{"took":316,"timed_out":false,"_shards":{"total":5,"successful":5,"skipped":0,"failed":0},"hits":{"total":{"value":10,"relation":"eq"},"max_score":null,"hits":[{"_index":"complaint-public-v1","_id":"14402376","_score":17.736938,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXEquifax Information Services LLC\\XXXX XXXX XXXX XXXX Formal Dispute Inaccurate and Misleading Collection Account Reporting\\n\\nAccount Name: XXXX XXXX XXXX XXXXDear EquifaxXXXX am writing to formally dispute and demand the immediate deletion of a collection account listed on my credit report under XXXX XXXX This account is being reported inaccurately, deceptively, and without proper verification, in direct violation of the Fair Credit Reporting Act (FCRAXXXX Why the Account Is Inaccurate and UnverifiableXXXX. The account is being reported by XXXX XXXX yet I received a collection email from XXXX XXXX XXXX XXXX) in XXXX XXXX, attempting to collect on this exact same account with a different balanceXXXX XXXX offered a 15-day settlement for less than the full balance, which suggests the account was either sold or assigned to a third-party collectorXXXX XXXX has never contacted me directly regarding this debt, and I have not received any documentation proving they are still the owner of this account. If the debt was soldXXXX XXXX has no legal right to continue reporting it under their nameXXXX. I formally requested debt validation and documentation from XXXX including the chain of assignment, original contract, and proof of ownership, and they failed to respond. Under both the FCRA and FDCPA, a debt that cannot be validated must not be reported or collected.\\n\\n4. Despite providing proof of third-party collection activity by XXXX which contradicts the reporting your bureau has continued to verify this account as accurate. This raises serious concerns about the integrity and legality of your reinvestigation procesXXXX. On XXXX XXXX XXXX a major XXXX data breach was publicly reported, affecting over 61 million customer records. This breach further undermines the reliability and security of the information XXXX holds and calls into question the accuracy of any debt or identity-based claims associated with my nameXXXXMy DemandsXXXX am formally demanding the following:\\n\\nImmediate deletion of the XXXX XXXX account from my credit report under FCRA 611 due to:\\n\\na. Lack of verification of ownership\\n\\nb. Conflicting balance and collector activity\\n\\nc. Unverified and deceptive third-party collection tacticXXXX A copy of the full method of verification, includingXXXX Who verified the accountXXXX The date and method of verificationXXXX Documentation usedXXXX Whether XXXX or XXXX currently owns the debXXXX A certified copy of any documentation in your records that substantiates the debt, including:XXXX The original signed contractXXXX Chain of assignmentXXXX The identity of the collector authorized to collect or reporXXXXf this account cannot be fully and accurately verified with original documentation, it must be immediately deleted from my credit report in accordance with federal law.XXXXThank you for your prompt attention. Please send me a response within the 30-day window, including the results of your reinvestigationXXXX XXXX","date_sent_to_company":"2025-07-02T00:40:01.000Z","issue":"Problem with a company's investigation into an existing problem","sub_product":"Credit reporting","zip_code":"60621","tags":null,"has_narrative":true,"complaint_id":"14402376","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"EQUIFAX, INC.","date_received":"2025-07-02T00:27:40.000Z","state":"IL","company_public_response":null,"sub_issue":"Their investigation did not fix an error on your report"},"highlight":{"complaint_what_happened":["Under both the FCRA and FDCPA, a debt that cannot be validated must not be reported or collected.\\n\\n4. Despite providing proof of third-party collection activity by XXXX which contradicts the reporting your bureau has continued to verify this account as accurate. This raises serious concerns about the integrity and legality of your reinvestigation procesXXXX. On XXXX XXXX XXXX a major XXXX data breach was publicly reported, affecting over 61 million customer records."]},"sort":[17.736938,"14402376"]},{"_index":"complaint-public-v1","_id":"10739565","_score":13.119828,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"Dear Sir, Madam, or to whom elsewise it may concern\nI am hereby contesting the accuracy of any information contained within my credit report that lacks\nsubstantiated evidence. This pertains particularly to unproven claims, such as allegations of delinquency and\nderogatoriness. My action is aligned with the provisions set forth in the Fair Credit Reporting Act (FCRA) and\nadheres to the recognized industry standard for Metro 2 data field reporting. I emphasize that, in accordance\nwith federal and state laws, it is imperative that all allegations are reported accurately and comprehensively.\nReporting claims that contravene established laws and regulations is not only inaccurate but also unjust.\nI write to formally notify you of the necessity to ensure the factual and accurate reporting of all claims, as\nmandated by the Metro 2 reporting standard. I kindly request that you furnish tangible, verifiable evidence\nsubstantiating the existence of the account and its lawful usage. Should such evidence not be forthcoming, I\ninsist on the removal of said account from my credit report. In accordance with this request, I grant\nauthorization for the delivery of physical documentation detailing your actions and an updated copy of my\ncredit report. Your prompt attention to this matter is greatly appreciated.\nListed below are the Personal Information that are being challenged\nEmployer - XXXX XXXX XXXX\nIncorrect Name: - XXXX XXXX XXXX Incorrect Previous Address: - XXXX XXXX XXXX XXXX XXXX, FL XXXX Incorrect Previous Address: - XXXX XXXX XXXX XXXX XXXX, FL XXXX Listed below are the Accounts that are being challenged\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Listed below are the Collections that are being challenged\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX\nListed below are the Inquiries that are being challenged XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX The following personal information is incorrect - The personal data reporting is inaccurate.\n1 of 1\nI am writing to request that you kindly update your records regarding the account of Employer with XXXX XXXX XXXX. I have noticed that the current information in your records is inaccurate and does not meet the\nminimum standard for accuracy.\nMay I kindly bring to your attention that failure to correct inaccurate data may result in legal action. Inaccurate\ninformation has no place in either your records or on my credit report, and as a valued customer, I respectfully\ndemand that it be removed without any delay.\nIncorrect Name: - XXXX XXXX XXXX The following personal information is incorrect - The personal data reporting is inaccurate.\nIncorrect Name: - XXXX XXXX XXXX\nI would like to kindly request your attention to a matter pertaining to the accuracy of names listed within your\nesteemed database. It would be greatly appreciated if you could ensure that my true and complete name is\nproperly reflected as XXXX XXXX. If there are any variations or discrepancies in your records, I kindly ask\nthat you promptly remove them to align with the accurate information provided. Your immediate assistance in\nthis regard would be highly valued and contribute to the overall reliability and integrity of your data.\nIncorrect Previous Address: - XXXX XXXX XXXX XXXX XXXX, FL XXXX The following personal information is incorrect - The personal data reporting is inaccurate.\nIncorrect Previous Address: - XXXX XXXX XXXX XXXX XXXX, FL XXXX I am writing to bring to your attention a critical matter pertaining to my credit file. It has recently come to my\nattention that an address is associated with my credit report which is no longer my place of residence and is\nnon-deliverable by the United States Postal Service. In the interest of safeguarding my personal identity and\npreventing any potential identity fraud, I kindly request that you remove this incorrect address from my file\nwithout any delay. Furthermore, I would like to emphasize that I have never resided at the aforementioned\naddress, and thus, this personal information is inaccurate and incomplete. I urge you to take prompt action in\nremoving this information from my credit report, as it is your responsibility to ensure that the information in my\nfile is up-to-date and accurate.\nIncorrect Previous Address: - XXXX XXXX XXXX XXXX XXXX, FL XXXX The following personal information is incorrect - The personal data reporting is inaccurate.\nIncorrect Previous Address: - XXXX XXXX XXXX XXXX XXXX FL XXXX I would like to bring to your attention that the address associated with my profile is no longer valid and has\nbeen deemed undeliverable by the United States Postal Service. In order to prevent any potential instances of\nidentity fraud, I kindly request that you remove this address from my account. It is imperative that this action is\ntaken as soon as possible, and I trust that you understand the gravity of this situation. Moreover, I would like to\ninform you that I have never resided at this address, and therefore, the personal information linked to it is\ninaccurate and incomplete. I urge you to please delete this address from my credit file to ensure the\ncorrectness and integrity of my credit report.\nXXXX XXXX XXXX XXXX This account is inaccuarately reporting late payments on multiple bureaus. The discrepancies in the payment\nstatus across XXXX, XXXX, and Transunion violate 15 USC 1681e(b), which mandates the bureaus to\nmaintain maximum possible accuracy of consumer reports. The account also displays inconsistency in\nreporting activity dates. - I have not received any documentation validating the legitimacy of this debt or\nconfirming the details reported. Under FCRA 15 USC 1681i(a)(5)(A), unverifiable information must be deleted\nfrom my report. If the credit bureau cannot substantiate this account's accuracy, I expect to be removed\nimmediately\nI regret to express my disappointment regarding the lack of documented evidence concerning compliance\n2 of 1\nreporting standards and applicable consumer laws, which represents a significant deficiency. It is imperative\nthat the flawed and inaccurate report be expeditiously deleted to rectify this matter. Failure to comply may\nresult in legal repercussions for your company, as it has not fulfilled the prescribed requirements outlined by\nthe law in terms of compliance and consumer protection. Accurate information is of utmost importance to\nproactively mitigate potential future issues. Regrettably, it appears that your seriousness in addressing this\nmatter is lacking, and I am compelled to consider pursuing legal action as a necessary course of action.\nXXXX - XXXX The inconsistency misrepresents my payment history and is clear violation of FCRA 15 USC 1681e(b), which\nmandates that credit bureaus must report accurate and consistent information. - Under 15 USC 1681i(a)(1)(A),\nI request an immediate investigation into these discrepancies. If accurate information cannot be obtained, this\naccount must be updated or deleted. The account is marked with comment \"Consumer disputes this\ninformation charge\" However the information has not been updated to reflect any resolution, violating my rights\nunder 15 USC 1681s-2(a)(3). I have not receiving any evidence validating the legitimacy if this debt or details\nreported. Under FCRA 15 USC 1681i(a)(5)(A) unverifiable information must be deleted from my report. If\nEquifax cannot provide substantiating documentation for this account, I expect it to be removed immediately\nI am writing to express my profound disappointment regarding the current status of the information associated\nwith XXXX and XXXX within your database. It has come to my attention that the data is not\nup-to-date and fails to adhere to the minimum standards of accuracy that one would expect. I feel compelled to\nbring this matter to your immediate attention, as the presence of incorrect and incomplete information within\nyour database and on my credit report is both unacceptable and incongruous. In light of these concerns, I\nrespectfully request that you take immediate action to rectify this situation. Failure to do so in a timely manner\nmay leave me with no alternative but to explore legal remedies. I firmly believe that data integrity is paramount,\nand as such, I kindly ask for the expeditious deletion of the inaccurate information from your database.\nXXXX XXXX XXXX XXXX This account is inaccurately reporting late payments on multiple bureaus. The discrepancies in the payment\nstatus XXXX, XXXX, and TransUnion violate 15 USC 1681e(b), which mandates the bureaus to maintain\nmaximum possible accuracy of consumer reports. The account also display inconsistency in reporting activity\ndate. - This is paid as agreed and should not be reporting negatively on my report. I am disputing the accuracy\nof this account under 15 USC 1681i. Please update the late payments to \"Paid as agreed, never late,\" in\naccordance with 15 USC 1681e(b). The account must be corrected across all three bureaus, or it should be\nremoved due to incomplete and inaccurate reporting. Failure to correct these discrepancies violates 15 USC\n1681i(5). If the issues are not resolved, the account should be deleted.\nI must express my disappointment that despite my repeated requests, you have not yet provided me with any\ndocumented proof of compliance reporting standards and applicable consumer laws. This deficiency is\nsignificant and cannot be overlooked.\nAs a result, I kindly request that you take immediate action to delete this flawed and inaccurate report from\nyour records. Failure to do so may result in legal action being taken against your company for failing to meet\nthe requirements set out by law with regards to these matters.\nIt is imperative that we have access to accurate and reliable information in order to prevent preventable issues\nfrom arising in the future. Therefore, I would appreciate it if you could provide me with the necessary\ndocumentation, so that I may better understand the situation at hand.\nIn addition, please refer to the attached image pertaining to my XXXX XXXX XXXX XXXX, which\nhighlights additional areas of concern. I would greatly appreciate it if you could take the necessary steps to\naddress these concerns promptly.\nXXXX - XXXX The account is listed as \"closed\" by XXXX and Transunion, but \"open\" by XXXX. The inconsistency in\n3 of 12\nreporting violates FCRA 15 USC 1681e(b), which mandates that credit bureaus report only accurate and\nconsistent informartion. - This is account is inaccurately reporting late payments, and discrepancies in\nreporting the across bureaus violate 15 USC 1681e(b), which mandates maximum possible accuracy in\nconsumer reports. The \"Late Pay\" issue reflects inconsistent data between XXXX, XXXX, and TransUnion,\nwhich is legally required to be fully accurate and consistent.\nI am writing to express my profound dissatisfaction with the current state of the information pertaining to\nXXXX and XXXX within your database. It is disheartening to note that the provided data lacks\ncurrency and fails to adhere to the essential benchmarks of accuracy. I implore you to address this matter with\nthe utmost urgency. Failure to rectify this situation in a timely manner may leave me with no choice but to\npursue legal recourse. It is imperative to emphasize that erroneous and flawed data should have no bearing\nwithin your esteemed database or on my credit report. Consequently, I earnestly request the immediate\ndeletion of said information.\nXXXX - XXXX This account is inaccurately reporting late payments and charge-offs with discrepancies across all three credit\nbureaus, which violates 15 USC 1681e(b) requiring maximum possible accuracy in consumer reports. The\n\"Late Pay\" and \"Charge Off\" remarks are inconsistent, and the balance information lacks compliance with the\nstandard reporting accuracy. - PLEASE DELETE ACCOUNT. This account violate these laws 15 USC 1681i,\n15 USC 1681s2, 15 USC 1681i5, 15 USC 1681eb.\nXXXX - XXXX,\nI kindly request your attention to the data presented above, which appears to lack proper certification to meet\nreporting standards. Additionally, it is important to acknowledge that this information may be incomplete,\noutdated, or unsupported. With utmost respect, I would appreciate your prompt consideration in removing any\ninaccurate or unsupported material from this page.\nXXXX - XXXX This account is inaccurately reporting late payments and charge-offs with discrepancies across all three credit\nbureaus, which violates 15 USC 1681e(b) requiring maximum possible accuracy in consumer reports. The\n\"Late Pay\" and \"Charge Off\" remarks are inconsistent, and the balance information lacks compliance with the\nstandard reporting accuracy. - Please remove any inaccurate, incomplete, and/or unverifiable information from\nmy consumer report.\nWe would like to bring to your attention the inconsistency pertaining to the currently reported XXXX with account number displayed as XXXX, which has been observed across the\nthree credit reporting agencies. It is our obligation to ensure that all reported items comply with the mandated\nreporting industrys own Metro 2 Data-filled Field Formatted reporting compliance standards. Any\ninconsistency, incompleteness, inaccuracy, or omission of the reported item serves as a discrepancy from\nthese standards, which must not deviate to maintain the integrity of the data, as stated in the XXXX XXXXXXXX XXXX.\nAs such, until there is evident confirmation of all aspect(s) of claim(s) that are factually true, correct, complete,\ntimely, physically verifiable, and elsewise undeniably valid, particularly if not certifiably compliant in full\naccording to the above-mentioned Metro 2 formatted industry requirements, the reported item in question\nremains lawfully questionable.\nXXXX - XXXX This account is inaccurately reporting late payments and charge-offs with discrepancies across all three credit\nbureaus, which violates 15 USC 1681e(b) requiring maximum possible accuracy in consumer reports. The\n\"Late Pay\" and \"Charge Off\" remarks are inconsistent, and the balance information lacks compliance with the\nstandard reporting accuracy. - Please remove any inaccurate, incomplete, and/or unverifiable information from\nmy consumer report.\n4 of 12\nWe would like to bring to your attention that the XXXX currently being reported, along with its\ncorresponding account number XXXX, exhibits inconsistencies across the three major credit reporting\nagencies. It is important to note that any discrepancy, incompleteness, inaccuracy, or omission in the reported\ninformation goes against the Metro 2 Data-filled Field Formatted reporting compliance standards, which are\nmandatorily enforced by the reporting industry. Deviation from these standards can potentially compromise the\nintegrity of the data, as outlined in the XXXX XXXXXXXX XXXX, and thus, raises concerns about the legality of the\nreported item until all claims are verifiably true, correct, complete, timely, physically verifiable, and fully\ncompliant with the aforementioned Metro 2 formatted industry requirements. Therefore, we kindly request your\nattention to the following suspect data fields associated with the contested reported item of injury.