/XX/XXXX. We have no record of a response, or a dispute being received in relation to our initial notification letter. Our records reflect that we subsequently received, investigated, and responded to a dispute regarding the account which was similar to the dispute made in this complaint. In response to that dispute, we sent the consumer a letter, a copy of which is attached, with validating documentation from the original account. The expiration of a statute of limitations limits PRAs ability to pursue legal actions but does not otherwise prohibit PRA from contacting a consumer regarding a debt. PRA furnished information from the account to the consumer reporting agencies in accordance with the Fair Credit Reporting Act as amended, the Consumer Financial Protection Bureau Regulation V, state and local law, and industry guidelines. PRA does not control the way in which the consumer reporting agencies report the information furnished by PRA. Accordingly, any differences in their reporting of the information which PRA furnishes is the responsibility of the consumer reporting agencies, not PRA. In response to this complaint, we reinvestigated the account and are sending the consumer a letter with validating documentation from the original account. We believe that the validation provided resolved the dispute and no further steps in response to the complaint or follow-up actions are required at this time.

Contradiction : PRAs response denies receiving disputes, claims resolution, and deflects responsibility to the bureaus. Yet all three bureaus show disputes, delayed reinvestigation, unresolved status, and XXXX has suppressed it and current disputes across all three bureaus and cfpb Known Practices & Risks Portfolio Recovery Associates , LLC PRA is known to : Report debts to credit bureaus for years without resolution File lawsuits against consumers who dont respond to collection attempts Misclassify accounts, such as reporting debt buyer accounts as open loans Delay or deny reinvestigation of disputes Blame credit bureaus for reporting errors that PRA itself furnished These practices reflect a pattern of systemic abuse and data manipulation that directly contradict their claims to the CFPB and violate multiple provisions of the FCRA and FDCPA.

CFPB Enforcement Actions Against Portfolio Recovery Associates , LLC XXXX CFPB Order Penalty : Over {$27.00} million in consumer refunds and civil fines Violations : FDCPA : Deceptive debt collection practices CFPA : Misleading affidavits and false legal claims Key Findings : o Collected on unsubstantiated debt o Filed misleading affidavits in court o Misrepresented intent to prove debts if contested o Sued on time-barred debt ( outside statute of limitations ) o Claimed debts were legally enforceable when they were not PRA was placed under a consent order prohibiting these practices going forward. 
XXXX CFPB Action Penalty : Over {$24.00} XXXX total {$12.00} XXXX in consumer restitution {$12.00} million civil penalty to CFPBs victims relief fund Violations : FCRA : Failure to properly investigate and resolve credit reporting disputes FDCPA : Continued illegal debt collection practices CFPA : Violated multiple provisions of the XXXX consent order Key Findings : Collected on unsubstantiated debt Sued consumers without documentation Threatened legal action without intent or basis Collected on time-barred debt without required disclosures Failed to provide validation documents within 30 days Blamed credit bureaus for errors PRA itself furnished CFPB XXXX XXXX XXXX XXXX PRA a repeat offender, stating : After getting caught red-handed in XXXX, Portfolio Recovery Associates continued violating the law through intimidation, deception, and illegal debt collection tactics and lawsuits. 
Federal Trade Commission ( FTC ) Enforcement Portfolio Recovery Associates Year XXXX XXXX XXXX XXXX XXXX XXXX Cause : Deceptive debt collection practices and violations of the Fair Debt Collection Practices Act ( FDCPA ) Key Violations : PRA was accused of misrepresenting consumers rights in debt collection notices Sent letters that falsely implied consumers could not dispute debts Failed to disclose that consumers had the right to request verification of the debt Misled consumers about the legal status and enforceability of time-barred debts Used language that threatened legal action without intent or basis FTC Findings : PRAs collection letters violated Section 5 of the FTC Act , which prohibits unfair or deceptive practices PRA also violated the FDCPA, specifically : o 807 ( 2 ) ( A ) : False representation of the character, amount, or legal status of any debt o 807 ( 10 ) : Use of false representation or deceptive means to collect a debt o 809 ( a ) : Failure to notify consumers of their right to dispute the debt Outcome : PRA agreed to a consent decree with the FTC Required to change its collection practices, including : o Clear disclosure of dispute rights o No threats of legal action unless substantiated o No collection on time-barred debts without proper notice How Federal Court Rulings Prove Your Case 1. Pattern of Misrepresentation Federal courts have ruled that PRA : Sued consumers without documentation Misrepresented the validity and enforceability of debts Filed affidavits they knew were false or misleading Collected on time-barred debts without proper disclosures These rulings directly support your claim that PRA : Reported unverifiable debt to credit bureaus Falsely claimed resolution to the CFPB Continued collection despite dispute and deletion XXXX. Violation of Dispute Rights In the XXXX CFPB judgment, the court found PRA : Failed to investigate disputes Improperly rejected valid consumer disputes as frivolous Did not maintain policies to ensure accuracy of credit reporting This aligns with your XXXX XXXX XXXX XXXX records showing : Delayed reinvestigation Ongoing disputes ignored for years No updates or corrections after dispute XXXX. Legal Precedent for Deletion The CFPBs XXXX final judgment required PRA to : Pay {$12.00} XXXX in consumer restitution Delete unverifiable accounts Reform dispute handling and credit reporting practices This sets a legal precedent that : PRAs reporting practices are unlawful Deletion is the correct remedy Consumers like you are entitled to relief 4. Repeat Offender Status Federal courts and agencies have labeled PRA a repeat offender : Violated XXXX CFPB consent order Fined again in XXXX for the same conduct Ignored prior federal mandates This proves systemic misconductnot an isolated errorand strengthens my demand for permanent deletion and regulatory review. 
My Leverage Federal rulings confirm : PRAs practices are legally documented violations my dispute history matches known patterns of abuse I am entitled to deletion, protection from reinsertion, and regulatory enforcement SECTION : Type of Account Open Misclassification by PRA PRA reported the account as Open on XXXX which falsely implies : An active credit line or revolving account Ongoing access to borrowed funds A direct relationship between the consumer and the furnisher This is categorically false. The account is : A charged-off debt purchased by a third party Closed by the original creditor ( XXXX XXXX ) Not open, revolving, or accessible to the consumer Violations FCRA 623 ( a ) ( 1 ) ( A ) Furnishing Inaccurate Information PRA misrepresented the account status, inflating credit utilization and misleading lenders.

