Consumer complaint received 2025-12-03 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: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: VA

Complaint narrative:
I am writing to file a formal complaint and to demand investigation, correction, and removal of inaccurate ( Names, Address, Phone Numbers, Places of Employment, and Consumer Credit Reporting ) improper, and unlawfully shared information that Equifax, Experian, and TransUnion are reporting about me. This complaint is submitted to the Consumer Financial Protection Bureau ( CFPB ) and concerns conduct that violates the Fair Credit Reporting Act FCRA, 15 U.S.C. 1681 et seq., the GrammLeachBliley Act GLBA, 15 U.S.C. 6801 6802, the Family Educational Rights and Privacy Act FERPA, 20 U.S.C. 1232g, the Privacy Act of 1974, 5 U.S.C. 552a, and related regulations and guidance, as well as the responsibilities of furnishers of information and the privacy and opt out requirements applicable to financial institutions. 
I am a consumer within the meaning of the FCRA, and Equifax, Experian, and TransUnion are consumer reporting agencies that assemble and furnish consumer reports about me. FERPA is a federal law enacted in 1974 that protects the privacy of student education records and applies to public and private elementary, secondary, and post secondary schools that receive applicable federal funds. To the extent that my credit reports contain information derived from student education records, including federal or institutional student loans connected to my education records, I contend that the handling and disclosure of those records and related information must be consistent with FERPAs privacy protections and limitations on disclosure without consent, and I request that the CFPB ensure that any reporting of such student loan information conforms to privacy requirements and is not used or disclosed beyond what these laws allow. I further request that any student loan tradelines that can not be verified as compliant with applicable federal privacy laws and FCRA accuracy standards be deleted, and that each deleted student loan related item entitles me to {$1000.00} in statutory remedies for willful noncompliance, as described below. 
Under FCRA 1681, Congress found that there is a need to ensure consumer reporting agencies exercise their grave responsibilities with fairness, impartiality, and a respect for the consumers right to privacy, and that these agencies must adopt reasonable procedures that are fair and equitable to the consumer with regard to confidentiality, accuracy, relevancy, and proper utilization of information. The FCRA defines a consumer reporting agency as any person which, for fees or on a cooperative basis, regularly assembles or evaluates consumer information for the purpose of furnishing consumer reports to third parties, and defines a consumer as an individual, and a consumer report as any written, oral, or other communication bearing on creditworthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living. 
The FCRA also distinguishes certain exclusions, such as information solely about transactions or experiences between the consumer and the person making the report, and strictly limits when reports may be furnished. The FCRAs permissible purposes provision, 15 U.S.C. 1681b, states that, subject to subsection ( c ), a consumer reporting agency may furnish a consumer report only under certain circumstances, including in accordance with the written instructions of the consumer to whom it relates. I assert that Equifax, Experian, and TransUnion, and the furnishers that report to them, have obtained, used, and shared consumer reports about me without proper written instructions from me and, in some instances, without a permissible purpose, particularly where information appears unrelated to any present credit, employment, insurance, account review, or other allowed purpose. 
I request that the CFPB require each credit reporting agency and furnisher to identify and document the specific permissible purpose under 1681b for each disputed account and inquiry, and where no such permissible purpose exists or can not be substantiated, to order deletion of those items and to treat each such improper access or furnishing as a violation that supports a statutory remedy of at least {$1000.00} per deleted item for willful noncompliance as provided in 15 U.S.C. 1681n. 
The FCRA limits what adverse information may appear in consumer reports. Under 15 U.S.C. 1681c ( a ) ( 5 ), no consumer reporting agency may make a consumer report containing adverse items of information, other than records of criminal convictions, that antedate the report by more than seven years, subject to certain specific exceptions in 1681c ( b ). My credit files include adverse items and derogatory marks that are more than seven years old and thus appear to be obsolete within the meaning of this provision, yet they continue to be reported by Equifax, Experian, and TransUnion. I ask the CFPB to direct the credit reporting agencies to remove any adverse items that are older than seven years and to ensure that each such obsolete item is permanently deleted, with a remedy of at least {$1000.00} per obsolete item removed for willful noncompliance based on the agencies continued reporting after being informed of the violations. 
The FCRA and its implementing regulations also address identity theft and the misuse of personal identifying information. Under 12 C.F.R. 1022.3, identity theft generally refers to fraud committed using the identifying information of another person without authority, and 15 U.S.C. 1681c2 requires consumer reporting agencies to block information in a consumers file that results from identity theft once the consumer provides proof of identity, an identity theft report, identification of the information, and a statement that the information does not relate to any transaction by the consumer. To the extent that items have been added to my consumer reports without my authorization or written consent, they may constitute identity theft related entries, and once properly disputed with identity theft documentation, the credit reporting agencies must promptly block and cease reporting them. For any such identity theft related items that are deleted or blocked after my complaint and submission of the required documentation, I request that each be treated as a separate violation supporting a minimum remedy of {$1000.00} per deleted or blocked item under 15 U.S.C. 1681n where willful noncompliance is shown, in addition to actual damages and other relief. 
The FCRA compliance procedures section, 15 U.S.C. 1681e, requires consumer reporting agencies to maintain reasonable procedures to avoid violations of 1681c and to limit furnishing reports to the purposes listed in 1681b, including verifying the identity and certified purposes of users and following reasonable procedures to assure maximum possible accuracy of information. The fact that my reports contain inaccurate items, obsolete adverse information, and entries with no legitimate permissible purpose shows that Equifax, Experian, and TransUnion are not maintaining the required reasonable procedures or verifying users and purposes appropriately. Because these failures persist despite disputes, they reflect willful or, at minimum, negligent noncompliance, and I request that each inaccurate or improperly furnished item that is removed be treated as a violation entitling me to damages of not less than {$100.00} and up to {$1000.00} for willful noncompliance under 1681n, and actual damages for negligent noncompliance under 1681o, with a minimum of {$1000.00} per deleted item where willfulness can be inferred from repeated disregard of the law after notice.