\nXXXX - XXXX This account is inaccurately reporting late payments and charge-offs with discrepancies across all three credit\nbureaus, which violates 15 USC 1681e(b) requiring maximum possible accuracy in consumer reports. The\n\"Late Pay\" and \"Charge Off\" remarks are inconsistent, and the balance information lacks compliance with the\nstandard reporting accuracy. - PLEASE DELETE ACCOUNT. This account violate these laws 15 USC 1681i,\n15 USC 1681s2, 15 USC 1681i5, 15 USC 1681eb.\nI am writing to bring to your attention the following details pertaining to XXXX - XXXX. It is\nimportant to note that the aforementioned data has not undergone certification to comply with any reporting\nstandards. Consequently, we cannot assure its accuracy, currency, or comprehensiveness. Moreover, it is\npertinent to highlight that this information may be incomplete, outdated, or lacking support. Therefore, I kindly\nrequest the removal of any erroneous or unsupported content from this page.\nXXXX XXXX XXXX This account is inaccurately reporting late payments and charge-offs with discrepancies across all three credit\nbureaus, which violates 15 USC 1681e(b) requiring maximum possible accuracy in consumer reports. The\n\"Late Pay\" and \"Charge Off\" remarks are inconsistent, and the balance information lacks compliance with the\nstandard reporting accuracy. - PLEASE DELETE ACCOUNT. This account violate these laws 15 USC 1681i,\n15 USC 1681s2, 15 USC 1681i5, 15 USC 1681eb.\nI would like to respectfully bring to your attention that the account identified as XXXX XXXX XXXX has been\nreported as an alleged XXXX, which has not been confirmed. I have received a section of a credit report\nindicating that the account number has not been reported or is not in compliance with the established\nstandards for credit reporting agencies. This can raise concerns about the accuracy and integrity of the data\nbeing reported. It is important to adhere to the established standards for reporting data fields, including the\naccount number, without any deviation, as emphasized in the report. Thank you for your attention to this\nmatter.\nXXXX XXXX XXXX\nThe collection account shows inconsistencies in bureaus and lacks validation under 15 USC 1692g.\nAdditionally, the account charge-off status does not align with accurate reporting procedures, violating 15 USC\n1681e(b), which mandates maximum possible accuracy in credit reporting. - Please remove any inaccurate,\nincomplete, and/or unverifiable information from my consumer report.\nWe would like to bring to your attention that there appears to be an inconsistency with regards to the\nXXXX associated with the displayed XXXX across all three credit reporting agencies.\nIt is imperative to note that any inconsistency, incompleteness, inaccuracy or omission in the reported item is a\ndeviation from the mandatory industry standards for reporting compliance, as per the Metro 2 Data-filled Field\nFormatted reporting compliance standards. Any deviation from these standards could potentially jeopardize the\nintegrity of the data (as stated in XXXX XXXX XXXX, and therefore, the accuracy of the reported item is subject\nto lawful scrutiny until all aspects of the claim are factually confirmed to be true, correct, complete, timely,\nphysically verifiable, and otherwise undeniably valid, particularly if not compliant with the above-mentioned\nMetro 2 formatted industry requirements. We respectfully request your attention to the following suspect\nreported data fields alleged for this now contested reported item of injury.\n5 of 12\nXXXX - XXXX This account is reporting inconsistencies in reporting is a violation of FCRA 15 USC 1681e(b), which requires\ncredit bureaus to report only accurate and consistent information. - PLEASE DELETE ACCOUNT. This\naccount violate these laws 15 USC 1681i, 15 USC 1681s2, 15 USC 1681i5, 15 USC 1681eb.\nXXXX - XXXX,\nI respectfully bring to your attention that the data provided above has not undergone the necessary certification\nprocess to meet established reporting standards. Additionally, it appears that this information may be\nincomplete, outdated, or lacking proper support. Therefore, I kindly request the removal of any inaccurate or\nunsupported content from this page. XXXX XXXX XXXX XXXX This account is inaccurately reporting late payments and charge-offs with discrepancies across all three credit\nbureaus, which violates 15 USC 1681e(b) requiring maximum possible accuracy in consumer reports. The\n\"Late Pay\" and \"Charge Off\" remarks are inconsistent, and the balance information lacks compliance with the\nstandard reporting accuracy. - Please remove any inaccurate, incomplete, and/or unverifiable information from\nmy consumer report.\nXXXX XXXX XXXX XXXX\nI kindly bring to your attention that the aforementioned data has not been duly certified to comply with\nestablished reporting standards. Additionally, it is crucial to acknowledge that this information might be\nincomplete, outdated, or lacking in support. Therefore, I respectfully request the removal of any inaccurate or\nunsupported content from this page.\nXXXX XXXX XXXX XXXX The collection account shows inconsistencies in bureaus and lacks validation under 15 USC 1692g.\nAdditionally, the account charge-off status does not align with accurate reporting procedures, violating 15 USC\n1681e(b), which mandates maximum possible accuracy in credit reporting. - PLEASE DELETE ACCOUNT.\nThis account violate these laws 15 USC 1681i, 15 USC 1681s2, 15 USC 1681i5, 15 USC 1681eb. XXXX XXXX XXXX XXXX,\nI would like to kindly bring to your attention that the data presented above appears to lack certification to meet\nthe required reporting standards. Additionally, it is essential to acknowledge that this information may be\nincomplete, outdated, or unsupported. Therefore, I respectfully request the removal of any inaccurate or\nunsupported material from this record. XXXX XXXX XXXX\nThis account is inaccurately reporting late payments and charge-offs with discrepancies across all three credit\nbureaus, which violates 15 USC 1681e(b) requiring maximum possible accuracy in consumer reports. The\n\"Late Pay\" and \"Charge Off\" remarks are inconsistent, and the balance information lacks compliance with the\nstandard reporting accuracy. - Please remove any inaccurate, incomplete, and/or unverifiable information from\nmy consumer report.\nI respectfully request that any detrimental aspects related to the allegations made against me be expunged\nfrom my credit report. The specific item in question is XXXX XXXX XXXX I hold the belief that this\nitem may have been reported unjustly, lacking the necessary authentication, or even in violation of the law.\nIt is my understanding that the law requires the expunction of the accusations of late payments associated with\nthis item. Thus, I request that such allegations be deleted from my credit report promptly.\n6 of 12\nINQUIRY XXXX XXXX XXXX XXXX\nVerify that the following inquiry was authorized? - If you are unable to verify this information, please promptly\nremove it from my credit report.\nI have attempted to communicate with INQUIRY XXXX XXXX XXXX regarding the credit inquiry they\nplaced on my credit profile. Despite my request for the removal of the inquiry and the cessation of their\nunlawful activities, they have failed to respond. It has been over 30 business days since I sent the letter, and I\nhave not received any communication from their office.\nAs a result, I am respectfully requesting your assistance in resolving this matter. Pursuant to the provisions of\nthe Fair Credit Reporting Act, I kindly request that you conduct an investigation into this inquiry on my credit\nreport to determine the identity of the authorizing party. If, following the completion of your investigation, you\nfind merit in my assertion, I request that you promptly remove the unauthorized inquiry from my credit report\nand provide me with an updated copy of my credit report, which can be sent to the address listed above.\nIn the event that you determine the inquiry to be valid, I respectfully request that you provide me with a detailed\ndescription of the procedures that were utilized during your investigation within 15 business days of its\nconclusion. Thank you for your prompt attention to this matter.\nINQUIRY - XXXX XXXX XXXX XXXX\nVerify that the following inquiry was authorized? - If you are unable to verify this information, please promptly\nremove it from my credit report.\nINQUIRY - XXXX XXXX XXXX XXXX I am writing to express my deep concern regarding an unauthorized inquiry that appeared on my credit report\nrecently. As you are aware, under the Fair Credit Reporting Act, it is imperative that no one accesses an\nindividual's information without obtaining their prior consent. Therefore, I would like to request that you provide\nme with evidence that justifies the presence of this inquiry on my credit report.\nI kindly ask that you furnish me with the necessary documentation that demonstrates the basis for this inquiry,\nincluding any relevant details and signatures that confirm that I had indeed applied for a loan or line-of\u0002business venture through the company in question. I believe that upon reviewing the evidence, you will agree\nthat these inquiries were not appropriate and should not have been included on my credit report.\nI would appreciate it if you could resolve this issue promptly and ensure that my credit report accurately\nreflects my creditworthiness. Please let me know if there is any additional information that you may need from\nme to resolve this matter satisfactorily.\nINQUIRY - XXXX XXXX XXXX XXXX\nVerify that the following inquiry was authorized? - If you are unable to verify this information, please promptly\nremove it from my credit report.\nI hope this message finds you well. I recently reviewed my credit report and identified an unauthorized inquiry\nrelated to my account with INQUIRY and XXXX XXXX XXXX XXXX According to the Fair Credit Reporting\nAct, it is imperative that my information remains safeguarded, and access to it requires proper authorization.\nHence, I kindly request your assistance in providing evidence of the justification for this inquiry. Your\ncooperation in promptly resolving this matter is greatly appreciated.\nINQUIRY - XXXX XXXX XXXX\nVerify that the following inquiry was authorized? - If you are unable to verify this information, please promptly\nremove it from my credit report.\nI write to bring to your attention a concerning matter regarding my recent review of the credit report I received.\n7 of 12\nIt has come to my notice that several credit inquiries have been recorded from companies that I do not recall\ngranting authorization to. I am well aware of the importance of obtaining explicit consent before placing any\ninquiry on my credit file, and thus, I kindly request that you take immediate action to remove this unauthorized\ninquiry from my credit file. Additionally, I kindly request that you provide me with comprehensive\ndocumentation confirming that a thorough investigation has been conducted and that the unauthorized\ninquiries have been expeditiously removed from my records.\nINQUIRY - XXXX XXXX XXXX XXXX XXXX\nVerify that the following inquiry was authorized? - If you are unable to verify this information, please promptly\nremove it from my credit report.\nI trust this message finds you well. I am writing to address a matter concerning my account with INQUIRY and\nits corresponding XXXX XXXX XXXX XXXX XXXX. During a recent review of my credit report, I have come across\nan unauthorized inquiry. Under the provisions of the Fair Credit Reporting Act, it is imperative to ensure that\nmy personal information remains protected, and access is granted solely with proper authorization. I kindly\nrequest your assistance in providing documented justification for the aforementioned inquiry. Your prompt\nattention to this concern is highly appreciated, and I believe that together, we can ensure the accuracy and\nintegrity of my credit report.\nINQUIRY - XXXX XXXX XXXX Verify that the following inquiry was authorized? - If you are unable to verify this information, please promptly\nremove it from my credit report.\nRegarding the information provided under the INQUIRY - XXXX XXXX XXXX, I would like to bring to your\nattention that it has not been verified to meet the necessary reporting standards. Its accuracy, completeness,\nand currency have not been established, and to ensure compliance with consumer protection laws,\ndocumentation proving compliance is required. The information supplied is inadequate, and I am requesting\nthe immediate deletion of any incorrect, incomplete, or unsupported data.\nI would greatly appreciate it if you could provide me with any further information or documentation necessary to\naddress these concerns and ensure that the information provided is compliant with the relevant standards.\nINQUIRY - XXXX XXXX XXXX XXXX Verify that the following inquiry was authorized? - If you are unable to verify this information, please promptly\nremove it from my credit report.\nI recently obtained a copy of my credit report and was disconcerted to observe credit inquiries made by\ncompanies for which I have no recollection of granting authorization. I am aware that inquiries should not be\nplaced on my credit file without proper consent, and I kindly request the prompt removal of this unauthorized\ninquiry from my credit file. Furthermore, I would greatly appreciate receiving official documentation confirming\nthat a thorough investigation has been conducted and that the aforementioned unauthorized inquiries have\nbeen successfully expunged.\nINQUIRY - XXXX XXXX XXXX\nVerify that the following inquiry was authorized? - If you are unable to verify this information, please promptly\nremove it from my credit report.\nI recently obtained a copy of my credit report and was surprised to discover credit inquiries made by\ncompanies that I have no recollection of authorizing. As per the established protocols, it is crucial that no\ninquiries be placed on my credit file without explicit authorization. Therefore, I kindly request the immediate\nremoval of this particular inquiry from my credit file. Additionally, I would highly appreciate receiving\ncomprehensive documentation affirming that a thorough investigation has been conducted and the\nunauthorized inquiries have been diligently eradicated.\n8 of 12\nINQUIRY XXXX XXXX XXXX XXXX XXXX\nVerify that the following inquiry was authorized? - If you are unable to verify this information, please promptly\nremove it from my credit report.\nI hope this message finds you well. I am writing to bring to your attention the presence of an alleged hard\ninquiry on my credit report associated with my INQUIRY and XXXX XXXX XXXX XXXX Upon receiving\nmy credit report today, I noticed this inquiry, but I do not have any recollection of authorizing it. Therefore, I\nkindly request that you provide me with documented proof of the credit application, including a valid signature\nconfirming my application for credit with the said company. If such documentation cannot be provided, I would\nappreciate an immediate removal of the alleged inquiry from my credit report.\nINQUIRY - XXXX XXXX XXXX\nVerify that the following inquiry was authorized? - If you are unable to verify this information, please promptly\nremove it from my credit report.\nPlease see attachment","date_sent_to_company":"2024-11-09T18:16:47.000Z","issue":"Improper use of your report","sub_product":"Credit reporting","zip_code":"32244","tags":null,"has_narrative":true,"complaint_id":"10739565","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"TRANSUNION INTERMEDIATE HOLDINGS, INC.","date_received":"2024-11-09T17:59:11.000Z","state":"FL","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Reporting company used your report improperly"},"highlight":{"complaint_what_happened":["If such documentation cannot be provided, I would\nappreciate an immediate removal of the alleged inquiry from my credit report.\nINQUIRY - XXXX XXXX XXXX\nVerify that the following inquiry was authorized? - If you are unable to verify this information, please promptly\nremove it from my credit report.\nPlease see attachment"]},"sort":[13.119828,"10739565"]},{"_index":"complaint-public-v1","_id":"7176495","_score":12.633167,"_source":{"product":"Credit reporting, credit repair services, or other personal consumer reports","complaint_what_happened":"Experian has violated my rights under the FCRA. I asked experian to conduct an investigation into multiple accounts to ensure its accuracy. they concluded their alledged investigation without removing accounts that are not accurately reporting. I demand the deletion of said accounts: \n\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXt has come to my attention that the reported Account Type XXXX, Account Type Details, Bureau Code,Payment Status XXXXXXXX High Credit XXXX, Monthly Payment XXXX No. of Months (terms) XXXX, Last Reported, Date Last Active (XXXXXXXX XXXX XXXX Year History across all bureaus may not meet the required reporting standards and decorum. Therefore, I am writing to request an explanation regarding the discrepancies observed in your account, which appear to be inconsistent with the established reporting guidelines at XXXX XXXX XXXX XXXX XXXX XXXX\n\nIt has been brought to our attention that the Account Type Details, Bureau Code, Monthly Payment (XXXX, No. of Months (terms) XXXX, Last Reported & Date Last Active XXXX reported is displaying inconsistencies among the three credit reporting agencies. As you are aware, adherence to XXXX XXXX standards is of utmost importance to ensure precise and reliable data reporting. Any deviation from these mandatory fields would compromise the integrity of all reported information. Upon reviewing this account, the observed inaccuracies raise doubts about the credibility of the entire account. Therefore, we kindly request your attention to rectify the reported discrepancies promptly. XXXX XXXX XXXX XXXX\n\nThe account associated with the name XXXX XXXX and the corresponding XXXX XXXX XXXX, as indicated in my report, lacks substantiated evidence of its validity, accuracy,completeness, and compliance with certified reporting standards. It is important to acknowledge the fact that the XXXX (XXXX XXXX XXXX XXXX) itself has either implied or explicitly stated that any deviation\nfrom the law or established credit reporting industry standards renders a claim deficient. Consequently, it is imperative to remove any and all such claims from reporting, with the condition that they can only be reintroduced if they can be proven to be lawfully compliant with all requirements for legitimate reporting. This action is necessary, irrespective of any apparent misapplication, willful ignorance, or reckless negligence on\nyour part regarding your reporting practices and claims. It is essential to take note of any deviations, including but not limited to the following issues, as sufficient grounds for the appropriate elimination of the claim's reportability.