Consumer complaint received 2026-02-24 00:00:00
Product: Debt collection — I do not know
Issue: Written notification about debt — Didn't receive enough information to verify debt
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: SC

Complaint narrative:
A collections account showed on my credit report XXXX of XXXX from XXXX XXXX XXXX ( XXXX XXXX XXXX XXXX XXXX XXXX without a Debt Validation Letter or any written notice with my Mailing Address attached. So I sent a Debt Validation Letter for a debt that started reporting on my Credit Report in XXXX on XX/XX/XXXX ( tracking number XXXX ) to XXXX XXXX XXXX to the address listed on my credit report XXXXXXXX XXXX XXXX XXXX, XXXXXXXX XXXX XXXXXXXX, it was sent back as inaccurate address. So I sent VIA Certified Mail with Return Receipt a second Debt Validation Letter with my mailing address attached to XXXX at XXXX XXXX XXXX, XXXXXXXX XXXX XXXX on XX/XX/XXXX ( Tracking Number XXXX ) it was marked as received XX/XX/XXXX. I waited XXXX days for a response, had no response and went and filed with the three credit bureaus ( return receipt tracking numbers ; XXXX XXXX XXXX ), this item is continuing to report on my credit report without a XXXX XXXX, when I spoke to Transunion on the phone ( audio recorded ) XXXX said the Method of Verification was " the system '', I waited on hold for a supervisor and XXXX told me it was " my name, number and Social Security Number ''. I explained this isn't a valid method of verification. He advised me to go ahead and file a complaint with this agency. FCRA 1681i ( a ) ( 1 ) ( A ) Requires consumer reporting agencies ( CRAs like TransUnion, XXXX XXXX ) to conduct a " reasonable reinvestigation '' of disputed information to determine if it's inaccurate or incomplete. If the item can not be verified, the CRA must delete it. This is the core requirement. Courts and regulators emphasize that " reasonable '' means more than superficial checksespecially when evidence ( like my FDCPA non-validation proofs ) shows the debt may be unverifiable. FCRA 1681e ( b ) CRAs must " follow reasonable procedures to assure maximum possible accuracy '' of information in consumer reports. The CFPB has repeatedly interpreted this to mean that shoddy or overly simplistic matching/verification ( e.g., limited to basic PII ) violates accuracy obligations, as it risks misattributing information or failing to resolve substantive disputes. XXXX Advisory Opinion on Name-Only Matching ( published in XXXX XXXX, XX/XX/XXXX ) : The CFPB explicitly stated that matching records solely by name ( or even name + limited identifiers like XXXX ) is not reasonable under 1681e ( b ) and can violate FCRA, due to high risk of mistaken identity or inaccuracy. PII ( name + SSN + DOB ) the Bureau emphasized that even multi-identifier matching can be inadequate if it doesn't address the substance of the dispute ( e.g., debt validity ). They warned against " thoughtless application of loose matching criteria '' and said nothing creates a " safe harbor '' for insufficient procedures. CFPB has enforced against XXXX for inadequate verification practices leading to inaccurate reports, reinforcing that PII matching alone doesn't satisfy " maximum possible accuracy '' when deeper issues ( like non-validation ) are raised.Regulation V ( 12 CFR Part 1022 ) Implements FCRA duties. Furnishers ( like XXXX ) and XXXX must conduct reasonable investigations of disputes ( XXXX022.43 for direct disputes ). Matching PII may suffice for basic identity confirmation but not for verifying debt accuracy or completeness if the dispute challenges verifiability. Courts have ruled that a " reasonable reinvestigation '' requires some degree of careful inquiry beyond mere PII confirmation : Fourth Circuit ( e.g., cases on furnishers ) : Must investigate " objectively and readily verifiable '' information ; superficial checks ( like confirming PII ) are insufficient if the dispute involves debt legitimacy. Second Circuit & others : Emphasize reasonable ( not perfect ) investigations, but purely automated or PII-based checks can fail if they ignore consumer-provided evidence. No court has held that name + SSN + DOB matching alone is always sufficient for reinvestigation when the dispute goes to accuracy/verifiability ( e.g., your FDCPA non-response claim ). It's often deemed unreasonable if it doesn't address substantive issues.

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