FCRA 623 ( a ) ( 2 ) Duty to Correct and Update PRA failed to correct the misclassification after multiple disputes.

FDCPA 807 ( 2 ) ( A ) False Representation of Legal Status Labeling a closed, charged-off debt as Open falsely implies ongoing liability and access.

FCRA 607 ( b ) CRA Duty to Ensure Maximum Possible Accuracy Equifax displayed a status that contradicts the original creditors records and PRAs own CFPB response.

SECTION : Type of Loan Debt Buyer Misclassification by PRA PRA reported the Type of Loan as Debt Buyer across multiple bureaus. This is not a loan productits a description of PRAs business model. This classification : Does not reflect any loan agreement signed by the consumer Misrepresents the nature of the obligation Implies the consumer borrowed directly from PRA, which is false Confuses asset ownership with consumer liability Violations FCRA 623 ( a ) ( 1 ) ( A ) Furnishing Inaccurate Information PRA misclassified the loan type, misleading the nature and origin of the debt.

FDCPA 807 ( 2 ) ( A ) False Representation of Legal Status Reporting a third-party purchase as a direct loan is a false claim of origin and enforceability.

FCRA 623 ( a ) ( 2 ) Duty to Correct and Update PRA failed to update the loan type to reflect the original product ( e.g., credit card ).

FCRA 607 ( b ) CRA Duty to Ensure Maximum Possible Accuracy Credit bureaus accepted and displayed a misclassification that harms consumers and misleads underwriters.

SECTION : Charge-Off, IRS Reporting , and Ownership Contradiction XXXX XXXXXXXX XXXX XXXX XXXXXXXX XXXX charged off the original account, which triggered a series of financial and legal events that directly contradict PRAs current reporting and collection practices. 
Charge-Off Process A charge-off is an accounting action where the original creditor declares the debt uncollectible and removes it from active assets. 
XXXX XXXX then claims the charged-off amount as a business loss on its annual tax filings, reducing taxable income. 
In many cases, the creditor also receives compensation through loss prevention insurance and or by selling the debt to a third-party buyer. 
IRS Reporting Implications XXXX XXXX issued a Form XXXX ( Cancellation of Debt ), the debt is considered canceled under IRS regulations XXXX 
Once canceled, the debt is no longer legally enforceable, and any attempt to collect or report it XXXX constitute double recovery, which is unlawful. 
PRA, as the purchaser, can not legally reclassify the debt as a new loan or report it as an Open account under the consumers name.

Ownership Transfer and Legal Status PRA purchased the debt from XXXX XXXX as part of a portfolio of charged-off accounts. 
This transaction is strictly between PRA and XXXX Onethe consumer was not a party to the sale. 
XXXXA now owns the collection rights, but not the original contract or terms.