\n\nWe would like to bring to your attention that the Account Type (XXXX), Account Type Details, Bureau Code, Payment Status XXXX), High Credit XXXX, Monthly Payment XXXX, No. of Months (terms) XXXX Last Reported, Date Last Active XXXX XXXX XXXX Year History may suggest a failure to meet established reporting standards or decorum. Upon review of the information reported, it has become apparent\nthat there are deviations from the required industry standards, which may result in inaccurate data. We would like to remind you of the paramount importance of complying with XXXX XXXX guidelines and ensuring that all fields are accurately and completely filled out before adding anything to our credit profile. We kindly request\nthat you take appropriate corrective measures to rectify this issue and avoid any potential negative impact on our credit standing. Thank you for your attention to this matter\n\nXXXX XXXX XXXX\n\n kindly request that you review and update my information as soon as possible, as it currently appears to be inaccurate and does not meet the minimum standards for accuracy. It would be greatly appreciated if you\ncould rectify this issue promptly, as having incorrect data in your records or on my credit report is not acceptable. If it is not too much trouble, could you also please take a moment to review the attached image, which highlights some additional areas of concern regarding my XXXX XXXX XXXX Your assistance in resolving these issues would be greatly appreciated. We would like to bring to your attention that the reported Account Type XXXX, Account Type Details,\nBureau Code, Payment Status XXXX High Credit XXXX, Balance XXXX Monthly Payment XXXX No. of Months (terms) XXXX Date Last Active XXXX XXXX XXXX Year History appears to be inconsistent across the three credit reporting agencies. It is crucial to adhere to the XXXX XXXX standards to ensure precise data reporting. Any deviation from these mandatory fields would jeopardize the integrity of all reported\ninformation. Therefore, we urge you to take swift action to address the apparent inaccuracies as it calls into question the entire account. Your cooperation in this matter is highly appreciated.\n\nXXXX XXXX XXXX\n\nIt has come to my attention that the reported Account Type XXXX, Account Type Details, Bureau Code, Payment Status XXXX, Credit Limit XXXX High Credit (XXXX, No. of Months (terms) XXXX XXXXast Reported, Date Last Active XXXX XXXX XXXX Year History across all bureaus does not meet the requisite standards with regard to reporting requirements and decorum. I am reaching out to request an explanation for\nthe discrepancies observed in your account's reported information, which appears to be inaccurate or inconsistent with the established XXXX reporting standards. I would appreciate prompt and immediate resolution of these issues to ensure compliance with the mandated guidelines. Thank you for your attention to this matter. XXXX XXXX XXXX XXXX XXXX\n\nI respectfully request that any detrimental aspects related to the allegations made against me be expunged from my credit report. The specific item in question is XXXX XXXX XXXX XXXX XXXX. I hold the belief that this item may have been reported unjustly, lacking the necessary authentication, or even in violation of the law.\nIt is my understanding that the law requires the expunction of the accusations of late payments associated with this item. Thus, I request that such allegations be deleted from my credit report promptly. I would like to draw your attention to an Account Type XXXX, Account Type Details, Bureau Code, Payment Status XXXX, Credit Limit XXXX Monthly Payment XXXX, No. of Months (terms) XXXX, Last Reported, Date Last Active XXXX XXXX XXXX XXXXear History that has been identified in the report. It\nappears that the data pertaining to this account may be inaccurate or inconsistent with the established reporting standards of the XXXX I kindly request that you thoroughly review the information once again, ensuring its validity, accuracy, completeness (within the given timeframe), verification, and compliance with all necessary requirements. If, upon reevaluation, the data does not meet these criteria, I respectfully request\nthat my profile be removed.\n\n\nXXXX XXXX XXXX\n\nI hereby bring to your attention the matter concerning the data pertaining to XXXX XXXX XXXX. It is imperative to acknowledge that the aforementioned data has not undergone any certification process to validate its adherence to established reporting standards. Consequently, it cannot be guaranteed that the included information is accurate, current, or comprehensive in nature. Moreover, it is essential to recognize\nthat this data may be incomplete, outdated, or lacking in proper support. In light of these circumstances, I kindly request the removal of any inaccurate or unsupported content from the aforementioned page. We would like to inform you that the reporting of Account Type XXXX Account Type Details, Account Status XXXX Bureau Code, Payment Status XXXX, No. of Months (terms) XXXX Last Reported & Date Last Active XXXX does not meet the necessary standards for reporting, as mandated by\nregulatory bodies.\n\nI am writing to bring to your attention the following details pertaining to XXXX XXXX XXXX XXXX XXXX It is important to note that the aforementioned data has not undergone certification to comply with any reporting standards. Consequently, we cannot assure its accuracy, currency, or comprehensiveness. Moreover, it is pertinent to highlight that this information may be incomplete, outdated, or lacking support. Therefore, I kindly request the removal of any erroneous or unsupported content from this page. I hereby submit this document to express my apprehensions regarding the adequacy of your reporting, as it fails to meet my standards and remains incomplete. As stipulated by legal obligations, both yourself and the data furnishers bear the responsibility of certifying all facets encompassing the mandatory Fair Credit\nReporting Act (FCRA) and XXXX XXXX compliance. It is imperative that such certification is conducted with utmost adherence to truthfulness, accuracy, comprehensiveness, and timeliness, in order to prevent any inadvertent\ninfringement upon my consumer and civil rights.","date_sent_to_company":"2023-06-27T19:47:17.000Z","issue":"Problem with a credit reporting company's investigation into an existing problem","sub_product":"Credit reporting","zip_code":"19720","tags":null,"has_narrative":true,"complaint_id":"7176495","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Experian Information Solutions Inc.","date_received":"2023-06-27T19:29:29.000Z","state":"DE","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Their investigation did not fix an error on your report"},"highlight":{"complaint_what_happened":["It is crucial to adhere to the XXXX XXXX standards to ensure precise data reporting. Any deviation from these mandatory fields would jeopardize the integrity of all reported\ninformation. Therefore, we urge you to take swift action to address the apparent inaccuracies as it calls into question the entire account. Your cooperation in this matter is highly appreciated."]},"sort":[12.633167,"7176495"]},{"_index":"complaint-public-v1","_id":"17172809","_score":9.810596,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"b'Re: DATA BREACH - Supplemental / Revised Notice & Demand / Dispute / Data Breach + FCRA Violations\\nSubject: Disputed items on file; persistent noncompliance; data breach; request for removal or correction; documentation; XXXXTo Whom It May Concern:\\n\\nI write as a follow-up and supplement to my prior dispute(s), and to place you on further notice of your ongoing noncompliance, and to demand immediate removal or correction of the disputed items. This letter restates and strengthens my position under the Fair Credit Reporting Act (15 U.S.C. 1681 et seq.), 47 U.S. Code 605 Unauthorized publication or use of communications, and related consumer protection and tort theories, and references recent legal developments.\\n\\nBelow is a statement of the facts, legal basis, demands, and preservation instructions. \\n\\n1. Statement of Facts Timeline & Prior Disputes\\n\\t1.\\tIn September 2024, I submitted the first formal dispute notice to TransUnion (or via a furnisher, as applicable) regarding multiple items/accounts on my credit file. That XXXX XXXX XXXXotice was included in the CFPB complaint and report you responded to.\\n\\t2.\\tIn response to the CFPB complaint (filed after that dispute), XXXX TransUnion removed only one of the disputed accounts, claiming to verify the remainder. You have not provided to me, nor (so far as I know), to any court or agency, any substantive creditor or lender documentation that supports your verification of those remaining disputed items (e.g. signed agreements, original statements, XXXX XXXXThe fact that you report many of the same accounts differently across Experian, Equifax, and TransUnion (or even differently from your prior XXXX representations) strongly suggests those items are inaccurate, improperly merged, misattributed, or otherwise erroneous. Indeed, the XXXX XXXX documentation (and the other CRA reports) demonstrate discrepancies that you have ignored or failed to reconcilXXXX above demonstrates a pattern of ongoing noncompliance and violation of your duty under FCRA 1681i to reinvestigate disputed items, correct or delete inaccurate data, and provide rXXXX XXXXarately, TransUnion has recently disclosed a major data breach (XXXX XXXX XXXX) affecting approximately XXXX individuals, in which unauthorized actors accessed a third-party application tied to your consumer support operations. \\n\\t\\tThe breach reportedly exposed names, Social Security numbers, dates of birth, and other personally identifiable information (though you claim no credit information was accessed). XXXXhis breach underscores systemic deficiencies in your data security, internal controls, and breach readiness, and calls into question the integrity of your verification and recordkeeping processes.\\n\\t\\tThe public class action lawsuits (e.g. by firms investigating claims) already reference TransUnions failure to safeguard consumer data. \\n\\nTogether, these facts support a claim that your verifications of my disputed items were not reasonable, and that you have persisted in reporting inaccurate information despite repeated noticeXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX are key legal principles and cases that support your obligations and potential liability.\\n\\n2.1 FCRA Duty to reinvestigate & ensure accuracy\\n\\t\\tUnder 15 U.S.C. 1681i(a), upon receipt of a consumers dispute, a credit reporting agency must conduct a reasonable reinvestigation, consider all relevant information provided, and promptly correct or delete information found to be inaccurate or unverifiable.\\n\\t\\tUnder 15 U.S.C. 1681e(b), a credit reporting agency must follow reasonable procedures to assure maximum possible accuracy of the information in consumer reports.\\n\\t\\tUnder 15 U.S.C. 1681g(b), a consumer has a right to receive a free description of the procedures used in the reinvestigation and the result.\\n\\t\\tUnder 15 U.S.C. 1681i(d), you must provide notice of the results to furnishers and allow them to respond.\\n\\t\\tUnder 15 U.S.C. 1681n (willful noncompliance) and 1681o (negligent noncompliance), I am entitled to statutory damages, actual damages, costs, and attorneys fees, as applicablXXXXBecause you have repeatedly ignored my dispute notices (from XXXX XXXX onward), and have failed to provide credible documentation supporting your verifications, your noncompliance is ongoing and may be willfuXXXX XXXX XXXXability, data security, and heightened scrutinXXXXhile FCRA typically governs credit reporting, the existence of a major data breach implicates additional legal theories (negligence, invasion of privacy, data security, breach of implied contract, etc.). The fact of the breach also raises the standard by which your verification and recordkeeping practices should be judged. Your admissions and public disclosures provide strong support for claims that your security controls and dispute-handling processes are deficient.\\n\\n2.3 Case law where plaintiffs prevailed (or favorable rulings) against TransUnion / CRAs\\n\\nHere are several relevant decisions you may draw upon or cite:\\n\\t\\tArrizon v. TransUnion, LLC (XXXX XXXX XXXX XXXX Dist., XXXX XXXX XXXX) In this case, the Illinois appellate court considered claims against TransUnion for dissemination of inaccurate information, including a long procedural history from federal to state court. \\XXXX v. TransUnion LLC, XXXX XXXX XXXX) The court held that CRAs must ensure maximum possible accuracy, even for debts that are void under state law, and that a reasonable procedure must catch legal invalidity. XXXX XXXX. TransUnion LLC, XXXX XXXX XXXX XXXX XXXX XXXX held that each class member must satisfy standing and that TransUnions placement of a false terrorist alert and mishandling of disclosures warranted damages. XXXX XXXX v. Ramirez, U.SXXXX XXXX XXXX XXXX While the Supreme Court limited the ability of class members to recover in certain circumstances (holding that only those plaintiffs who suffered concrete harm have Article III standing), the decision reaffirmed the importance of the FCRAs protections and has been heavily discussed in the context of consumer reporting suits. \\n\\t\\tFluker v. Trans Union, XXXX XXXX XXXX XXXX In that pending or decided district court litigation, the plaintiff alleged failure by TransUnion to reinvestigate identity theft disputes and failure to ensure accuracy of credit reports. \\n\\nWhile not all of these are complete victories, they illustrate that courts have recognized consumer rights under FCRA and held CRAs liable in similar contexts.XXXX XXXX XXXX XXXX XXXXBased on the foregoing, I hereby repeat and expand my demands. You must, within XXXX XXXX of your receipt of this letter:\\n\\t1.\\tConduct a fresh, full, reasonable reinvestigation of every disputed item (including those you previously verified) in light of my XXXX XXXX dispute, my documentation, and the inconsistencies across CRAs and your own recordsXXXXroduce to me, in writing, the results of your reinvestigation, including:\\XXXXThe identity (name, address, contact) of each furnisher/creditor from whom you obtained verification.\\n\\t\\tAll documentation or data considered e.g. account contracts, original creditor statements, chain-of-title, payment ledgers, or any other record that demonstrates the accuracy and ownership of the account.\\n\\t\\tA description of the procedures you used in your investigation, including cross-checking among CRAs or internal consistency checksXXXXDelete or permanently suppress from my TransUnion credit file (and cease further reporting) any item for which you cannot provide competent, verifiable documentary support demonstrating that it is accurate, owned by me, or properly attributedXXXXNotify all furnishers of the disputed accounts that the information is disputed, and instruct them to cease reporting or updating the disputed items until the dispute is resolved.XXXXFlag my credit file with an identity theft or data breach alert (fraud alert or victim of data breach notation) to warn anyone reviewing the file of heightened XXXX distribution of my file (or portions thereof) to third parties for account-opening or creditgranting purposes until the dispute is resolved in my favor or you provide full documentatioXXXXPreserve all evidence This includes all related documents, communications, logs, audit trails, internal notes, dispute investigation files, security and forensic reports related to your handling of my file, and all materials relating to the XXXX data breach. You must not destroy or alter any relevant recordsXXXX Demand for Immediate Removal of Unauthorized Hard Inquiries\\n\\nIn addition to the disputed accounts, I hereby formally dispute and demand the immediate removal of all hard inquiries listed on my TransUnion credit report whereXXXXo credit was extended,\\n\\t\\tNo loan, service, or account was ever opened or approvedXXXX did not receive any valuable consideration or benefit from the inquiry, andXXXX XXXXnd/or the reporting creditor have failed to produce any documentation justifying or authorizing such inquiry.\\n\\nLegal Basis:\\n\\nUnder the Fair Credit Reporting Act (15 U.S.C. 1681b), a consumer reporting agency may furnish a consumer report only under specific permissible purposes, such as:\\n\\t\\tIn connection with a credit transaction that is initiated by the consumer (1681b(a)(3)(A)),\\n\\t\\tFor employment purposes with written permission (1681b(a)(3)(B)),\\n\\t\\tOr with the consumers express consent (1681b(c) and (e)).\\n\\nAny inquiry placed without a permissible purpose is a violation of FCRA, and a consumer has the right to demand its immediate deletion.\\n\\nAdditionally, an inquiry without a completed credit transaction or where no consideration was exchanged, constitutes a false representation of consumer-initiated credit activity, which injures the consumers creditworthiness, artificially lowers credit scores, and suggests false activity to potential lenders.\\n\\nIf a creditor or lender made an inquiry, but did not extend credit, did not open an account, and cannot prove that I provided informed, written, or recorded consent to that inquiry, it must be deleted under the FCRAs accuracy and permissible use provisions.\\n\\nSupporting Case Law:\\n\\nIn Pintor v. TransUnion, LLC, XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX the court held that a plaintiff stated a valid FCRA claim where TransUnion failed to remove inquiries that were allegedly made without the consumers knowledge or consent.\\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX the court emphasized that consumer reporting agencies must promptly delete inquiries where the furnisher cannot confirm a permissible purposeXXXXAccordingly, I hereby demand that all hard inquiries that meet any of the following conditions be immediately removed from my TransUnion credit file:\\n\\t\\tThe lender or creditor did not extend credit, issue a loan, approve a service, or otherwise complete a transaction;\\n\\t\\tI received no benefit or consideration (no value exchanged);\\n\\t\\tThere is no signed authorization or proof of permissible purpose;XXXXhe inquiry was not initiated by me or lacks my express written consent.\\n\\nYou must also provide a written explanation ofXXXXhe original source and purpose of each hard inquiry;\\n\\t2.\\tWhether credit was extended or a transaction completed;\\n\\t3.\\tThe date and nature of any signed or recorded authorization you claim to have relied upon.