Consumer complaint received 2025-12-04 00:00:00
Product: Debt collection — I do not know
Issue: Attempts to collect debt not owed — Debt is not yours
Company: Bread Financial Holdings, Inc.
State: NY

Complaint narrative:
I am creating a new CFPB case because multiple Comenity-related accounts continue to appear on my credit reports despite my previous disputes, despite my submission of an FTC Identity Theft Report, and despite my clear statements that I do not own, recognize, or have any contractual relationship with any Comenity Bank accounts .

This new complaint is being filed because the previous investigations did not resolve the issue, the reporting continues to negatively impact me, and the companies involved have not provided any legally required documentation validating the accounts. These accounts are fraudulent, unauthorized, and inconsistent with my legitimate financial history. They are the direct result of identity theft, which I formally documented with an FTC Identity Theft Report.

This complaint covers all Comenity-related accounts, including any accounts listed under : Comenity Bank Comenity Capital Bank Retail store cards serviced by Comenity Any Comenity tradeline appearing as charged off, open, closed, past due, sold, or in collections Because Comenity uses multiple sub-brands and retail partners, it is not possible for me to identify every fraudulent account separately through the CFPB platform. Therefore, this new case covers ALL Comenity accounts reported in my name, all of which I dispute in full.

Below is a detailed explanation of what happened.

1. Identity Theft Occurred FTC Identity Theft Report Filed I filed an FTC Identity Theft Report because unauthorized accounts were opened in my name without my knowledge or consent. These fraudulent accounts include all Comenity tradelines currently appearing on my credit file. As a victim of identity theft, I followed the legal steps required : Filed an official FTC Identity Theft Report Documented the identity theft incident Initiated disputes with the credit reporting agencies Informed Comenity that I do not own these accounts Requested validation and full documentation Under FCRA 605B, once a consumer submits an identity theft report, companies are required to block, remove, or cease reporting fraudulent accounts unless they can provide original, first-party documentation proving the account belongs to the consumer.

Comenity has not provided any such documentation.

2. I Do Not Recognize or Own ANY of the Comenity Accounts I have never : Applied for a Comenity credit card Opened a retail card serviced by Comenity Entered into a contract with Comenity Authorized Comenity to pull my credit Received any goods or services from a Comenity-serviced retailer Received statements, correspondence, or onboarding materials from them I do not have : A relationship with Comenity A purchase history with Comenity retailers Any memory of seeing these accounts before they appeared fraudulently Any reason to have multiple Comenity accounts The fact that multiple Comenity accounts appeared all at once is a common pattern seen in identity theft cases involving retail card fraud.

3. Comenity Never Provided Any Legal Proof of Ownership or Documentation Under the Fair Credit Reporting Act, a furnisher must provide evidence proving that : I opened the accounts I signed the credit applications I agreed to the terms I authorized credit inquiries I made purchases I received account statements I activated the cards I used the credit line Comenity has never provided : A signed contract or agreement A credit application with my handwriting or digital signature IP addresses associated with account creation Delivery confirmation for cards Statement history Communication logs Fraud investigation documentation Chain-of-custody data Identity verification documents used at account opening They have provided no evidence, yet continue reporting these fraudulent accounts.

4. Prior Disputes Were Closed Without Proper Investigation I previously disputed these accounts with all three credit reporting agencies. I also requested : Method of Verification Documentation reviewed Evidence supporting their verification Details of investigation procedures Audit trails Itemization of charges Proof of identity matching However, my disputes were verified through automated means, likely using the e-OSCAR system. Automated verification is not a sufficient reinvestigation under the FCRA because : e-OSCAR does not review actual documents e-OSCAR only exchanges two-digit codes No human reviewed original account records No contract was examined No identity theft documentation was evaluated My disputes were effectively dismissed without any real investigation.

5. Comenity Has Not Provided Documentation Required Under FCRA 623 Under FCRA 623 ( a ) ( 3 ), furnishers must not continue reporting information that they knowor reasonably should knowis inaccurate. Reporting accounts belonging to an identity theft victim violates this requirement.