Reporting the account as Open falsely implies an active relationship and ongoing liability, which violates federal law.

Violations Triggered by Misclassification Federal Violations : FCRA 623 ( a ) ( 1 ) ( A ) Furnishing inaccurate information FCRA 623 ( a ) ( 2 ) Failure to correct and update after dispute FCRA 611 ( a ) ( 5 ) ( A ) Obligation to delete unverifiable or inaccurate data FCRA 607 ( b ) Credit bureaus must ensure maximum possible accuracy FDCPA 807 ( 2 ) ( A ) False representation of the character or legal status of any debt FDCPA 807 ( 10 ) Use of deceptive means to collect a debt FDCPA 809 ( a ) Failure to notify consumers of their right to dispute the debt IRS Violations ( if 1099-C was issued ) : Improper collection on canceled debt False asset classification Potential double recovery Violation of IRS bad debt deduction rules Strategic Conclusion XXXX XXXX has already claimed the debt as a loss and been compensated. PRAs reporting of this account as Open and Debt Buyer misrepresents the legal status, origin, and enforceability of the debt. This contradiction supports permanent deletion under FCRA 611 ( a ) ( 5 ) ( A ), reinsertion protection under 611 ( a ) ( 5 ) ( B ), and regulatory review under CFPB and IRS enforcement guidelines.

SECTION : PRAs Long-Term Ownership and Monetization Contradiction Portfolio Recovery Associates , LLC ( PRA ) has held this account for a duration sufficient to trigger its own financial reporting obligations. Under IRS regulations and standard corporate accounting practices, PRA has : Claimed the account as a business bad debt deduction under IRS Topic No. 453 and Publication 535 Reported the account as a business loss on its annual income tax filings Recovered the value through loss prevention insurance or internal portfolio write-downs IRS Bad Debt Deduction Rules According to IRS Topic No. 453 and Publication 535 : A business may deduct a debt that becomes wholly or partially worthless during the tax year The deduction must be claimed in the year the debt is deemed uncollectible The business must demonstrate reasonable efforts to collect before declaring it worthless If PRA : Held the account for multiple years Failed to collect any payments Continued reporting it as Open despite no verified activity Then, PRA has already claimed the debt as worthless for tax purposeswhile still reporting it as active on consumer credit files.

Insurance Recovery Risk PRA : Insured its portfolio against non-performing assets Received compensation for this account Continued reporting or collecting on it Then, PRA has engaged in double monetization, which could trigger insurance fraud exposure under state and federal law.

Legal Contradiction PRA can not : Claim the debt as a business loss Recover its value through tax deductions or insurance And still report the account as Open and collectible under the consumers name This contradiction violates : FCRA 623 ( a ) ( 1 ) ( A ) Furnishing inaccurate information FDCPA 807 ( 2 ) ( A ) False representation of legal status IRS Code PRA collects on a canceled or deducted debt, it may trigger unlawful double recovery Strategic Conclusion PRAs long-term ownership and monetization of this account contradict its continued reporting as an active liability. This supports permanent deletion under FCRA 611 ( a ) ( 5 ) ( A ), reinsertion protection under 611 ( a ) ( 5 ) ( B ), and regulatory review under CFPB, IRS, and insurance enforcement guidelines.

DEMAND FOR ACTION I am requesting the following actions be taken immediately : 1. Permanent deletion of the PRA Group account # XXXX from XXXX XXXX XXXX XXXX  under FCRA 611 ( a ) ( 5 ) ( A ) and 623 ( a ) ( 3 ).

2. Confirmation that no future furnishers, including PRA Group XXXX XXXX XXXXXXXX XXXX XXXX XXXX, or any third-party collector, may reinsert this account or any derivative into my credit reports without : o No updates, corrections, or reinsertions may be made to my credit reports regarding any account furnished by Portfolio Recovery Associates , LLC ( PRA ), XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX any third-party debt collector or debt buyer, without my explicit written consent. Any attempt to do so without my agreement constitutes a violation of FCRA 611 ( a ) ( 5 ) ( B ), 623 ( a ) ( 3 ), and FDCPA 807.

o Notification to all bureaus per FCRA 611 ( a ) ( 5 ) ( B ) 3. Regulatory review of PRA Groups misrepresentation to the CFPB and breach of reinvestigation timelines.

4. Investigate pra via CFPB, FTC, other law enforcement, and agencies This contradiction is now archived for legacy-grade breach documentation and survivor-centered override enforcement.

Company response to consumer: Closed with explanation