\\n\\nFailure to remove unauthorized hard inquiries will constitute willful noncompliance under 15 U.S.C. 1681n and subject you to statutory and punitive damages.\\n\\n\\nIf you fail to comply, I will proceed with all available legal remedies, including:\\n\\t\\tFiling suit for statutory and actual damages (under 15 U.S.C. 1681n/1681o), injunctive relief, costs and attorneys fees\\n\\t\\tJoining or initiating class action claims\\n\\t\\tComplaints to the CFPB, FTC, state attorneys general, and other regulatory bodies\\n\\t\\tSeeking punitive or exemplary damages (where available) for willful or reckless misconduct\\n\\nI require your written acknowledgment and substantive response within 30 days from receipt of this notice, sent to the address above. Failure to respond or refusal to remove or correct the disputed items will be considered willful noncompliance and will be used as evidence in any future litigation or regulatory action.\\n\\nSincerely,\\n\\nManuel Javier CarrilloXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX accompanies my TransUnion dispute submission regarding inaccurate and unlawfully obtained data linked to the TransUnion data breach. All items listed below are inaccurate, re-aged, misleading, or unauthorized and must be corrected or deleted immediately under the Fair Credit Reporting Act (15 U.S.C. 1681 et seq.), 604, 605B, and 623, as well as 47 U.S. Code 605, which prohibits the unauthorized publication or use of communications or data obtained without proper authorization.\\n\\n\\n\\nI. Verified and Accurate Personal Information\\n\\nField\\tCorrect Information\\tNotes\\nFull XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX. Personal Information to Be Removed\\nCategory\\tInaccurate XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXRemove all\\tNot mine / duplicates\\nEmployers\\tMilayva Roof Co Jamba Juice\\tRemove\\tOutdated or not affiliated\\n\\nIII. Accounts with Inaccurate or Misleading Reporting\\n\\nEach of the following accounts contains data-breach exposure, re-aging, or inconsistent reporting across bureaus, producing false delinquencies, charge-offs, or payment patterns.\\n\\n1. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Pay Status: > Charge-off <\\n\\t\\tInaccuracies: Business account incorrectly tied to personal credit; continuous Date Updated entries (XXXX) suggest unlawful re-aging. Payment-status history changes monthly, which misrepresents true closure.\\n\\t\\tRequested Action: Delete immediately; business accounts are not consumer debts under FCRA.\\n\\n\\n2. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX > Paid, Closed <\\n\\t\\tInaccuracies: Reported 120 days past due despite full payment XXXX XXXX XXXX XXXX misstate closure.\\n\\t\\tRequested Action: Correct to Paid as agreed / Closed Never late or deleteXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX high-balance history altered; inconsistent late-payment pattern across bureaus; taxable charge-off misclassified as open delinquency.\\n\\t\\tRequested Action: Delete or update to Closed XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX differ by CRA; months reported 90 on TransUnion show OK elsewhere. Misleading to lenders.\\n\\t\\tRequested Action: Remove all negative history or delete entire account for data integrityXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXCharge-off)\\n\\t\\tInaccuracies: Successive Charge-off postings monthly through 09/25; indicates re-aging and false open status.\\n\\t\\tRequested Action: Delete entirely; account is a completed charge-off (taxable event).\\n\\n\\n\\n6. XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Status: Charge-off\\n\\t\\tInaccuracies: Re-aged and reported as updated 10/06/25; misleads creditors and violates FCRA 623(a)(5).\\n\\t\\tRequested Action: Delete immediatelyXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX: Listed as joint account despite no joint contract; false placed for collection date XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX: Factoring account falsely assigned; consumer never contracted with XXXX XXXX XXXX XXXX XXXXelete immediatelyXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXs: Duplicate factoring entry; collection status without agreement; repeated updates after closure.\\n\\t\\tRequested Action: Delete in full.\\n\\n\\n\\nIV. Requested Summary of Corrections\\n\\t1.\\tKeep only the accurate personal information in Section I.\\n\\t2.\\tRemove all inaccurate personal and employment data (Section II).\\n\\t3.\\tDelete or correct each erroneous account (Section III).\\n\\t4.\\tProvide written confirmation of all changes within 30 days.\\n\\n\\n\\nV. Unauthorized / Identity-Theft Inquiries\\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX\\tNo permissible purpose; identity-theft suspected.\\tDelete immediately & block future accessXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXUnauthorized soft inquiry; no application.\\tDelete immediately\\XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXermissible purpose; possible breach data use.\\tRemove & block access\\nRXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX no credit application.\\tDelete immediately\\nFXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXUnauthorized access to file; no request made by consumer.\\tRemove\\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX possible identity-theft link.\\tRemove\\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXNo permissible purpose; unauthorized inquiry.\\tDelete immediately\\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX valuable consideration or credit exte\\t\\n\\nSupporting Notes\\n\\t\\tNone of the above inquiries were authorized by me or connected to legitimate credit applications.\\n\\t\\tThese violations fall under FCRA 604(a) (no permissible purpose) and must be blocked per 605B (identity-theft provision).\\n\\t\\tPlease confirm removal and initiate an identity-theft block across the file.'","date_sent_to_company":"2025-11-11T16:01:28.000Z","issue":"Incorrect information on your report","sub_product":"Credit reporting","zip_code":"92807","tags":null,"has_narrative":true,"complaint_id":"17172809","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"TRANSUNION INTERMEDIATE HOLDINGS, INC.","date_received":"2025-11-11T15:39:29.000Z","state":"CA","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Account status incorrect"},"highlight":{"complaint_what_happened":["XXXXhis breach underscores systemic deficiencies in your data security, internal controls, and breach readiness, and calls into question the integrity of your verification and recordkeeping processes.\\n\\t\\tThe public class action lawsuits (e.g. by firms investigating claims) already reference TransUnions failure to safeguard consumer data."]},"sort":[9.810596,"17172809"]},{"_index":"complaint-public-v1","_id":"6583808","_score":9.15831,"_source":{"product":"Credit reporting, credit repair services, or other personal consumer reports","complaint_what_happened":"Metro 2 / e-OSCAR Compliance Deficiencies and FCRA willful violations - XXXX Bank credit card XXXX inaccurately reported in Metro 2 as old card XXXX \n- [ ] Despite my clear disputes for willful FCRA violations, XXXX and every CRA are NOT Metro 2 Compliant which should have forced and requested e-OSCAR to verify whether every item and every required field is filled in accurately, mandatorily and logically 100% perfect to meet compliance standards, as set forth in the 355 page Credit Reporting Resource Guide to meet ALL of the requirements of the FCRA, FCBA, and ECOA to insure maximum accurate and complete information on my credit history. My paper credit reports of Experian, XXXX XXXX XXXX of XXXX showed that I never missed a payment to any creditor. However, supplemental and additional data omitted illegally from my paper credit report but included in Metro 2 files in XXXX XXXX showed that I had been 60 days past due with a 100% perfect which is not only illogical but impossible as I have always had a perfect payment record on every account. Numerous credit scoring and credit data analysis firms such as XXXX XXXX access Metro 2 credit data to report scores and account changes and payment records. Metro 2 coding errors and data concealed from paper credit reports prevents errors from being known and corrected by consumers in willful violation of the FCRA. Metro 2 is available to lenders who use information concealed from consumers which most likely contains inaccurate data such as late payments. My credit score was 200+ points below what it should have been due to the concealed and inaccurate 60 day late payment inside Metro 2 and concealed from my paper reports. I have complained to every CRA and the improper verification responses have been to ask me what data is incorrect instead of researching my Metro 2 data to tell me what data is in Metro 2 that is concealed from my paper credit reports. Consumers are scammed by Metro 2 inaccurate data concealed from paper reports resulting in a systematic inappropriate reporting system in substantial and known violation of laws including the FCRA. In fact, the whole Metro 2 system is useless since it contains data visible to others but concealed from consumers. How can a consumer check data for accuracy on paper credit reports when a complete set of conflicting and additional supplemental data is available inside Metro 2 yet undiscoverable, concealed and Unknown to innocent unsuspecting consumers??? Metro 2 even scams sophisticated consumers who frequently check paper credit reports fir accuracy. Therefore, my XXXX Closed account plus all my closed accounts must be permanently deleted from every CRA unless and until an independent unbiased capable entity certifies that all Metro 2 data is 100% accurately coded and properly incorporated in my paper data credit reports so that Metro 2 data is 100% identical to my paper reports. I maintain that Metro 2 data will always contain data not available and not visible on paper credit reports in willful violation of the FCRA. Therefore, my XXXX and every CRA must promptly permanently delete my XXXX and other closed accounts and, in the interim until deletion, report accounts as disputed by consumer, closed by consumer, consumer affected by a natural or declared disaster, payment deferred, affected by COVID-19, etc for which Metro 2 does not even have the fields and capability to accurately insure such required items are reported completely, consistently, logically and accurately monthly without the possibility of change through updates causing improper removal of codes and code replacements. XXXX does not understand this and it is incompetent and incapable of complying with the FCRA and Metro 2 mandatory coding as will be shown herein. This matter is ripe for investigation by the CFPB and Florida AG who has an injunction against XXXX for deceptive, unfair and unlawful trade practices. I need from XXXX every Metro 2 data submission since XXXX with a manual reconciliation to explain each and every paper entry in my credit report for every item and field. I need the Metro 2 transcribed to what is actually in its system as I know the codes (such as XA, XB, XC, XD, XE, XFetc) and I know what the codes mean but I do not know exactly what code has been reported since coding may be illogically, subjective, improper, temporary and changing with erroneous and inconsistent coding. My credit reports change multiple time daily with codes removed, replaced, removed, replaced, removed, etc erroneously and inaccurately in willful violations of the FCRA. Once my account is closed it must remain as closed but a furnisher subsequently reporting a closed account as disputed usually will remove the closed account code in violation of the FCRA and replace it with a dispute code instead of keeping both the closed and disputed designation. Garbage in means garbage out. Metro 2 gets complicated in my case when I have a XXXX acct with a wrong account number which is closed, disputed, affected by a natural or declared disaster, payment deferred, paid from insurance, failed to be reported monthly, etc where the Metro 2 codes cannot properly report the mandatory obligated FCRA requirements. Moreover, XXXX has shown that it is incapable of understanding Metro 2 and is unqualified and unwilling to report accurate credit data. The integrity and reportability of my XXXX and other closed accounts is called into question as mandatory data fields are missing, contested and cannot be verified and certified as perfectly compliant, mandating deletion entirely. Not only are numerous required fields in segments missing entirely, but many fields are inaccurate, and more importantly, Furnishers do not understand how to accurately code the complex mandatory compliance codes. XXXX does not even know what a closed account is under Metro 2 so it inaccurately reported my account that I closed in XXXX XXXX as open and refuses to mark my account as closed as required by the FCRA and Metro 2. XXXX claims that it closed my account to purchases when I closed my account but it will never mark my account on my credit report as Closed unless and until I pay my balance in full. All XXXX has to do is read Metro 2 to see that an account is closed by a consumer when requested even if there is a balance. Metro 2 and the FCRA clearly requires marking my account as closed promptly after my admitted closure in XXXX. If XXXX does not understand Metro 2 and the FCRA and its obligations and prohibitions how can XXXX be permitted to continue to report under Metro 2??? It is almost 2 months and XXXX has failed to mark my account as closed, disputed, affected by natural or declared disaster on a monthly basis? My closed XXXX account is still willfully inaccurate as it is still reported as OPEN on XXXX on my 3 credit reports, As of XXXX, XXXX last reported my account to XXXX on XXXX in willful violation of the Metro 2 requirement to report monthly. CRAs know Metro 2 requires monthly reporting. CRAs have the responsibility to delete my account before XXXX responds. XXXX does not even know how to report account numbers accurately in Metro 2 as my account number continues to be reported as XXXX even though my account number was changed to XXXX about 3 years ago. Metro 2 is too complicated for XXXX to use and it is obvious that it does not understand how to change account numbers or it just shortcuts its obligations and refuses to accurately report my account accurately. Simply stated, XXXX is not Metro 2 compliant as it does not understand the system and the 355 page guidelines requiring proper coding for fields for Closed, Disputed, inaccurate data and account numbers and accounts affected by COVID and natural and declared disasters, all of which are missing from my XXXX file for months. XXXX has failed to monthly report my account since it last reported to XXXX on XXXX as of XXXX. Clearly, XXXX is not Metro 2 compliant mandating deletion. XXXX does not have the ability or desire to accurately report. Metro 2 field 17A must include DA immediately to prevent irreparable harm and to avoid further willful FCRA violations with punitive damages exceeding XXXX based on 11th circuit USCA decisions for jury awards of XXXX for a single failure to report the account as disputed. XXXX is a recalcitrant lender who does not know the law and refuses to follow its known obligations. XXXX should attempt to mitigate damages instead of alienating me and increasing its obligation to pay me significant damages. I claim past statutory and other damages to offset the frivolous and uncollectable disputed balance which I claim is XXXX, mandating dismissal and deletion of my XXXX account permanently. I demand XXXX and every CRA disclose every Metro 2 coded field since XXXX to ascertain what is actually exactly reported and at the same time asking them to manually reconcile paper conflicts. I do not understand why XXXX refuses to immediately mark my account as Closed, disputed, deferred, affected by COVID and a natural disaster, etc. What is its sinister goal???? A Metro 2 Compliance request triggers e-OSCAR to electronically evaluate whether every piece of data was mandatorily perfect and complete Metro 2 Formatted Reporting Standards was properly reported within the compliance standards set forth by the FCRA. CDIA definitions that go along with Metro 2 Language are either unknown, not read, not considered, or just purposely evaded by XXXX or purposely violated due to incompetence or willful disregard. Obviously, a systematic problem exists at XXXX affecting its similarly situated cardholders. Closed accounts at XXXX are never reported as closed in willful violation of the FCRA. I demand that XXXX immediately stop reporting my account as OPEN. My account is closed since XXXX and such date closed is required to be permanently entered into Metro 2. XXXX is not Metro 2 Compliant mandating permanent deletion of my account from every CRA. Compliance Condition Codes are used to reflect accounts Closed at Consumers Request AND Accounts Disputed By Consumer to comply with mandatory reporting under the FCRA, FCBA and FDCPA. XXXX does not even know the Definition of a closed account is and what a dispute is and it has not put any of the multiple mandatory codes into Metro 2 in complete and willful violation of the FCRA and other laws, both State and Federal. XXXX knows that my account is Closed and disputed yet it knowingly refuses to enter any Compliance Condition Codes in willful violation of the FCRA. Simply stated, no code means XXXX is not Metro 2 Compliant mandating permanent deletion of my account from every CRA. My XXXX and Experian reports are not reported monthly as required under Metro 2. (See Attached Experian reports of XXXX and XXXX showing XXXX as last reported date). Rather than promptly reporting my account as CLOSED on XXXX as required with a simple update, XXXX completely stopped reporting since XXXX in violation of Metro 2. Apparently, XXXX does not know how to enter mid cycle updates or it is just incapable of monthly reporting and mandatory prompt and immediate mid-cycle updates required by Metro 2 to comply with the FCRA. My attached XXXX report of XXXX shows inaccurately shows my XXXX account number as XXXX instead of XXXX. an inaccurate variable/adjustable rate, an inaccurate date of last payment, missing data for XXXX XXXX etc,, inaccurate date of last activity, missing deferral date, missing date closed, missing Closed account status, missing dispute code and other FCRA compliance codes. Despite my disputes, XXXX has failed to promptly and immediately update inaccurate disputed information to CRAs apparently willfully or because it does not understand how to update with Metro 2 / e-OSCAR protocols. Reporting inaccuracies must be corrected promptly in order to comply with the FCRA. See section 623(a)(2)(B). The e-OSCAR Consumer Dispute System is designed and required to have built-in edits and safeguards to prevent illogical responses and impossible entries such as deletion of a closed account status resulting in a closed account inaccurately reported as open. Similarly, once a consumer is marked