The FCRAs furnisher responsibility provision, 15 U.S.C. 1681s2, prohibits furnishers from reporting information they know or have reasonable cause to believe is inaccurate and from continuing to report information after notice and confirmation of errors. Furnishers must also conduct reasonable investigations after receiving disputes from consumer reporting agencies and must correct and update information that is incomplete or inaccurate. I have notified the credit reporting agencies and furnishers that certain information is inaccurate and can not be verified, yet those same items continue to appear on my reports, indicating that the furnishers have violated 1681s2 ( a ) and ( b ). I request that the CFPB require the furnishers to cease reporting any disputed information that can not be verified, to correct or delete such items, and to recognize that each continued reporting after notice constitutes an additional violation supporting at least {$1000.00} in statutory damages per item for willful noncompliance, plus any actual damages I have suffered. 
The Privacy Act of 1974, 5 U.S.C. 552a, defines a record broadly to include collections of information about an individual, such as education and financial transactions, that contain identifying particulars like a name or number, and it restricts agencies from disclosing records in systems of records without prior written consent, subject to limited exceptions, including certain disclosures to consumer reporting agencies under 31 U.S.C. 3711 ( e ). To the extent that federal agencies or institutions have disclosed information about me, including education related or financial records, to consumer reporting agencies without complying with consent and procedural requirements, those disclosures may violate the Privacy Act as well as the FCRA. I request that the CFPB coordinate, where appropriate, with other regulators to review any federal or institutional disclosures of my records to Equifax, Experian, and TransUnion, and that any information derived from records disclosed in violation of the Privacy Act or related provisions be removed from my reports, with recognition that such unlawful disclosures and resulting entries support additional remedies and {$1000.00} in statutory relief per deleted item under applicable FCRA provisions when willful noncompliance is established. 
GLBA and its implementing regulation, Regulation P 12 C.F.R. Part 1016, govern the treatment of nonpublic personal information by financial institutions, requiring clear and conspicuous privacy notices, explaining when information may be disclosed to nonaffiliated third parties, and giving consumers the right to opt out of most such disclosures. Financial institutions must provide an initial privacy notice to customers and consumers before disclosing nonpublic personal information to nonaffiliated third parties and must provide a clear opt out notice and a reasonable method for exercising the opt out right, and must honor an opt out direction as soon as reasonably practicable, with the opt out effective until revoked. I have not received adequate initial privacy notices or reasonable opt out mechanisms from all furnishers reporting to Equifax, Experian, and TransUnion, yet my nonpublic personal information has been shared with these nonaffiliated consumer reporting agencies. 
Through this complaint, I am expressly exercising my right to opt out of the disclosure of my nonpublic personal information to nonaffiliated third parties to the fullest extent allowed by law and request that the CFPB ensure that all furnishers and credit reporting agencies honor this opt out and cease any nonrequired, nonpermissible sharing, and that any items that must be removed because they stem from noncompliant disclosures be treated as violations warranting at least {$1000.00} in statutory remedies per deleted item under FCRA civil liability provisions. Under FCRA civil liability provisions, 15 U.S.C. 1681n provides that any person who willfully fails to comply with any requirement of the FCRA is liable to the consumer for actual damages or statutory damages of not less than {$100.00} and not more than {$1000.00}, as well as potential punitive damages, plus costs and attorneys fees. Section 1681n also authorizes, in the case of a natural person obtaining a consumer report under false pretenses or knowingly without a permissible purpose, actual damages or {$1000.00}, whichever is greater. Section 1681o provides that any person who is negligent in failing to comply with any FCRA requirement is liable for actual damages and costs and attorneys fees. Given the repeated and continuing violations after disputes and notices, I contend that Equifax, Experian, TransUnion, and relevant furnishers have engaged in willful noncompliance, and therefore each instance of improper reporting, failure to delete or correct, obsolete adverse information, unlawful disclosure, or lack of permissible purpose should be treated as a separate violation, entitling me to at least {$1000.00} per deleted or corrected item, plus any actual damages and additional relief the CFPB and courts may deem appropriate. 
In light of the above, I respectfully request that the CFPB investigate these matters ; require Equifax, Experian, TransUnion, and all relevant furnishers to conduct thorough reinvestigations ; delete all inaccurate, unverifiable, obsolete, improperly disclosed, identity theft related, and impermissibly furnished items from my credit reports ; ensure compliance with FERPA and the Privacy Act for any student related or federal records ; enforce GLBA/Regulation P privacy and opt out requirements ; and recognize and enforce my entitlement to remedies of not less than {$1000.00} per deleted item for willful violations under 15 U.S.C. I have taken the time to highlight each inaccurate reporting on all three of the Consumer Reporting Agency.

The highlighted portions on each transcript are as followed : Multiple variations to my name Multiple non mailable Addresses Wrong employers Inaccurate Payment and Credit Reporting Reporting Violations based on the law stated above Negative And Adverse action caused for unlawful reporting. 

Accounts Include # XXXX XXXX XXXX Acct # XXXX XXXX XXXX XXXX XXXX Acct # XXXX / XXXX / XXXX XXXX XXXX Acct # XXXX XXXX  Acct # XXXX / XXXX / XXXX / XXXX / XXXX XXXX XXXX Acct # XXXX / XXXX

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