Consumer complaint received 2025-09-09 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Account information incorrect
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: CA

Complaint narrative:
XXXX XXXX XXXX XXXX XXXX XXXX, CA XXXX Date : XX/XX/XXXX To : Consumer Financial Protection Bureau ( CFPB ) Re : CFPB Ref No : XXXX Ref : XXXX Account Ending in XXXX Formal Rebuttal to XXXX XXXX Response Dear CFPB and Customer Advocate Services Team , This letter serves as my rebuttal to the correspondence dated XX/XX/XXXX, regarding the reporting of my XXXX XXXX XXXX XXXX account ending in XXXX. The response provided by XXXX XXXX fails to comply with the Fair Credit Reporting Act ( FCRA ), the Fair Debt Collection Practices Act ( FDCPA ) ( where applicable ), and the CARES Act protections enacted during COVID-19. 

1. FCRA Accuracy and Reasonable Investigation Under 15 U.S.C. 1681s-2 ( a ), furnishers must ensure that information furnished to CRAs is accurate and not misleading. Courts have emphasized that accuracy means more than technical correctness ; it requires reporting that does not create a misleading impression. See XXXX XXXX XXXXXXXX XXXX XXXX XXXXXXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ). 

XXXX is reporting multiple late payments and a final status of Paid/Closed Settled for Less than Full Balance or Paid Charge-Off. 

Reporting both a charge-off and subsequent lates after closure is misleading because once an account is charged off, it can not continue to accrue additional delinquency history. See XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX. XXXX XXXX ( XXXX XXXXXXXX. XXXX ) ( reporting delinquency information in an inconsistent or misleading manner violates the FCRA ). 

Courts require furnishers to ensure their reporting does not misrepresent the true status of the debt. See XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX ( XXXX XXXX. XXXX ). 

XXXX  reporting creates a double penalty : a derogatory charge-off and additional late notations, materially worsening the consumers credit profile. 

2. Failure to Report Account as Disputed The FCRA requires furnishers to mark disputed accounts as such. See 15 U.S.C. 1681s-2 ( a ) ( 3 ). 

XXXX admits disputes were filed but fails to confirm whether CRAs were updated with the proper dispute designation. Omitting this notation is itself a violation. See XXXXXXXX XXXX XXXXXXXXXXXX XXXX XXXX, XXXX, XXXX XXXX XXXX ( XXXXXXXX XXXX XXXXXXXX ). 

3. COVID-19 / CARES Act Provisions Ignored The CARES Act ( XXXX XXXX XXXXXXXX. XXXX, XXXX, XX/XX/XXXX ) amended the FCRA to protect consumers during COVID-19 : If an account was current at the time of an accommodation ( e.g., forbearance, deferral, reduced payment ), it must continue to be reported as current. 

If the account was delinquent, the furnisher may not advance the delinquency while the accommodation is in effect. 

XXXX reporting of lates and charge-off status during the COVID-19 period without acknowledgment of hardship protections violates the CARES Act and CFPBs own published guidance. 

4. FDCPA Violations Misrepresentation of Status Because this account was personally guaranteed, collection activities fall under the FDCPA. Misrepresenting the character, amount, or legal status of a debt violates 15 U.S.C. 1692e. 

By reporting a charge-off while simultaneously showing additional late payments, XXXX misrepresents the legal status of the account. 

Courts have confirmed that such conflicting or duplicative derogatories can violate federal law. See XXXXXXXX XXXX XXXX XXXXXXXX XXXX XXXX ( XXXX XXXX XXXXXXXX ). 

5. Material Harm This reporting causes serious damage to my credit profile : The paid charge-off/settled for less status is already derogatory. 

Adding late notations after closure/charge-off makes the reporting even more damaging and misleading to lenders. 

Courts have recognized that such reporting directly impacts creditworthiness and can support FCRA claims. See XXXX XXXX XXXX XXXXXXXX. XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ). 

Relief Requested I respectfully demand that : The account ending in XXXX be corrected or deleted from all CRAs due to misleading and unlawful reporting. 

The account be updated to remove any lates reported before charge-off status. 

The account be properly designated as consumer disputes this account under 15 U.S.C. 1681s-2 ( a ) ( 3 ). 

XXXX immediately provide documentation of its COVID-19 CARES Act compliance review. 

All collection and reporting activity cease until proper validation is provided under 15 U.S.C. 1692g ( b ). 

Failure to comply will result in escalation, including civil litigation for statutory damages, actual damages, costs, and attorneys fees under the FCRA ( 15 U.S.C. 1681n, 1681o ), FDCPA ( 15 U.S.C. 1692k ), and applicable CARES Act provisions. 

I request all response be sent to this compliant. 

Respectfully, XXXX XXXX XXXX XXXX XXXX XXXX, CA 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