as deceased, Metro 2 must prevent the person to be reported as alive by not permitting illogical coding entries. Replacing a required field with a blank field or zero to force Metro 2 to accept data for updates and submission must not be tolerated. The CFPB website, like most websites, prevents submission until all required fields are marked and entered. Metro 2 has no such controls so it allows submission of blank and inconsistent data without any effective checks and controls or allows furnished to evade requirements. The numerous blank data fields demonstrate that XXXX cannot and has not complied with Metro 2 standards and any one of the multiple blank required fields is grounds, standing alone, to delete my entire account for Metro 2 Compliance deficiencies and FCRA violations. Every Metro 2 field has a purpose and no field must be blank under any scenario. The entire Metro 2 Compliance safeguards are nonexistent. Information within a dispute response must be complete and logical to insure maximum possible accuracy pursuant to well settled law. There are multiple coding duplicate safeguards to insure Metro 2 compliance. For example not only does Metro 2 require a permanent Compliance Code for a closed account to comply with the FCRA but Metro 2 requires the entry of the actual DATE CLOSED so the closed status must be reported in 2 fields to prevent coding evasion. Purposely entering blank required fields to force Metro 2 to update a submission constitutes a willful and deliberate violation of the FCRA and Metro 2 intended protocols. The incomplete, delayed and inaccurate XXXX reporting, with missing mandatory and required Metro 2 fields, should have required e-OSCAR to delete my account due to multiple Metro 2 Compliance deficiencies. XXXX should have been notified by CRAs of its reporting deficiencies or otherwise blocked from reporting entirely. XXXX has been negligent by failing to update its internal controls and record keeping to avoid and prevent re-reporting incorrect and illogical information. XXXX Frequently Asked Questions and Answer, Question 64, discusses How should a replacement credit card be reported. XXXX either does not have competent staff to understand Metro 2 or it just refuses to comply to save money. In my case, my old acct # XXXX was required to be updated with the new account number of XXXX (changed about 3 years ago) so XXXX is NOT 100% Metro 2 Compliant mandating deletion. Exact account number reporting is mandatory for many reasons including an internal control to prevent duplicate reporting of accounts especially when accounts are sold or transferred to others. I have made multiple disputes but not only has XXXX noticed yet failed to fix the obvious account number inaccurate account number but not one CRA has noticed the error nor forced Metro 2 updating of the correct account number as required to be Metro 2 compliant. My Experian paper report conceals the last 4 digits of my XXXX account number so I could not discover the inaccurate account numbers and inaccurate reporting in willful violation of the FCRA. On the other hand, XXXX just reports just the last 4 numbers of XXXX account on my paper so that the complete account number is discoverable to scammers by merely looking at 2 separate credit reports. The FCRA and Metro 2 require the complete account number into Metro 2 and paper credit reports to insure accuracy and prevent duplication. The ineffective procedure of partially blocking 4 or more account numbers on paper reports is counterproductive, achieves no valuable benefit or protection and deprives consumers of the right to determine accuracy especially if accounts are transferred. Since there is XXXX liability for credit fraud to consumers, complete account numbers must be reported on every CRA pursuant to the FCRA especially on Closed accounts, such as XXXX, which should be blocked. The partially blocking of account numbers has protections for furnishers and no benefits for consumers, so every account on my credit report is inaccurate and not Metro 2 Compliant mandating deletion of every account including my XXXX account. XXXX answer to Question 58 required XXXX to Report my account as deferred along with Special Comment AW (Affected by Natural or Declared Disaster) and other coding mandatory field entries negligently or intentional omitted in violation of the FCRA. As XXXX knows I live in XXXX and I told it many times that I took a direct hit from Hurricane Ian in XXXX XXXX and I have been seriously affected by the FEMA declared natural disaster, not only has XXXX willfully violated its specific obligation under the FCRA to report on my credit report Affected By Natural or Declared Disaster, Compliance code AW, but it claims I am late despite the prohibition of late reporting due to Hurricane Ian. Again, XXXX is apparently deliberately negligent or untrained in meeting its mandatory obligations under Metro 2 contained in the 355 page Guide or it has maliciously and purposely violated the FCRA to hopefully induce me to pay disputed account charges thereby entitling me to XXXX+ in statutory and punitive damages so my claims exceed the smaller XXXX disputed claim. XXXX and every CRA must enter account status code DA in field 17A to avoid and mitigate damages. How about the mandatory Date of First Delinquency that furnishers and CRAs never report accurately. It is about time XXXX sends its employees Back to School to learn about its obligations to insure maximum possible accuracy coding required under Metro 2/e-OSCAR/FCRA/FCBA/etc. Garbage IN means Garbage OUT. Worst yet is leaving mandatory required fields BLANK in complete disregard for the requirements of Metro 2 and the FCRA. Exhibit 8 of the XXXX regarding Compliance Condition Codes, which is reported in Field 20 of the Base Segment, is used to reflect accounts Closed at Consumers Request, and, inter Alia, consumer disputes under the FCBA, FDCPA and FCRA. Numerous Condition Codes exist (XA, XB, XC, XD, XE, XF, XI, XH, XJ etc) exist mandating reporting Accounts Closed at Consumers Request with the DEFINITION: Reported when a consumer requested an account be CLOSED with an Important Note: Report the DATE CLOSED as the date the account was CLOSED TO FURTHER PURCHASES which XXXX acknowledges was in XXXX XXXX. Field Definitions in Metro 2 for #26 state: Date Closed the date the account was closed to further purchases there may be a BALANCE DUE. I need to repeat again and again what the FCRA and Metro 2 require in the 355 page guide. Definition: Reported when a consumer requested an account be closed with an Important Note: Report the Date Closed as the Date the account was closed to further purchaseswhich XXXX letter acknowledges was in XXXX. Again, Field Definitions for #26 Date Closedthe date the account was closed to further purchasesthere may be a balance due. There can be absolutely no doubt that XXXX has no idea of what a Closed account is and what the FCRA, case law, and the 355 page Metro 2 guide defines. Or worse it has lied, lied, lied to federal investigators and its own superiors mandating disciplinary action against employees conspiring to violate the FCRA. XXXX top management needs to take disciplinary action against its staff for unconscionable conduct. XXXX frivolous and illegal position that it will never report my account as closed unless and until I pay the entire balance in full is absolutely ridiculous and in willful and malicious disregard for the FCRA mandating maximum possible Statutory and Punitive damages plus Attorney Fees exceeding XXXX. Does XXXX want a US District Court jury to punish it if it is wrong? Does XXXX want to spend XXXX in legal fees and related expenses only to lose? Does XXXX want a US District Court to ask a US Magistrate Judge to issue a Report of Findings of Fact and Conclusions of Law to be reviewed by the US District Court Judge for judgment and Rule 11 sanctions? Does XXXX want the CFPB and the Florida AG to prosecute it? Does XXXX employees want to risk losing their jobs for knowingly, deliberately, maliciously, negligently and purposely violating the FCRA in bad faith? Is there criminal conduct under multiple federal statutes for lying to federal authorities? XXXX top management and below have no idea what the FCRA and Metro 2 straight forward Definitions are for a closed account or worst it knows my account is closed yet it continues to illegally report my account as Open for a sinister purpose. XXXX knows that my account was closed yet it refuses to report my account as Closed in willful violation of the FCRA, Metro 2 etc even though it acknowledges my phone call demand to close my account in XXXX resulting in not only a closure, by definition, but XXXX blocking my account from further purchases thereby meeting the Metro 2 definition of a Closed account. XXXX falsely claims that my account will NEVER be reported as closed until my entire balance is paid in full. I closed my account in XXXX but XXXX refuses to report my account as closed and just willfully violated the FCRA and Metro 2 by reporting my account as OPEN. XXXX had systematically, maliciously, deliberately and willfully violated the FCRA and Metro 2 resulting in inaccurate and incomplete reporting of data including blank data and codes in data fields in Metro 2 that XXXX and CRAs refuse to adequately investigate. Once I called XXXX by phone and demanded it close my account and XXXX at that time processed my closure request telling me my account was now closed telling me the account was blocked from further purchasers so I needed to advise merchants not to use my closed account further, XXXX was required to PROMPTLY in a matter of a few days or minutes (not months) report my Account As Closed By Consumer forever keeping it Closed with every CRA never to be changed or deleted. Reporting an account as closed should be an instantaneous and automatic credit reporting process as it happens so frequently. XXXX blocked my account from further purchasers and read me the disclosure statement on its recorded line that my account was closed which I demand a certified copy of such transcript herein as additional proof of XXXX wrongdoing. This is certainly a learning lesson for XXXX so its staff may understand and comply with its obligations under the FCRA and Metro 2. Treating Consumers as stupid with disrespect is a terrible way to respond to bona fide complaints and disputes., especially when CFPB complaints can be viewed online for the public to read. Does XXXX really want to risk multi jurisdictional civil and criminal litigation over the Definition of a Closed Account? The Definition of what a Closed account under the FCRA and Metro 2 is absolutely clear and its repeated definitions cannot be challenged under any scenario. Your Law firms will risk damaging their reputation and licenses by claiming my Closed XXXX account is still Open when faced with a Rule 11 motion and action for sanctions for frivolous conduct. What is wrong with XXXX? Is your XXXX parent telling you to lie to federal authorities? Are your executives stupid? Do you think the CFPB is stupid? Do you think a jury and US District Court Judges are stupid? Well, I am obviously NOT stupid and it is obvious that I am furious about the entire credit reporting system and its lack of controls. The CFPB knows and has acknowledged unacceptable systematic FCRA violations. I just cant believe XXXX insists on reporting my Closed account as Open. Keep being STUPID and XXXX will pay bigger and bigger serious consequences. Customers must be treated with respect not treated as Stupid by untrained inexperienced or stupid employees who do not act in the banks best interest. When I filed my complaint with the CFPB, you should have taken the complaint seriously and tried everything to satisfy me by even giving me more than I asked for instead of being stupid. XXXX should have reduced my interest to 0% and just offer to pay me a XXXX statutory damage amount while not admitting or denying wrongdoing. Moreover, XXXX should have offered to permanently delete my account from every CRA as that would cost XXXX. But XXXX is not only stubborn but a stupid recalcitrant lender who would never offer a XXXX concession but would prefer to spend millions rather than make needed token concessions. Businesses pay huge sums to answer customer service phone calls and concessions are the cheapest and most effective way to satisfy and retain customers. But obviously, XXXX has alienated me (and others similarly situated) by treating me as stupid even after filing a CFPB complaint. What would XXXX XXXX Parent in XXXX say when matters get out of Control and no one wants to acquire you? I could continue for 20 more pages quoting the FCRA, Metro 2 Guidelines, statutory intent, criminal federal statutes, CFPB policies, Case law etc but XXXX is required to know all that and have its Staff trained and knowledgeable. This Complaint will certainly assist XXXX staff in understanding its obligations under the FCRA and Metro 2. I am entitled to relief as a consultant would charge huge amounts for what I have told you about your deficiencies. Once my account was closed, XXXX was prohibited to report my account with a variable interest rate so again XXXX coding with a variable rate is inaccurate which everyone missed after closure. XXXX needs to send its staff and upper management Back To School to Metro 2 workshops, e-learning courses and seminars. The industry Reporting Standards of Metro 2 to insure integrity and consistency of credit information requires: All Accounts must be reported a minimum of once per month. Prompt immediate and button-pushing automatic mid cycle updates are required especially for Closed, Disputed and accounts Affected by Natural or Declared Disaster. XXXX has failed to meet these and other Metro 2 obligations because as of XXXX, my last XXXX update to XXXX and Experian was XXXX per the attached. Pursuant to section 1682 et seq of the FCRA, XXXX and every CRA may be liable for willfully and negligently failing to follow reasonable procedures to assure maximum possible accuracy. XXXX is out of control. XXXX numerous deliberate deficiencies of illegally withholding and inaccurately concealing and reporting false and missing required account data is purposely intended to negatively affect a consumer credit score in complete willful violation of the FCRA. XXXX has escalated my complaint issues to a high level executive department so there is no defense or excuse of new or inexperienced employees or other type of employee error or negligence as my dispute issue responses are purportedly prepared and investigated by senior level experience staff and reviewed by higher level experienced staff. While Rule 11 sanction requests for frivolous conduct in federal courts permit violators to escape sanctions due to a 30 day safe harbor, willful violations of the FCRA cannot escape statutory and punitive damages. Some attorneys prefer to immediately file FCRA lawsuits upon discovery of violations. My efforts are intended to provide repeated notice of XXXX illegal conduct so that FCRA violations can be corrected to mitigate damages. If XXXX willfully continues to violate the FCRA despite numerous warnings, higher punitive damages will be incurred. I believe that XXXX will never admit FCRA violations due to its internal policies for dealing with FCRA violation complaints. So despite my indisputable detail of widespread and systematic illegal conduct known to be illegal, I expect XXXX will continue to willfully violate the FCRA rather than just delete my account permanently from every CRA. CFPB Director XXXX XXXX recently said around XXXX XXXX XXXX: XXXX is an out/of-control repeat offender that believes it is above the law. I am concerned that XXXX leadership is either unwilling or incapable of operating its businesses lawfully. My XXXX issues similarly prove that XXXX is an out-of-control repeat offender that refuses to comply with the FCRA and is incapable of understanding and implementing Metro 2 and the most basic FCRA provisions for reporting closed, disputed, affected by natural or declared disaster accounts and data. On XXXX XXXX XXXX Florida Attorney General XXXX XXXX announced a settlement agreement with 34 attorneys generals and XXXX that included about XXXX XXXX in relief nationally including future injunctive relief requiring that XXXX shall maintain policies and procedures with respect to deferments, forbearances, modifications, and other related servicing and collection matters, and ensure that these policies and procedures are followed by its employees. I maintain that the violations of the FCRA by XXXX and its refusal to mark my offered payment deferrals due to Hurricane Ian on my credit reports constitute violations of it injunction which I will address counsel for the Florida AG. The AG injunction also stated: XXXX shall comply with the Florida Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes. Obviously, XXXX willful and malicious violations of the FCRA clearly constitute grave violations of Floridas Deceptive and Unfair Trade Practices also enjoined by the injunction relief agreed to by XXXX. XXXX is just out of control and incapable of complying with its obligations. Metro 2 and the FCRA is just too complicated for XXXX to administer as required mandating permanent deletion of my disputed and closed account from my credit report. XXXX retaliated against me for seeking deferrals offered and accepted automatically and required due to Hurricane Ian resulting in unacceptable FCRA violations and a complete disregard for requirements of Metro 2. I insist on 100% compliance with the requirements of Metro 2 and the FCRA to prevent the inaccuracies and incomplete credit reporting. Moreover, I demand a copy of every XXXX Metro 2 code filed so that I can compare codes submitted versus paper reports received. My credit file is the Metro 2 codes which is inconsistent and quite different from my paper credit reports as the Metro 2 files contain data that is not on my paper reports. Failure to provide me with past Metro 2 filings shall constitute the same FCRA violation as failing to provide an English paper credit report or electronic copy of my credit report. Keep in mind that an analysis of my Metro 2 codes show that I was in the past 60 days late which is impossible as my paper reports showed that I was never late to any creditor. The Metro 2 coding is so complicated that inaccurate negative and derogatory data will always exist in Metro 2 which is not shown on a paper report to a consumer. Metro 2 must be exactly the same as a XXXX","date_sent_to_company":"2023-02-17T10:42:31.000Z","issue":"Incorrect information on your report","sub_product":"Credit reporting","zip_code":"32836","tags":"Older American","has_narrative":true,"complaint_id":"6583808","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"Experian Information Solutions Inc.","date_received":"2023-02-17T10:42:19.000Z","state":"FL","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Account status incorrect"},"highlight":{"complaint_what_happened":["The integrity and reportability of my XXXX and other closed accounts is called into question as mandatory data fields are missing, contested and cannot be verified and certified as perfectly compliant, mandating deletion entirely. Not only are numerous required fields in segments missing entirely, but many fields are inaccurate, and more importantly, Furnishers do not understand how to accurately code the complex mandatory compliance codes."]