Consumer complaint received 2025-05-22 00:00:00
Product: Debt collection — Telecommunications debt
Issue: Attempts to collect debt not owed — Debt was paid
Company: P&B Capital Group, LLC
State: IN

Complaint narrative:
Pursuant to UCC 9-203 ( b ), 9-210, and 3-301, only the party in possession of the original, authenticated security agreement and entitled by law may enforce a secured transaction. You have failed to show lawful standing or provide the original instrument with wet-ink signature. Therefore, you are acting without authority and must cease collection attempts immediately. 

UCC 3-301 Person Entitled to Enforce an Instrument iii ) a person not in possession but who is entitled to enforce the instrument under Section 3-309 or 3-418 ( d ). 

If the party does not hold the original instrument ( wet-ink contract or promissory note ), and can not show the chain of title, they lack standing to enforce the debt. 

UCC 9-210 Request for Accounting and Request Regarding a List of Collateral or Statement of Account 1. 12 CFR 226.17 Truth in Lending Act ( TILA ) Disclosures Requires clear disclosure of credit terms by the original creditor. 
Debt collectors must inherit this duty if they claim to own the debt.

If they cant verify the terms from the original creditor, they may be in violation.

A debtor may send an authenticated demand to a secured party for an accounting of the obligation secured, a list of collateral, or a statement of 2. 12 CFR 1026.39 Mortgage Transfer Disclosures ( Reg Z ) No transfer notice = no lawful assignment = no standing. 

4. 31 CFR 363.6 XXXX XXXX XXXX ( XXXX context ) Covers registration and ownership of book-entry securities. 
Important if youre asserting that the debt has been securitized. 
If your debt was securitized, it may no longer be a collectible item by a 3rd party. 

If the debt is securitized and registered as a security, the only lawful party is the holder in due course. You must prove that status. 

5. 31 CFR 103.121 ( now 31 CFR 1020.220 ) Customer Identification If you possess or use my private information without proof of lawful transfer, you may be violating federal identity protections. 

26 CFR 1.6045-1 Requires brokers to file Form 1099-B for certain securities transactions.

26 CFR 1.6049-5 Relates to OID ( Original Issue Discount ) reporting on Form 1099-OID.

: If my debt has been securitized or used in a financial transaction, IRS disclosure forms must exist. I demand to see any filings under my name or estate. 

i have the right to demand proof from any party claiming to be a secured party ( such as a debt collector ) and they must respond with accurate documentation. If they fail or provide incomplete information, they are not lawfully standing in the position of a secured creditor. 

Only a party with a valid, authenticated security agreement ( usually the original creditor ) and proper proof of assignment or transfer can enforce a security interest. 

This is my second notice to the company. They are attempting to collect a debt without providing proper verification. I have only received a copy, not the original contract with my wet-ink signature. This is a violation of my privacy rights, and I am concerned my information was sold or traded without my consent. I have requested documentation of debt purchase, filings of any 1099-B or OID forms, and proof of assignment from the original creditor. If they do not respond, I will file Form 3949-A with the IRS, initiate arbitration, and pursue liens and identity theft charges. I am seeking a full deletion and discharge of this debt immediately. 

NOTICE TO CEASE COLLECTION ACTIVITY IMMEDIATELY This is Notice Number 2. You are hereby instructed to CEASE AND DESIST all collection activities related to the above-referenced account due to your continued failure to provide the original wet-ink signed contract as proof of debt obligation. You have merely provided a copy, which is not valid evidence of a legally binding agreement under UCC and contract law.

Let this serve as further notice that your continued attempts to collect without proper and verified documentation is not only an invasive practice but may constitute acquiescence to claims that you have no lawful right to pursue this alleged debt. 

YOU ARE HEREBY PUT ON NOTICE OF THE FOLLOWING : 1. You have not shown standing as a real party in interest with proof of assignment from the original creditor.

2. You have not demonstrated that you purchased the debt including the original terms and agreement.

3. If this debt was securitized, which is likely, then Forms 1099-B and OID were likely filed on my behalf without authorization. 
4. You must show proof that you lawfully purchased my personal information, including my Social Security Number, address, and other private data, or this constitutes a breach of privacy, potential identity theft, and unauthorized trading of a financial instrument. 
5. You have failed to verify your claim pursuant to the Fair Debt Collection Practices Act ( 15 USC 1692g ( b ) ).

DEMAND FOR PROOF : The original contract with my wet-ink signature.

A complete chain of title from the original creditor to your agency.

A statement showing whether Forms 1099-B, 1099-A, or OID have been filed under my name or trust. 
A notarized affidavit from the original creditor acknowledging your legal standing. 
A UCC financing statement to show perfected lien and security interest FAILURE TO RESPOND : If you do not comply with the above within 15 calendar days from the date of this notice, you will be deemed in default, and I will proceed with : 1. Filing a formal complaint with the FTCfor invasive and deceptive debt collection practices.

2. Filing Form 3949-A with the IRS to report potential tax fraud.

3. Filing Form 211 ( XXXX XXXX XXXX ) regarding unlawful securitization and tax violations.

Company response to consumer: Closed with explanation