Consumer complaint received 2025-04-29 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Public record information inaccurate
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: OK

Complaint narrative:
I am writing to formally dispute the unverified bankruptcy information currently reported on my TransUnion, XXXX credit file. A detailed review indicates that this information originated from XXXX of XXXX sister companies in the financial risk sector formerly wholly owned by TransUnion XXXX XXXX and recently acquired by XXXX XXXX XXXX began operations in XX/XX/XXXX. There appears to be a perceptible cooperation and understanding between XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX as being owed to TransUnion, XXXX as a result TransUnion XXXX XXXX wholly owning the now unified brand. The sister companies are identified asXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  all which are identified as data brokers not unlike TransUnion, XXXX and are all operating under the jurisdiction of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq.

Inadequate Verification Procedures and FCRA Violations As outlined by the E-Government Act of 2002, 28 U.S.C. 312 ( c ) ( 1 ), public access to bankruptcy records through Public Access to Court Electronic Records ( PACER ) is restricted to the last four digits of an individuals Social Security Number ( SSN ). Therefore, any attempt by data brokers to correlate bankruptcy records to a consumer using partial SSNs and other unverifiable identifiers is inherently flawed and fails to meet the FCRAs maximum possible accuracy standard under 15 U.S.C. 1681e ( b ).

Data Broker Matching Errors and False Positive Risk Data brokers use proprietary algorithms and analytics to match individuals with public records, but these systems often produce false positives by matching records based solely on partial SSNs, names, and addresses. This flawed practice has resulted in the erroneous reporting of a bankruptcy record that does not belong to me.

Lack of Full SSN Matching : PACER and court records do not disclose full SSNs, making it impossible to conclusively verify the individual associated with the bankruptcy.

Violation of FCRA Guidelines : Under 15 U.S.C. 1681e ( b ), credit reporting agencies are required to use reasonable procedures to assure maximum possible accuracy in credit reporting. Failure to verify complete consumer information before attributing public records constitutes a clear violation of the FCRA. 
Relevant Case Law : The precedent set by XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  ), affirms that failure to verify public record information before associating it with a consumer XXXX constitute a breach of the FCRAs accuracy requirement.

However, as noted, social security numbers ( SSNs ) are heavily redacted from public bankruptcy filings in compliance with the E-Government Act of 2002 ( 28 U.S.C. 312 ( c ) ( 1 ) ), which mandates that only the last four digits of an individuals SSN be displayed in public records. This raises a critical question about how data brokers manage to associate bankruptcy records with a consumers credit profile given this limitation.

How Data Brokers Verify Bankruptcy Cases Without Full SSNs : Partial SSN and Name Matching Data brokers use the last four digits of the plaintiff 's SSN along with the individuals full name and address to attempt a match.

However, this approach is prone to errors, especially with common names, as matching only the last four digits and name increases the likelihood of false positives. 

Address and Date of Birth Correlation Data brokers cross-reference the bankruptcy filing with publicly available information such as previous addresses, date of birth ( XXXX ), and other identifying details available in consumer profiles. 
Even though the full SSN is unavailable, combining partial SSN, XXXX, and address history increases the perceived probability of an accurate XXXX still not guaranteed. 

Use of Proprietary Matching Algorithms Many data brokers employ proprietary matching algorithms that attempt to correlate multiple data points to identify a consumer. 
These algorithms weigh the similarity of names, addresses, DOBs, and other metadata to assign a confidence score to the match.

However, these systems are not infallible and can introduce errors that lead to the reporting of bankruptcies on the wrong individuals credit report.

PACER Court Record Cross-Referencing While PACER itself does not verify identities, data brokers retrieve court documents and then attempt to match case information with their internal databases.

The limitation is that PACER does not furnish the complete SSN or confirm the individuals identity beyond what is publicly available.

Third-Party Verification Attempts Some data brokers utilize third-party sources to further validate the information, although these sources often rely on the same incomplete data, compounding the potential for errors.

Legal Implications of Unverified Matches FCRA Violations : According to the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681e ( b ), data brokers and credit reporting agencies are required to ensure the maximum possible accuracy when reporting consumer information. Inaccurate matching based on incomplete identifiers violates this statutory mandate.

FTC Guidelines : The Federal Trade Commission ( FTC ) has emphasized that partial or assumed knowledge can not be used to verify a consumers identity or bankruptcy status for credit reporting purposes.

Case Law Supporting Inaccuracy ClaimXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  ) : Reinforced that credit reporting agencies and data brokers must use reliable procedures to prevent the inclusion of inaccurate information. 
XXXX XXXX XXXX XXXX XXXX  ( XXXX ) : Highlighted that a failure to conduct reasonable investigations before attributing public records to a consumer XXXX constitute a violation of the FCRA. 

Why This Matters Because data brokers do not have the full SSN or reliable means to conclusively verify a bankruptcys connection to a particular individual, any match based solely on partial SSN and name/address data can not meet the maximum possible accuracy standard under the FCRA. This weakness in verification opens the door to challenging the accuracy of any bankruptcy-related information reported on my credit profile. 