},"sort":[9.15831,"6583808"]},{"_index":"complaint-public-v1","_id":"6583809","_score":9.137791,"_source":{"product":"Credit reporting, credit repair services, or other personal consumer reports","complaint_what_happened":"Metro 2 / e-OSCAR Compliance Deficiencies and FCRA willful violations - XXXX Bank credit card XXXX inaccurately reported in Metro 2 as old card XXXX\n\n- [ ] Despite my clear disputes for willful FCRA violations, XXXX and every CRA are NOT Metro 2 Compliant which should have forced and requested e-OSCAR to verify whether every item and every required field is filled in accurately, mandatorily and logically 100% perfect to meet compliance standards, as set forth in the 355 page Credit Reporting Resource Guide to meet ALL of the requirements of the FCRA, FCBA, and ECOA to insure maximum accurate and complete information on my credit history. My paper credit reports of XXXX XXXX XXXX TransUnion of XXXX showed that I never missed a payment to any creditor. However, supplemental and additional data omitted illegally from my paper credit report but included in Metro 2 files in XXXX XXXX showed that I had been 60 days past due with a 100% perfect which is not only illogical but impossible as I have always had a perfect payment record on every account. Numerous credit scoring and credit data analysis firms such as XXXX XXXX access Metro 2 credit data to report scores and account changes and payment records. Metro 2 coding errors and data concealed from paper credit reports prevents errors from being known and corrected by consumers in willful violation of the FCRA. Metro 2 is available to lenders who use information concealed from consumers which most likely contains inaccurate data such as late payments. My credit score was 200+ points below what it should have been due to the concealed and inaccurate 60 day late payment inside Metro 2 and concealed from my paper reports. I have complained to every CRA and the improper verification responses have been to ask me what data is incorrect instead of researching my Metro 2 data to tell me what data is in Metro 2 that is concealed from my paper credit reports. Consumers are scammed by Metro 2 inaccurate data concealed from paper reports resulting in a systematic inappropriate reporting system in substantial and known violation of laws including the FCRA. In fact, the whole Metro 2 system is useless since it contains data visible to others but concealed from consumers. How can a consumer check data for accuracy on paper credit reports when a complete set of conflicting and additional supplemental data is available inside Metro 2 yet undiscoverable, concealed and Unknown to innocent unsuspecting consumers??? Metro 2 even scams sophisticated consumers who frequently check paper credit reports fir accuracy. Therefore, my XXXX Closed account plus all my closed accounts must be permanently deleted from every CRA unless and until an independent unbiased capable entity certifies that all Metro 2 data is 100% accurately coded and properly incorporated in my paper data credit reports so that Metro 2 data is 100% identical to my paper reports. I maintain that Metro 2 data will always contain data not available and not visible on paper credit reports in willful violation of the FCRA. Therefore, my XXXX and every CRA must promptly permanently delete my XXXX and other closed accounts and, in the interim until deletion, report accounts as disputed by consumer, closed by consumer, consumer affected by a natural or declared disaster, payment deferred, affected by COVID-19, etc for which Metro 2 does not even have the fields and capability to accurately insure such required items are reported completely, consistently, logically and accurately monthly without the possibility of change through updates causing improper removal of codes and code replacements. XXXX does not understand this and it is incompetent and incapable of complying with the FCRA and Metro 2 mandatory coding as will be shown herein. This matter is ripe for investigation by the CFPB and Florida AG who has an injunction against XXXX for deceptive, unfair and unlawful trade practices. I need from XXXX every Metro 2 data submission since XXXX with a manual reconciliation to explain each and every paper entry in my credit report for every item and field. I need the Metro 2 transcribed to what is actually in its system as I know the codes (such as XA, XB, XC, XD, XE, XFetc) and I know what the codes mean but I do not know exactly what code has been reported since coding may be illogically, subjective, improper, temporary and changing with erroneous and inconsistent coding. My credit reports change multiple time daily with codes removed, replaced, removed, replaced, removed, etc erroneously and inaccurately in willful violations of the FCRA. Once my account is closed it must remain as closed but a furnisher subsequently reporting a closed account as disputed usually will remove the closed account code in violation of the FCRA and replace it with a dispute code instead of keeping both the closed and disputed designation. Garbage in means garbage out. Metro 2 gets complicated in my case when I have a XXXX acct with a wrong account number which is closed, disputed, affected by a natural or declared disaster, payment deferred, paid from insurance, failed to be reported monthly, etc where the Metro 2 codes cannot properly report the mandatory obligated FCRA requirements. Moreover, XXXX has shown that it is incapable of understanding Metro 2 and is unqualified and unwilling to report accurate credit data. The integrity and reportability of my XXXX and other closed accounts is called into question as mandatory data fields are missing, contested and cannot be verified and certified as perfectly compliant, mandating deletion entirely. Not only are numerous required fields in segments missing entirely, but many fields are inaccurate, and more importantly, Furnishers do not understand how to accurately code the complex mandatory compliance codes. XXXX does not even know what a closed account is under Metro 2 so it inaccurately reported my account that I closed in XXXX XXXX as open and refuses to mark my account as closed as required by the FCRA and Metro 2. XXXX claims that it closed my account to purchases when I closed my account but it will never mark my account on my credit report as Closed unless and until I pay my balance in full. All XXXX has to do is read Metro 2 to see that an account is closed by a consumer when requested even if there is a balance. Metro 2 and the FCRA clearly requires marking my account as closed promptly after my admitted closure in XXXX. If XXXX does not understand Metro 2 and the FCRA and its obligations and prohibitions how can XXXX be permitted to continue to report under Metro 2??? It is almost 2 months and XXXX has failed to mark my account as closed, disputed, affected by natural or declared disaster on a monthly basis? My closed XXXX account is still willfully inaccurate as it is still reported as OPEN on XXXX on my 3 credit reports, As of XXXX, XXXX last reported my account to TransUnion on XXXX in willful violation of the Metro 2 requirement to report monthly. CRAs know Metro 2 requires monthly reporting. CRAs have the responsibility to delete my account before XXXX responds. XXXX does not even know how to report account numbers accurately in Metro 2 as my account number continues to be reported as XXXX even though my account number was changed to XXXX about 3 years ago. Metro 2 is too complicated for XXXX to use and it is obvious that it does not understand how to change account numbers or it just shortcuts its obligations and refuses to accurately report my account accurately. Simply stated, XXXX is not Metro 2 compliant as it does not understand the system and the 355 page guidelines requiring proper coding for fields for Closed, Disputed, inaccurate data and account numbers and accounts affected by COVID and natural and declared disasters, all of which are missing from my XXXX file for months. XXXX has failed to monthly report my account since it last reported to TransUnion on XXXX as of XXXX. Clearly, XXXX is not Metro 2 compliant mandating deletion. XXXX does not have the ability or desire to accurately report. Metro 2 field 17A must include DA immediately to prevent irreparable harm and to avoid further willful FCRA violations with punitive damages exceeding $100,000 based on 11th circuit USCA decisions for jury awards of $80,000 for a single failure to report the account as disputed. XXXX is a recalcitrant lender who does not know the law and refuses to follow its known obligations. XXXX should attempt to mitigate damages instead of alienating me and increasing its obligation to pay me significant damages. I claim past statutory and other damages to offset the frivolous and uncollectable disputed balance which I claim is XXXX, mandating dismissal and deletion of my XXXX account permanently. I demand XXXX and every CRA disclose every Metro 2 coded field since XXXX to ascertain what is actually exactly reported and at the same time asking them to manually reconcile paper conflicts. I do not understand why XXXX refuses to immediately mark my account as Closed, disputed, deferred, affected by COVID and a natural disaster, etc. What is its sinister goal???? A Metro 2 Compliance request triggers e-OSCAR to electronically evaluate whether every piece of data was mandatorily perfect and complete Metro 2 Formatted Reporting Standards was properly reported within the compliance standards set forth by the FCRA. CDIA definitions that go along with Metro 2 Language are either unknown, not read, not considered, or just purposely evaded by XXXX or purposely violated due to incompetence or willful disregard. Obviously, a systematic problem exists at XXXX affecting its similarly situated cardholders. Closed accounts at XXXX are never reported as closed in willful violation of the FCRA. I demand that XXXX immediately stop reporting my account as OPEN. My account is closed since XXXX and such date closed is required to be permanently entered into Metro 2. XXXX is not Metro 2 Compliant mandating permanent deletion of my account from every CRA. Compliance Condition Codes are used to reflect accounts Closed at Consumers Request AND Accounts Disputed By Consumer to comply with mandatory reporting under the FCRA, FCBA and FDCPA. XXXX does not even know the Definition of a closed account is and what a dispute is and it has not put any of the multiple mandatory codes into Metro 2 in complete and willful violation of the FCRA and other laws, both State and Federal. XXXX knows that my account is Closed and disputed yet it knowingly refuses to enter any Compliance Condition Codes in willful violation of the FCRA. Simply stated, no code means XXXX is not Metro 2 Compliant mandating permanent deletion of my account from every CRA. My TransUnion and XXXX reports are not reported monthly as required under Metro 2. (See Attached XXXX reports of XXXX and XXXX showing XXXX as last reported date). Rather than promptly reporting my account as CLOSED on XXXX as required with a simple update, XXXX completely stopped reporting since XXXX in violation of Metro 2. Apparently, XXXX does not know how to enter mid cycle updates or it is just incapable of monthly reporting and mandatory prompt and immediate mid-cycle updates required by Metro 2 to comply with the FCRA. My attached XXXX report of XXXX shows inaccurately shows my XXXX account number as XXXX instead of XXXX. an inaccurate variable/adjustable rate, an inaccurate date of last payment, missing data for XXXX, XXXX etc,, inaccurate date of last activity, missing deferral date, missing date closed, missing Closed account status, missing dispute code and other FCRA compliance codes. Despite my disputes, XXXX has failed to promptly and immediately update inaccurate disputed information to CRAs apparently willfully or because it does not understand how to update with Metro 2 / e-OSCAR protocols. Reporting inaccuracies must be corrected promptly in order to comply with the FCRA. See section 623(a)(2)(B). The e-OSCAR Consumer Dispute System is designed and required to have built-in edits and safeguards to prevent illogical responses and impossible entries such as deletion of a closed account status resulting in a closed account inaccurately reported as open. Similarly, once a consumer is marked as deceased, Metro 2 must prevent the person to be reported as alive by not permitting illogical coding entries. Replacing a required field with a blank field or zero to force Metro 2 to accept data for updates and submission must not be tolerated. The CFPB website, like most websites, prevents submission until all required fields are marked and entered. Metro 2 has no such controls so it allows submission of blank and inconsistent data without any effective checks and controls or allows furnished to evade requirements. The numerous blank data fields demonstrate that XXXX cannot and has not complied with Metro 2 standards and any one of the multiple blank required fields is grounds, standing alone, to delete my entire account for Metro 2 Compliance deficiencies and FCRA violations. Every Metro 2 field has a purpose and no field must be blank under any scenario. The entire Metro 2 Compliance safeguards are nonexistent. Information within a dispute response must be complete and logical to insure maximum possible accuracy pursuant to well settled law. There are multiple coding duplicate safeguards to insure Metro 2 compliance. For example not only does Metro 2 require a permanent Compliance Code for a closed account to comply with the FCRA but Metro 2 requires the entry of the actual DATE CLOSED so the closed status must be reported in 2 fields to prevent coding evasion. Purposely entering blank required fields to force Metro 2 to update a submission constitutes a willful and deliberate violation of the FCRA and Metro 2 intended protocols. The incomplete, delayed and inaccurate XXXX reporting, with missing mandatory and required Metro 2 fields, should have required e-OSCAR to delete my account due to multiple Metro 2 Compliance deficiencies. XXXX should have been notified by CRAs of its reporting deficiencies or otherwise blocked from reporting entirely. XXXX has been negligent by failing to update its internal controls and record keeping to avoid and prevent re-reporting incorrect and illogical information. CRRG Frequently Asked Questions and Answer, Question 64, discusses How should a replacement credit card be reported. XXXX either does not have competent staff to understand Metro 2 or it just refuses to comply to save money. In my case, my old acct # XXXX was required to be updated with the new account number of #XXXX (changed about 3 years ago) so XXXX is NOT 100% Metro 2 Compliant mandating deletion. Exact account number reporting is mandatory for many reasons including an internal control to prevent duplicate reporting of accounts especially when accounts are sold or transferred to others. I have made multiple disputes but not only has XXXX noticed yet failed to fix the obvious account number inaccurate account number but not one CRA has noticed the error nor forced Metro 2 updating of the correct account number as required to be Metro 2 compliant. My XXXX paper report conceals the last 4 digits of my XXXX account number so I could not discover the inaccurate account numbers and inaccurate reporting in willful violation of the FCRA. On the other hand, TransUnion just reports just the last 4 numbers of XXXX account on my paper so that the complete account number is discoverable to scammers by merely looking at 2 separate credit reports. The FCRA and Metro 2 require the complete account number into Metro 2 and paper credit reports to insure accuracy and prevent duplication. The ineffective procedure of partially blocking 4 or more account numbers on paper reports is counterproductive, achieves no valuable benefit or protection and deprives consumers of the right to determine accuracy especially if accounts are transferred. Since there is $0 liability for credit fraud to consumers, complete account numbers must be reported on every CRA pursuant to the FCRA especially on Closed accounts, such as XXXX, which should be blocked. The partially blocking of account numbers has protections for furnishers and no benefits for consumers, so every account on my credit report is inaccurate and not Metro 2 Compliant mandating deletion of every account including my XXXX account. CRRG answer to Question 58 required XXXX to Report my account as deferred along with Special Comment AW (Affected by Natural or Declared Disaster) and other coding mandatory field entries negligently or intentional omitted in violation of the FCRA. As XXXX knows I live in XXXX and I told it many times that I took a direct hit from Hurricane Ian in XXXX XXXX and I have been seriously affected by the FEMA declared natural disaster, not only has XXXX willfully violated its specific obligation under the FCRA to report on my credit report Affected By Natural or Declared Disaster, Compliance code AW, but it claims I am late despite the prohibition of late reporting due to Hurricane Ian. Again, XXXX is apparently deliberately negligent or untrained in meeting its mandatory obligations under Metro 2 contained in the 355 page Guide or it has maliciously and purposely violated the FCRA to hopefully induce me to pay disputed account charges thereby entitling me to $10,000+ in statutory and punitive damages so my claims exceed the smaller XXXX disputed claim. XXXX and every CRA must enter account status code DA in field 17A to avoid and mitigate damages. How about the mandatory Date of First Delinquency that furnishers and CRAs never report accurately. It is about time XXXX sends its employees Back to School to learn about its obligations to insure maximum possible accuracy coding required under Metro 2/e-OSCAR/FCRA/FCBA/etc. Garbage IN means Garbage OUT. Worst yet is leaving mandatory required fields BLANK in complete disregard for the requirements of Metro 2 and the FCRA. Exhibit 8 of the CRRG regarding Compliance Condition Codes, which is reported in Field 20 of the Base Segment, is used to reflect accounts Closed at Consumers Request, and, inter Alia, consumer disputes under the FCBA, FDCPA and FCRA. Numerous Condition Codes exist (XA, XB, XC, XD, XE, XF, XI, XH, XJ etc) exist mandating reporting Accounts Closed at Consumers Request with the DEFINITION: Reported when a consumer requested an account be CLOSED with an Important Note: Report the DATE CLOSED as the date the account was CLOSED TO FURTHER PURCHASES which XXXX acknowledges was in XXXX XXXX Field Definitions in Metro 2 for #26 state: Date Closed the date the account was closed to further purchases there may be a BALANCE DUE. I need to