Consumer complaint received 2026-01-12 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Installment loan
Issue: Problem when making payments — 
Company: Affirm Holdings, Inc
State: MO

Complaint narrative:
AFFIRM CREDIT-FURNISHING + DISPUTE-HANDLING FAILURE Transaction : XXXX XXXX Installments XXXX XXXX | Order # XXXX | Affirm Agreement ID XXXX Amount : {$430.00} | Purchase Date : XX/XX/XXXX | Dispute Opened : XX/XX/XXXX | Closed : XX/XX/XXXX XXXX Dispute opened + Affirms written representation of paused/ no delinquency reporting On XX/XX/XXXX I opened a billing dispute because the merchandise was materially not as described ( standard parallel to Visa Reason Code 13.3 ). That same day Affirm acknowledged in writing that payments were paused and that no negative credit reporting would occur while the dispute was pending. Such a representation creates a reasonable reliance expectation under CFPB XXXX XXXX and FTC Deceptive-Practices standards ( see FTC XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ) ) XXXX 



2 Repeated evidence submission + failure to specify criteria Between XX/XX/XXXX and XX/XX/XXXX I submitted photos, screenshots, and product comparisons through XXXX XXXX and via email. Affirm never identified what specific items were needed to satisfy its sufficiency standard, in violation of the transparency principles articulated in XXXX XXXX Credit Bureau XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) ( a furnisher can not claim to have conducted a reasonable investigation when it fails to identify the information necessary to resolve the dispute ). This failure destroyed the consumers ability to rebut merchant claims with clarity or finality. 



XXXX Insufficient evidence closure without verifiable basis On XX/XX/XXXX Affirm closed the dispute for insufficient evidence without : a reasons list, the merchant evidence packet, identification of records reviewed and facts relied upon, or an auditable decision trail ( timestamps, reviewer identity, internal codes ). 

This denial methodology contradicts the standard of a reasonable reinvestigation under 15 U.S.C. 1681s-2 ( b ) and the competence requirement of 1681i ( a ) ( see XXXX v. XXXX XXXXXXXX XXXX XXXX  XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) a reasonable investigation requires obtaining and reviewing underlying records supporting the dispute ). 



XXXX Escalation and adverse furnishing despite active dispute and prior warning After closure, Affirm sent collection-escalation communications threatening charge-off and third-party collection within days while the account remained disputed. Affirm then furnished derogatory information to consumer reporting agencies. 

Key fact : Before the negative reporting occurred I warned Affirm in writing that the account remained in active dispute and that reporting it as delinquent would constitute knowing furnishing of inaccurate information. Affirm ignored that notice and furnished anyway. 

That conduct triggers 1681s-2 ( a ) ( 1 ) ( A ) ( knowingly furnishing inaccurate data ) and 1681s-2 ( a ) ( 3 ) ( failure to flag disputed information ), and has been held to constitute bad faith in cases such as XXXX XXXX XXXX & XXXX XXXX XXXX XXXX XXXX ( XXXX XXXX. XXXX ) and XXXX v. XXXX & XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ), where continued negative reporting of disputed accounts was found to violate the FCRAs good-faith investigation duty. 

Affirms decision to furnish derogatory status after explicit warning constitutes willful non-compliance under XXXX XXXXXXXX XXXX XXXX  XXXX, XXXX XXXX XXXX ( XXXX ) ( intent established by reckless disregard for statutory obligations ). 



XXXX Missing native audit artifacts that determine accuracy A lawful investigation would produce the following records : complete merchant evidence packet, internal dispute logs and decision codes ( who, what, when ), audit trail of system status changes, and furnishing history ( XXXX fields, dispute indicator XXXX XXXX  exchange ). 

Affirm has produced none of these. Failure to retain or disclose these materials violates the record-preservation expectations outlined in CFPB XXXX XXXX and precludes verification of reasonable procedures to assure maximum possible accuracy required by 15 U.S.C. 1681e ( b ). When a furnisher can not produce the records underlying its certification of accuracy, the presumption of accuracy collapses ( see XXXX v. XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) ). 



XXXX Statutory framework violated ( collective summary ) 15 U.S.C. 1681s-2 ( a ) ( 1 ) ( A ) Furnishing information known to be inaccurate.

1681s-2 ( a ) ( 3 ) Failure to flag account as in dispute.

1681s-2 ( b ) Failure to conduct a reasonable investigation after notice of dispute.

1681e ( b ) Failure to maintain reasonable procedures for maximum possible accuracy.

1681n / 1681o Willful and negligent non-compliance damages standards. 
CFPB Circular XXXX Inadequate dispute investigations violate FCRA and XXXX. 
XXXX XXXX. XXXX XXXX investigation requirements under XXXX XXXX. 



XXXX Pattern and practice risk Affirms practice of closing consumer disputes without reason codes, failing to produce merchant packets, and furnishing derogatory status while claiming paused billing suggests a systemic deficiency in its FCRA and XXXX compliance programs ( see In re EOS XXXX, CFPB No. XXXX {$2.00} XXXX penalty for similar failures ). The same factual pattern dispute open, negative reporting continued, no records preserved has been repeatedly cited by CFPB as unfair and deceptive under 12 U.S.C. 5531.

8 Conclusion Affirm made a clear representation that payments were paused and no negative credit reporting would occur during the dispute. I relied on that representation in good faith. Affirm then reversed its own position, denied the dispute without verifiable records, and furnished derogatory information after explicit warning that the account remained disputed. Those acts demonstrate a knowing or reckless disregard for statutory duties, satisfying the willfulness standard under XXXX. The record failures alone establish that Affirms investigation can not be deemed reasonable or conducted in good faith. 



This submission therefore raises potential violations of the FCRA ( 1681s-2 ( a ), ( b ), ( e ) ), CFPA ( 12 U.S.C. 5531-5536 ), and Regulation V ( 12 C.F.R. 1022.43 ), and warrants supervisory review for systemic furnisher misconduct.

Company response to consumer: Closed with explanation