Demand for XXXXmediate Correction and Removal Pursuant to 15 U.S.C. 1681i ( a ) ( 5 ) ( A ), I formally request the immediate removal of the inaccurately reported bankruptcy entry due to insufficient verification procedures. 
I also request that TransUnion, XXXX : XXXX. Provide documentation detailing the verification procedures implemented by TransUnion XXXX XXXX wholly owned subsidiaXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX, that is relied upon by TransUnion XXXX XXXX and other leading financial institutions, payments providers, and retailers worldwide for competitive studies, predictive analytics, models, and advisory services whom which correlated this bankruptcy record to me. 
XXXX. Identify the source of this erroneous information and provide all supporting documentation. 
XXXX. Remove the inaccurate bankruptcy entry and confirm the deletion in writing within 30 days as required by 15 U.S.C. 1681i ( a ) ( 1 ) ( A ).

Failure to Comply and Legal Action Should TransUnion, LLC fail to correct this inaccurate reporting, I am prepared to file a formal complaint with the Consumer Financial Protection Bureau ( CFPB ) and explore legal remedies to enforce my rights under the FCRA. Continued failure to comply may result in civil liability under 15 U.S.C. 1681n for willful noncompliance and 15 U.S.C. 1681o for negligent noncompliance.I am writing to formally and unequivocally demand that Equifax provide a full and complete disclosure regarding the Method of Verification employed in response to the items I previously disputed on my credit report and which I am now re-disputing. You are hereby required to provide a detailed accounting of the procedures utilized to verify each disputed trade-line item, along with an explanation of how TransUnion, LLC ensured strict compliance with all applicable federal laws during the investigation process.

Specifically, I demand the following without exception : 1. A complete and itemized explanation of the verification methods used for each disputed entry.

2. Copies of all documentation obtained and reviewed during your investigation process.

3. Identification of all individuals, departments, and/or third parties involved in the verification.

4. The specific dates on which each verification action was initiated and completed.

As you are fully aware, under the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681i ( a ) ( 6 ), you are legally obligated to provide the results of any re-investigation to the consumer. Furthermore, under 15 U.S.C. 1681g ( a ) ( 2 ), you are required to disclose the sources of information within my consumer file. Additionally, pursuant to 15 U.S.C. 1681i ( a ) ( 7 ), I am entitled to a complete description of the procedures used to determine the accuracy and completeness of any disputed information.

You are hereby instructed to provide detailed documentation and explanations regarding your compliance with the following federal statutes and regulations : Fair Credit
Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., including but not limited to : 1681i ( a ) ( 1 ) ( A ), 1681i ( a ) ( 2 ), 1681i ( a ) ( 4 ), 1681i ( a ) ( 5 ), 1681i ( a ) ( 6 ), 1681i ( a ) ( 7 ), 1681g ( a ), 1681s-2 ( b ) Fair and Accurate Credit Transactions Act ( FACTA ) amendments, including : 1681c-1, 1681c-2, 1681s-2 ( a ) ( 8 ) Consumer Financial Protection Act ( CFPA ), 12 U.S.C. 5531 et seq.

12 C.F.R. Part 1022 ( Regulation V ) 16 C.F.R. Part 660 - Duties of Furnishers of Information Gramm-Leach-Bliley Act ( GLBA ), 15 U.S.C. 6801 et seq.

Equal Credit Opportunity Act ( ECOA ), 15 U.S.C. 1691 et seq., and Regulation B, 12 C.F.R. Part 1002 Federal Trade Commission Act, 15 U.S.C. 45 ( a ) In your response, you must address how TransUnion, LLC : 1. Conducts " reasonable reinvestigations '' as mandated by 1681i ( a ) ( 1 ) ( A ).

2. Verifies information directly with original furnishers.

3. Considers all relevant information submitted by consumers during disputes.

4. Determines the accuracy and completeness of disputed entries.

5. Implements compliance measures related to FCRA, FACTA, CFPA, and all corresponding regulations.

Additionally, as mandated by FCRA 1681i ( a ) ( 6 ), you are required to provide the results of your reinvestigation within 5 business days of its completion. Your failure to timely and fully comply with these statutory obligations will be considered a breach of federal law and may subject you to legal liability.

I expect a comprehensive response to this demand within 30 days of your receipt of this letter, including a fully updated credit report reflecting the corrections, deletions, or modifications resulting from your investigation.

Please be advised that failure to provide the requested information and documentation in a complete, timely, and lawful manner will leave me no choice but to consider escalation of this matter through formal legal channels, including but not limited to complaints filed with the Consumer Financial Protection Bureau ( CFPB ), the Federal Trade Commission ( FTC ), and potential civil action. 

ATTACHED YOU WILL FIND MY PETITION READY TO BE FILED IN FEDERAL COURT AS A RESULT OF YOUR ACTIONS AND THOSE LISTED IN MY COMPLAINT.

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 explanation