repeat again and again what the FCRA and Metro 2 require in the 355 page guide. Definition: Reported when a consumer requested an account be closed with an Important Note: Report the Date Closed as the Date the account was closed to further purchaseswhich XXXX letter acknowledges was in XXXX. Again, Field Definitions for #26 Date Closedthe date the account was closed to further purchasesthere may be a balance due. There can be absolutely no doubt that XXXX has no idea of what a Closed account is and what the FCRA, case law, and the 355 page Metro 2 guide defines. Or worse it has lied, lied, lied to federal investigators and its own superiors mandating disciplinary action against employees conspiring to violate the FCRA. XXXX top management needs to take disciplinary action against its staff for unconscionable conduct. XXXX frivolous and illegal position that it will never report my account as closed unless and until I pay the entire balance in full is absolutely ridiculous and in willful and malicious disregard for the FCRA mandating maximum possible Statutory and Punitive damages plus Attorney Fees exceeding $100,000. Does XXXX want a US District Court jury to punish it if it is wrong? Does XXXX want to spend $50,000 in legal fees and related expenses only to lose? Does XXXX want a US District Court to ask a US Magistrate Judge to issue a Report of Findings of Fact and Conclusions of Law to be reviewed by the US District Court Judge for judgment and Rule 11 sanctions? Does XXXX want the CFPB and the Florida AG to prosecute it? Does XXXX employees want to risk losing their jobs for knowingly, deliberately, maliciously, negligently and purposely violating the FCRA in bad faith? Is there criminal conduct under multiple federal statutes for lying to federal authorities? XXXX top management and below have no idea what the FCRA and Metro 2 straight forward Definitions are for a closed account or worst it knows my account is closed yet it continues to illegally report my account as Open for a sinister purpose. XXXX knows that my account was closed yet it refuses to report my account as Closed in willful violation of the FCRA, Metro 2 etc even though it acknowledges my phone call demand to close my account in XXXX resulting in not only a closure, by definition, but XXXX blocking my account from further purchases thereby meeting the Metro 2 definition of a Closed account. XXXX falsely claims that my account will NEVER be reported as closed until my entire balance is paid in full. I closed my account in XXXX but XXXX refuses to report my account as closed and just willfully violated the FCRA and Metro 2 by reporting my account as OPEN. XXXX had systematically, maliciously, deliberately and willfully violated the FCRA and Metro 2 resulting in inaccurate and incomplete reporting of data including blank data and codes in data fields in Metro 2 that XXXX and CRAs refuse to adequately investigate. Once I called XXXX by phone and demanded it close my account and XXXX at that time processed my closure request telling me my account was now closed telling me the account was blocked from further purchasers so I needed to advise merchants not to use my closed account further, XXXX was required to PROMPTLY in a matter of a few days or minutes (not months) report my Account As Closed By Consumer forever keeping it Closed with every CRA never to be changed or deleted. Reporting an account as closed should be an instantaneous and automatic credit reporting process as it happens so frequently. XXXX blocked my account from further purchasers and read me the disclosure statement on its recorded line that my account was closed which I demand a certified copy of such transcript herein as additional proof of XXXX wrongdoing. This is certainly a learning lesson for XXXX so its staff may understand and comply with its obligations under the FCRA and Metro 2. Treating Consumers as stupid with disrespect is a terrible way to respond to bona fide complaints and disputes., especially when CFPB complaints can be viewed online for the public to read. Does XXXX really want to risk multi jurisdictional civil and criminal litigation over the Definition of a Closed Account? The Definition of what a Closed account under the FCRA and Metro 2 is absolutely clear and its repeated definitions cannot be challenged under any scenario. Your Law firms will risk damaging their reputation and licenses by claiming my Closed XXXX account is still Open when faced with a Rule 11 motion and action for sanctions for frivolous conduct. What is wrong with XXXX? Is your XXXX parent telling you to lie to federal authorities? Are your executives stupid? Do you think the CFPB is stupid? Do you think a jury and US District Court Judges are stupid? Well, I am obviously NOT stupid and it is obvious that I am furious about the entire credit reporting system and its lack of controls. The CFPB knows and has acknowledged unacceptable systematic FCRA violations. I just cant believe XXXX insists on reporting my Closed account as Open. Keep being STUPID and XXXX will pay bigger and bigger serious consequences. Customers must be treated with respect not treated as Stupid by untrained inexperienced or stupid employees who do not act in the banks best interest. When I filed my complaint with the CFPB, you should have taken the complaint seriously and tried everything to satisfy me by even giving me more than I asked for instead of being stupid. XXXX should have reduced my interest to 0% and just offer to pay me a XXXX statutory damage amount while not admitting or denying wrongdoing. Moreover, XXXX should have offered to permanently delete my account from every CRA as that would cost XXXX. But XXXX is not only stubborn but a stupid recalcitrant lender who would never offer a $1 concession but would prefer to spend millions rather than make needed token concessions. Businesses pay huge sums to answer customer service phone calls and concessions are the cheapest and most effective way to satisfy and retain customers. But obviously, XXXX has alienated me (and others similarly situated) by treating me as stupid even after filing a CFPB complaint. What would Banco XXXX Parent in XXXX say when matters get out of Control and no one wants to acquire you? I could continue for 20 more pages quoting the FCRA, Metro 2 Guidelines, statutory intent, criminal federal statutes, CFPB policies, Case law etc but XXXX is required to know all that and have its Staff trained and knowledgeable. This Complaint will certainly assist XXXX staff in understanding its obligations under the FCRA and Metro 2. I am entitled to relief as a consultant would charge huge amounts for what I have told you about your deficiencies. Once my account was closed, XXXX was prohibited to report my account with a variable interest rate so again XXXX coding with a variable rate is inaccurate which everyone missed after closure. XXXX needs to send its staff and upper management Back To School to Metro 2 workshops, e-learning courses and seminars. The industry Reporting Standards of Metro 2 to insure integrity and consistency of credit information requires: All Accounts must be reported a minimum of once per month. Prompt immediate and button-pushing automatic mid cycle updates are required especially for Closed, Disputed and accounts Affected by Natural or Declared Disaster. XXXX has failed to meet these and other Metro 2 obligations because as of XXXX, my last XXXX update to TransUnion and XXXX was XXXX per the attached. Pursuant to section 1682 et seq of the FCRA, XXXX and every CRA may be liable for willfully and negligently failing to follow reasonable procedures to assure maximum possible accuracy. XXXX is out of control. XXXX numerous deliberate deficiencies of illegally withholding and inaccurately concealing and reporting false and missing required account data is purposely intended to negatively affect a consumer credit score in complete willful violation of the FCRA. XXXX has escalated my complaint issues to a high level executive department so there is no defense or excuse of new or inexperienced employees or other type of employee error or negligence as my dispute issue responses are purportedly prepared and investigated by senior level experience staff and reviewed by higher level experienced staff. While Rule 11 sanction requests for frivolous conduct in federal courts permit violators to escape sanctions due to a 30 day safe harbor, willful violations of the FCRA cannot escape statutory and punitive damages. Some attorneys prefer to immediately file FCRA lawsuits upon discovery of violations. My efforts are intended to provide repeated notice of XXXX illegal conduct so that FCRA violations can be corrected to mitigate damages. If XXXX willfully continues to violate the FCRA despite numerous warnings, higher punitive damages will be incurred. I believe that XXXX will never admit FCRA violations due to its internal policies for dealing with FCRA violation complaints. So despite my indisputable detail of widespread and systematic illegal conduct known to be illegal, I expect XXXX will continue to willfully violate the FCRA rather than just delete my account permanently from every CRA. CFPB Director XXXX XXXX recently said around XXXX XXXX XXXX: TransUnion is an out/of-control repeat offender that believes it is above the law. I am concerned that TransUnions leadership is either unwilling or incapable of operating its businesses lawfully. My XXXX issues similarly prove that XXXX is an out-of-control repeat offender that refuses to comply with the FCRA and is incapable of understanding and implementing Metro 2 and the most basic FCRA provisions for reporting closed, disputed, affected by natural or declared disaster accounts and data. On XXXX XXXX XXXX, Florida Attorney General XXXX XXXX announced a settlement agreement with 34 attorneys generals and XXXX that included about XXXX XXXX in relief nationally including future injunctive relief requiring that XXXX shall maintain policies and procedures with respect to deferments, forbearances, modifications, and other related servicing and collection matters, and ensure that these policies and procedures are followed by its employees. I maintain that the violations of the FCRA by XXXX and its refusal to mark my offered payment deferrals due to Hurricane Ian on my credit reports constitute violations of it injunction which I will address counsel for the Florida AG. The AG injunction also stated: XXXX shall comply with the Florida Deceptive and Unfair Trade Practices Act, Chapter 501, Part II, Florida Statutes. Obviously, XXXX willful and malicious violations of the FCRA clearly constitute grave violations of Floridas Deceptive and Unfair Trade Practices also enjoined by the injunction relief agreed to by XXXX. XXXX is just out of control and incapable of complying with its obligations. Metro 2 and the FCRA is just too complicated for XXXX to administer as required mandating permanent deletion of my disputed and closed account from my credit report. XXXX retaliated against me for seeking deferrals offered and accepted automatically and required due to Hurricane Ian resulting in unacceptable FCRA violations and a complete disregard for requirements of Metro 2. I insist on 100% compliance with the requirements of Metro 2 and the FCRA to prevent the inaccuracies and incomplete credit reporting. Moreover, I demand a copy of every XXXX Metro 2 code filed so that I can compare codes submitted versus paper reports received. My credit file is the Metro 2 codes which is inconsistent and quite different from my paper credit reports as the Metro 2 files contain data that is not on my paper reports. Failure to provide me with past Metro 2 filings shall constitute the same FCRA violation as failing to provide an English paper credit report or electronic copy of my credit report. Keep in mind that an analysis of my Metro 2 codes show that I was in the past 60 days late which is impossible as my paper reports showed that I was never late to any creditor. The Metro 2 coding is so complicated that inaccurate negative and derogatory data will always exist in Metro 2 which is not shown on a paper report to a consumer. Metro 2 must be exactly the same as a XXXX","date_sent_to_company":"2023-02-17T10:42:31.000Z","issue":"Incorrect information on your report","sub_product":"Credit reporting","zip_code":"32836","tags":"Older American","has_narrative":true,"complaint_id":"6583809","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"TRANSUNION INTERMEDIATE HOLDINGS, INC.","date_received":"2023-02-17T10:42:19.000Z","state":"FL","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Account status incorrect"},"highlight":{"complaint_what_happened":["The integrity and reportability of my XXXX and other closed accounts is called into question as mandatory data fields are missing, contested and cannot be verified and certified as perfectly compliant, mandating deletion entirely. Not only are numerous required fields in segments missing entirely, but many fields are inaccurate, and more importantly, Furnishers do not understand how to accurately code the complex mandatory compliance codes."]},"sort":[9.137791,"6583809"]},{"_index":"complaint-public-v1","_id":"9561046","_score":5.745858,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"I wish to practice my right as a customer of Bank of America to use your organisation's service, seeking a\nformal, impartial investigation to amicably settle my dispute with Bank of America.\nIn order to clear up the myriad of letters and correspondences I have hitherto sent to Bank of America\nrespecting my complaint, I believe it will substantially strengthen both my case and your understanding, by\ntaking a deeper look at the happenings of my case, and analysing the relevant facts in an objective and\ncomprehensive fashion.\nIt is crucial to note that I have been manipulated, socially-engineered and coerced to engage these fraudulent\ncriminals. Much to my embarrassment, I recognise that I am the victim of an investment scam.\nMy complaint to the CFPB has arisen as I do not consider, by any stretch of the imagination, the conduct\nof Bank of America to be commensurate with their legal role and responsibility to their customers. They\nsell a service to look after their customers, protect their money and are a financial institution that maintains\na traditional relationship and way of working with its customers.\nDuring the complaints process with Bank of America, I found their communication ineffective, which\nfurther hides their conduct to management and diminishes the service offering to their clients. They are\nstruggling to adapt their business offering in the ever-changing world of IT development. The internet is\npresenting a real problem which they choose to manage in a way which is not in line with rules and\nregulations of CFPB as well as their own internal policy and procedures sold to their clients.\nGeneral Obligation:\nCommencing on or abouXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX fell victim to a multi-layered scam\noperation run by XXXX XXXX XXXX XXXX which involved me making deposits for a total amount of XXXX XXXX from my Bank of America account to fraudulent investment firm.\nWhen determining whats reasonable and fair, we should focus on the issue of liability; common queries\ninclude, but are not limited to, the following (i) whether Bank of America did not take notice of any rule,\nlaw, or regulation, and/or possibly missed any material elements of the relevant bylaws or codes of conduct,\nthat may have prevented them from protecting my financial safety; (ii) whether by virtue of Bank of\nAmericas custodianship over my funds or by its control over them, they owed a fiduciary duty to the me\nand if so, whether that duty was breached; (iii) whether Bank of America promoted the transaction(s) in\nquestion despite being aware of the nature of the transaction(s) in question (iv) whether Bank of America\nwas in compliance with its own policies and procedures; (v) whether Bank of America owed duties to\nmyself, what the scope of those duties was, and whether Bank of America did not uphold those duties; (vi)\nwhether Bank of Americas conduct was unfair; and (vii) whether Bank of America has within its power\nthe ability to, and should, compensate me for the harm that has befallen me.\nUpon identification of such unusual or suspicious activity, it is crucial that the relevant staff member\nadequately describe the factors making an activity or transaction suspicious, thoroughly depict the extent\nand nature of this activity and properly communicate to the customer that such activity meets the relevant\ncriteria of fraud.\nIn providing its services to a customer, a financial institution is required by law to exercise the care and\nskill of a diligent, prudent banker. In this case, this means that the payment service provider should not turn\na blind eye to known facts pointing to a real possibility that their customer is being scammed. In other\nwords, Bank of America must have had special knowledge of what was occurring or been alerted to a real\npossibility of fraud taking place. The financial institution must have known or reasonably ought to have\nknown that I was dealing with a scammer.\nGranted, there is room for diversity of view insofar as reasonableness is concerned. Indeed, there is a sense\nin which the standard of care of the reasonable person involves in its application a subjective element.\nHowever, it must be remembered that the correct test is always reasonable care in all circumstances, not\naverage care. The fact that most people behave in a certain way may be good evidence that the conduct is\nreasonable, but this is not necessarily the case. Although reasonableness is a very fluid concept, all of the\nevidence suggests that Bank of America did not foresee the fraud and disregarded even the most obvious\ndangers in this respect.\nSituations do tend to repeat themselves and it is advisable to examine previous outcomes to see how the\nstandard of the reasonable person should be applied, and that lessons can be learnt from the errors of the\npast.\nBank of Americas Position:\nBank of America wrote in a letter The amounts totaling of XXXX in question that you listed in your\ncomplaint is an accumulation of several transactions that were sent to the three previously mentioned\nmerchants that were confirmed valid and not made in error. Please note, the transactions posted correctly\nto your account as instructed in XXXX XXXX. While we are sensitive to the effect this matter has had on\nyou, we are unable to dispute any agreements that you may have had with the recipient of the funds.\nWe can only recommend that you contact the recipient directly for further assistance with your disputes.\nRefuting Bank of Americas arguments from a purely logical perspective:\nBank of Americas position is that the features of the situation at hand do not generate a genuine obligation\nto protect innocent and helpless victims; they are essentially arguing that common-sense-based approaches\nare doomed to fail, leaving their exclusively technical account of the subject matter as the only meaningful\nchoice. For reasons which are unclear, this extremely serious situation barely gets the attention it deserves\neven though ample evidence has been offered in support of this complaint.