Consumer complaint received 2024-06-17 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Improper use of your report — Reporting company used your report improperly
Company: TRANSUNION INTERMEDIATE HOLDINGS, INC.
State: TN

Complaint narrative:
Subject : Request for Deletion of Accounts Due to Privacy Notice Violations Dear Sir/Madam, I am writing to formally dispute and request the deletion of the following accounts from my credit report : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX accounts ) XXXX XXXXXXXX DEPT OF ED/XXXX ( XXXX accounts XXXX US DEPT OF EDUCATION XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  The basis for my dispute is the failure of the financial institutions managing these accounts to comply with privacy notice requirements as stipulated in 15 U.S. Code 6802 ( a ) ( b ), also known as the Gramm-Leach-Bliley Act ( GLBA ).

Violation of Initial Privacy Notice ( 15 U.S. Code 6802 ( a ) ) : According to 15 U.S. Code 6802 ( a ), financial institutions are mandated to provide an initial privacy notice to consumers, detailing how they collect, share, and protect consumer information. I have not received such notices from the institutions managing the above-mentioned accounts. This indicates a significant breach of my privacy rights and raises serious concerns about the proper handling and protection of my nonpublic personal information.

Violation of Opt-Out Notice ( 15 U.S. Code 6802 ( b ) ) : Furthermore, under 15 U.S. Code 6802 ( b ), consumers must be provided with an opt-out notice if their information is to be shared with non-affiliated third parties. This notice should inform consumers of their right to opt out and provide easy methods to do so. I have not received any opt-out notices concerning the sharing of my nonpublic personal information related to these accounts, thus depriving me of my right to control the dissemination of my personal data.

Reference to Transactions or Experiences ( FCRA 603 ) : Additionally, the Fair Credit Reporting Act ( FCRA ) specifies under 603 that a report containing information solely as to transactions or experiences between the consumer and the person making the report does not constitute a consumer report. Given the lack of proper privacy and opt-out notices, the information related to the above accounts should be considered invalid and should not appear on my consumer report.

Violation of Furnishing Deceptive Forms ( 15 U.S. Code 1692j ) : Under 15 U.S. Code 1692j, it is illegal to design, compile, and furnish any form knowing that it will create the false belief in a consumer that a person other than the creditor is participating in the collection of or in an attempt to collect a debt. The failure to provide proper privacy and opt-out notices as required by law may indicate deceptive practices which further support my request for the deletion of these accounts.

Violation of Timing of Payments ( 15 U.S. Code 1666b ) : Furthermore, 15 U.S. Code 1666b requires that payments must be credited to the consumers account as of the date of receipt, ensuring timely recording and preventing unnecessary fees or damages to credit reports. The mismanagement and non-compliance of the financial institutions with this requirement further justifies my request for deletion of the associated accounts due to potential inaccuracies and detrimental impacts on my credit report. 
Given these violations, I believe that the handling of my nonpublic personal information by the financial institutions was not in compliance with federal regulations, rendering the accounts invalid. Therefore, I request the immediate deletion of the above-mentioned accounts from my credit report. 
Enclosed are copies of supporting documents, including my credit report with the disputed accounts highlighted, for your reference. I trust you will conduct a thorough investigation and rectify this situation promptly. 
As per the FCRA, I expect this dispute to be investigated and resolved within 30 days of your receipt of this letter. Please provide me with a written statement of your findings and any actions taken, including an updated copy of my credit report if any changes are made. 
Thank you for your prompt attention to this matter. I look forward to your timely response and resolution. 
Sincerely, XXXX XXXX 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