Under FCRA 623 ( b ), furnishers must : Conduct a reasonable investigation Review all relevant information Provide documentation supporting accuracy Correct or delete inaccurate information Comenity has not complied with these duties. Instead, they continue reporting accounts without verification, despite : My FTC Identity Theft Report My prior disputes My formal statements denying ownership This constitutes inaccurate and harmful reporting.

6. Comenity Account Patterns Suggest Identity Theft, Not Legitimate Use Identity theft patterns often include : Multiple accounts opened in a short timeframe High utilization immediately after account opening Rapid delinquency Charge-offs occurring shortly after opening Accounts transferred to collections quickly No matching physical or digital evidence No pattern consistent with consumer behavior All Comenity accounts on my credit report follow these patterns.

Legitimate accounts do not : Open and charge-off in quick succession Appear without the consumer ever receiving a card Lack any supporting documentation Fail verification Occur in clusters with retailers the consumer has no connection to These accounts resemble identity-theft activity not authorized account usage.

7. Comenitys Continued Reporting Causes Serious Harm The fraudulent Comenity accounts have : Lowered my credit scores Created false delinquency history Caused lenders to deny applications Impacted access to credit Created emotional distress Damaged my financial reputation Interfered with legitimate financial activity Increased my risk profile with creditors This ongoing reporting harms me daily, despite my FTC Identity Theft Report and disputes.

8. Comenity Failed to Provide a Legally Required Method of Verification Under FCRA 611 ( a ) ( 6 ) ( B ) : I have the right to receive a description of the procedure used to determine the accuracy and completeness of the information.

Comenity has not provided : Any documents Any signed agreements Any identity verification materials Any application records Any primary evidence Therefore, they can not legally continue reporting.

9. Comenity Has Not Demonstrated That They Followed Reasonable Identity Theft Prevention Procedures Under the Red Flags Rule, financial institutions must detect and prevent identity theft by : Monitoring suspicious account activity Conducting enhanced verification Investigating fraud reports Responding appropriately to identity theft alerts Comenity has : Ignored an FTC Identity Theft Report Ignored disputes Ignored requests for documentation Failed to validate accounts Failed to remove fraudulent data This suggests non-compliance with federal identity theft prevention standards.

10. Comenity Must Remove Fraudulent Accounts Under FCRA 605B Under 605B, a consumer submitting an identity theft report is entitled to blocking of fraudulent information unless the furnisher proves that : The information is accurate The information was not caused by identity theft The furnisher has documentation showing the consumer is responsible Comenity has supplied none of the required documentation.

Therefore, all Comenity accounts must be blocked or deleted.

11. These Accounts Do Not Belong to Me Period I have no association with these accounts : No application No agreement No contract No card No activation No purchases No statements No communication No use Identity theft is the only possible explanation.

Comenity 's failure to validate any account confirms they can not prove otherwise.

12. Why I Am Creating a New Case A new CFPB case is necessary because : The prior case did not resolve the issue The accounts remain on my credit reports No documentation was provided Comenity failed to meet verification obligations The harm caused by the reporting continues The identity theft has been formally documented The accounts continue to appear as delinquent or charged off This new case reflects the continuation of the same unresolved problem.

13. Summary of What Happened To summarize : I filed an FTC Identity Theft Report.

I informed the credit bureaus that I do not own any Comenity accounts.

I disputed all Comenity accounts multiple times.

Comenity failed to provide any documentation proving the accounts belong to me.

Automated systems verified the accounts without review of actual evidence.

The accounts continue to report inaccurately and harmfully.

Comenity has not complied with FCRA 623, 605B, or furnisher responsibilities.

I am filing a new CFPB case because the matter remains unresolved.

These accounts are fraudulent. I do not own them.

They must be removed.

Company response to consumer: Closed with non-monetary relief