\nIn Bank of Americas view, it is implied that we should not home in (and consequently rely) on unwritten\nlaws, practicality, good judgement, reasonableness, sharpness, sensibleness, past outcomes, and insight,\nwhen taking appropriate precautions. To underscore, once again, such views are at odds with common sense\nand are wildly irresponsible.\nImagine a view according to which the one and only thing that can make Bank of America morally obligated\nto do something is having it written down somewhere. Pursuant to this view, if Bank of America encounter\nthe suffering of totally naive victims, they are only obligated to intervene in or remedy the situation, to the\ndegree required by written material. This is unbecoming for a reputable establishment such as Bank of\nAmerica.\nI have reviewed the material hereto sent by Bank of America carefully, and it unfortunately provides no\nresponse to my fundamental argument concerning the degree of care. Given its size, influence, and the\nresources at its disposal, this establishment clearly had a far greater capacity than an individual such as\nmyself had, to determine the level and likelihood of risk that a client such as myself is subjected to and had\na duty to intervene as they now do to query in particular out-of-pattern transactions of this kind.\nIt is perfectly obvious that Bank of America, inadvertently, employs a subtle approach in addressing some\nof the key questions in a manner which neither provides me with adequate support nor protects anything\nother than its own interests.\nIt is Bank of America here, who has the burden of proof, to show that it has exercised the duty of care, that\nis to say, that Bank of America adhered to a standard of reasonable care in relation to the matter at issue\ngiven its extensive experience compared to mine. It is Bank of America that claims that the damages which\nI have suffered in connection to this matter have not been reasonably foreseeable, and that my proposed\ndegree of care is not, and has not been, commensurate with XXXX XXXX capacity, experience,\nexpertise, or scope of services in any way. To reemphasize, Bank of Americas indisputable overriding\npurpose is by no means to purely execute transactions in a blind and blank fashion, but rather to strike a\nbalance between executing those transactions and capitalising on its undeniably vast capabilities to protect\nconsumers thereby enhancing market integrity.\nApropos of the fluidity of the concept of reasonableness, all Bank of America has done in this regard is set\nup a dichotomy of having or not having the legal obligation under consideration, however, that does not go\none-inch toward explaining why various regulatory authorities, has maintained that financial institutions\ncan, and should, protect consumers using their systems, advanced technologies, and rich experience.\nBank of America is obliged to take some action if it is sufficiently aware of a real possibility that a fraud\nmay be being perpetuated. If you don't question its customers instructions or raise the possibility of a scam\nwith the customer in these circumstances, it may be liable if the red flags indicate the customer is:\n particularly vulnerable, or\n if the possibility of fraud was serious or real, not just suspected.\nThere are some recommendations to organisations for protecting customers from financial harm that might\noccur as a result of fraud or financial abuse; and gives guidance on how to recognise customers who might\nbe at risk, how to assess the potential risks to the individual and how to take the necessary actions to prevent\nor minimise financial harm.\nThese recommendations are established as a general principle, the organisation should deliver a\nservice that:\n1) Takes a proactive approach to minimising risks, impact and incidences of financial harm and it sets\nout systems and tools for the prevention and detection of fraud and financial abuse. As a general point,\nit says organisations should ensure that all systems are developed using technologies and methodologies\nthat are effective in the prevention of fraud and financial abuse, through authorised and unauthorised\npayments, thereby minimising the risk of financial harm to customers. As regards to the detection of\nfraud and financial abuse, it says the organisation:\nA) should have measures in place across all payment channels and products to detect suspicious\ntransactions or activities that might indicate fraud or financial abuse. It then lists the following\nexamples of suspicious activity on customer accounts:\na. multiple cheque books;\nb. sudden increased spending;\nc. transfers to other accounts;\nd. multiple password attempts;\ne. logins from new devices, multiple geographical locations;\nf. sudden changes to the operation of the account; Unusual transactions are transactions\nwhose amount, characteristics and frequency bear no relation to the economic activity\nof the customer, exceed normal market parameters or have no apparent legal\njustification.\ng. a withdrawal or payment for a large amount;\nh. a payment or series of payments to a new payee;\ni. financial activity that matches a known method of fraud or financial abuse.\nB) organisations should have a process in place to ensure that staff make contact with the customer\nto verify the financial activity, challenge its authenticity, explain the nature of the suspected or\ndetected fraud and discuss an appropriate plan of action.\nBank of America are yet to show, or otherwise provide me with, a compelling argument that their wideranging\nexperience and wealth of specialist knowledge in detecting transactional anomalies were not\nsufficient to avert the fraud at issue. By contrast, I have provided a multitude of sound and powerful reasons\nby which requiring their involvement has not only been pressingly relevant but also eminently reasonable\nand well-justified.\nRather than empathising with and undertaking substantial efforts to convey their knowledge of the existence\nof such regulations abroad and thereafter use it to protect and proactively relieve the plight of consumers\nwho have been cheated out of their money and whose role in society is properly fulfilled, positively\ncontributing to local economic growth, development and sustainability Bank of America adopts a rather\ninsouciant attitude toward my financial predicament portrayed herein.\nI am deeply convinced that the disastrous results that I have previously elaborated upon will continue to\nensue if no responsibility is adopted by Bank of America in relation to this matter. I have also thoroughly\ndetailed why they cannot simply dismiss this problem by strictly adhering to legal technicalities which,\nafter careful reflection, struck me as being nothing more than self-interest. Indeed, it seems to me utterly\nunfair to disregard fragile, sensitive, and vulnerable consumers who are afflicted by such allegedly\nmalevolent acts, thereby keeping an unjust status-quo that is corrupting our society at its core.\nI would also like to highlight the stark difference in how complaints are handled between Bank of America\nand XXXX XXXX Bank of America's handling of the situation was notably inadequate. They failed to properly\nacknowledge the issues I faced and did not provide the necessary support to recover my funds. In contrast,\nPNC Bank managed the situation with exemplary care. They not only acknowledged everything I had been\nthrough but also took proactive steps to assist me in recovering my funds. This level of customer service\nand attention to detail speaks volumes about XXXX XXXX commitment to their clients and their ability to\neffectively address and resolve issues.\nConclusion:\nBased on my analysis, and as confirmed by various authorities concerned with such matters, there is\nabundant evidence that forward-thinking financial institutions ought to take reasonable steps to forestall\nfraud, or at least mitigate its risk by using an effective risk management system, demonstrating their\nundisputed ability to responsibly and pre-emptively respond to questionable transactions in the digital\narena. The use of such systems, largely based on newly adopted technologies aimed at effectively\nnavigating the evolving threat landscape, is only one of a number of possible endeavors undertaken in this\nconnection, alongside the application of past knowledge and experience related to popular fraudulent\npractices.\nAstonishingly, I am pondering how it is that, despite being shown that Bank of Americas business conduct\nwas insufficient insofar as background checks are concerned, they keep refuting their indisputable role and\nresponsibility in connection with the matter herein discussed. The points that I have hitherto made are too\ncrucial to be taken lightly. Bank of Americas non-observance of the fundamental principles of justice \nthat is, to completely overlook and not even remotely try to mitigate the suffering of vulnerable consumers\nis inexcusable given the size of the establishment and the vast resources at its disposal as the direct result\nof the patronage of clients like myself.\nIf it was, indeed, solely my responsibility, we must then believe at least one of the following clauses: a)\nfinancial institutions have absolutely no role whatsoever in preventing and detecting fraud, b) the fraud in\nquestion was not reasonably foreseeable, or c) the transactions in question were not sufficiently alarming.\nIt is extremely unfortunate that Bank of America pushes quite hard for me to believe all three of these\nthingsdespite evidence to the contrary.\nIn summary, I respectfully ask your organization to consider my points, given your personal and\ncompanywide obligation to provide a fair and reasonable investigation into the complaint.\nI look forward to your input and would gladly cooperate to reach a fair and reasonable outcome.\nThank you.\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Bank of America\nBank of America Corporate Center, XXXX XXXX XXXX XXXX\nWITHOUT PREJUDICE\nSubjectXXXX XXXX XXXX complaint to XXXX XXXX XXXX: Bank of Americas complaints dept.\nDear Sir / Madam,\nI have now reviewed your response dated XXXX XXXX XXXX Based on my review, I do not believe you have acted fairly, let alone reasonably.\nThe investigatory processes appear to disfavour the victim, and there is a lack of knowledge of good industry practice as well as a lack of\ncare/compassion towards me as the customer.\nYour response is, to say the least, extremely inadequate. It is based on a blatantly incorrect understanding of what I have maintained.\nWhat amazes me is just how difficult it has been to find soundness in it. Your analysis, for instance, does not engage with the actual\nhistory of my account and a significant portion of related data that may contradict your position has been conveniently ignored.\nSeemingly, in arriving at a decision in relation to the issue I raised, no consideration was given to a) Duty of care in relation to the fact\nthat I am the victim of a financial crime and b) The responsibility that your institution hold to protect its clients from such crimes.\nI find your rejection incredibly offensive and perplexing. In all honesty, if you could provide me with any kind of a logical coherent\naccount that could reconcile the evident fact of the multiple warning signals as well as my susceptibility relating to this matter with the\nexistence of a sound anti-fraud program, then I would absolutely appreciate your point of view.\nGiven the variety of similar cases involving various types of scams, you should be acutely aware of this problem for society, but your\nsuperficial (and perhaps convenient) answer to it, simply put, is that blameless victims must be held accountable for their misfortune.\nBecause your argument presumably aims at self-protection rather than the truth, we can have no confidence that your rejection is\nultimately just, fair, or reasonable. It is time to adopt a more realistic, long-term attitude towards unavoidable scenarios of this kind,\nstarting from the justifiable assumption that such injured parties did not in the least contribute to (and thus certainly should not bear\nresponsibility for) their own victimisation.\nMisplaced Accountability:\nScam victims have relatively little freedom of reactivity; under such circumstances, they respond immediately, instinctively, and\ninvariably to the specific demands of the perpetrator. Being able to consciously refrain from reacting in such a way is extremely difficult\nand sometimes impossible. Unwittingly giving off signals that mark us as easy targets, is by no means the same as being grossly\nnegligent, in view of the increasingly sophisticated scams, which continue to be a pervasive problem in society.\nDue to personal circumstances, I was particularly vulnerable during the victimisation period; I was also relatively financially illiterate\nand very inexperienced in the finance sector which made me a prime target for criminal enterprises in this field.\nSince this time, having lost all of my savings to these fraudulent companies, I have learnt an enormous amount about the scope of these\ncriminal endeavours and also about how the financial services sector operates internationally.\nFinancial institutions are well aware of the scope and nature of such crimes and the risks that these pose to their clients, who, in contrast,\nmostly have limited knowledge of these dangers.\nTo be clear, people who have been scammed such as myself, are not individuals who have made poor investment decisions. They are\npeople who have been tricked, lied to, deceived and emotionally manipulated. Sophisticated, aggressive sales techniques end up trapping\nthe uninformed and unsuspecting victim who once in the clutches of the scammer cannot get out until most or all of the funds have been\nlost (stolen) by the scammers. A good comparison is a perpetrator who grooms his victim whilst at the same time assaults him/her and\nprevents them from escaping.\nThis complex issue has caused substantial harm to me, and if not appropriately addressed, will cause substantial harm to others, we must\ntherefore conduct an in-depth and comprehensive review of all of the contributing factors that have led to an outcome as horrendous as\nthe one described herein.\nThe grounds upon which you refute my claim:\nScrutiny shows that your claims are defective as an endeavour to thoroughly investigate the accessible facts; let alone as an attempt to\nportray an accurate image respecting the role of banks in fighting financial crime and fraud, your organisations scope of services, and\nvarious other details in connection with the duties that emerge out of our relationship, particularly in the context of the broader historical\ncircumstances. The emphasis that you have placed on the incredibly insufficient diligence checks as well as the inconsequential\nreferences and the unidimensional thinking, not only gives a skewed picture of my fundamental rights as your customer, but also\npresents a poor blueprint for understanding the issue discussed in a well-reasoned and objective manner, and an even poorer guide to\ndictate whether there has been, as suggested, wrongdoing on your part.\nThe amounts totaling of XXXX in question that you listed in your complaint is an accumulation of several transactions that\nwere sent to the three previously mentioned merchants that were confirmed valid and not made in error. Please note, the\ntransactions posted correctly to your account as instructed in XXXX XXXX. While we are sensitive to the effect this matter has had on\nyou, we are unable to dispute any agreements that you may have had with the recipient of the funds. We can only recommend that you\ncontact the recipient directly for further assistance with your disputes.\nConcerning the \"authorisation\" argument, it can be cast as an incompatibility between statements such as \"the transaction has been\nauthorised\" and \"the duty of care has been breached\". However, you have not shown that both statements are logically incompatible or\nimprobable with respect to each other. They are not mutually exclusive in the broader context.\nThe view that I have authorised the transaction and therefore fully liable is dangerously reductive--various aspects relating to the breach\nof the duty of care have been marginalised. Clearly there are more facts to be taken into account than at first appears.\nI notice that your account of the subject matter depends crucially on the supposed lack of obligation which is perhaps the most obscure\npoint in your argument. But regardless, your views give us reason to contemplate as well whether your societal role (which arguably\nrenders you capable of preventing plausibly foreseeable damages such as the one set forth herein) should trigger the appropriate moral\nobligations rather than unscrupulous beliefs which are inherently unjust, flagrantly unfair and merely conducive to your own self-interest\nand welfare. Likewise, you unknowingly oppose the emergent notion that I was no luckier in blindly placing faith in your\nestablishments competence than I would have been in not doing so.\nYou have blithely ruled out your obligation herein by undermining reasoning strategies aimed at justice and fairness; remarkably, you\nhave deliberately avoided the uncomfortable yet inevitable conclusion that in this instance you are to be held accountable, by narrowly\nholding that a financial institution's role in society is merely to \"act upon the customer's instruction.\" This sort of reductionist view has\nlong since been exposed as inadequate among world-leading, key financial regulatory authorities.\nIt is intuitively clear that you have not reckoned with the remarkable range of indispensable functions, which your organisation should\nperform for the community in a manner that is both stable and sustainable. It is moreover blatantly apparent, that, instead of being\nattuned more than ever to the importance of apprehending the pernicious influences of your idleness and non-intervention amidst an\ninexorable rise of financial fraud, you are unwarrantably hiding behind specious arguments based on thin assumptions, inadequate\nresearch, poor evidence, and sloppy reasoning. It is a whole lot better and far more effective to do the right thing, rather than the most\nprofitable one thereby compromising the integrity of your enterprise. I suggest that by following adequate protocols aimed at mutual\nbenefits (rather than satisfaction of personal goals), disadvantaged consumers will thrive rather than suffer, with a plethora of positive\nfeedback propagating far and wide as a result.\nI demand an investigation to bring to light additional relevant evidence that I am persuaded will support my view. It is hereby proposed\nthat your motivations may adversely affect reasoning through overreliance on a biased set of processes. As a substitute for sub-optimally\nrelying on a set of gross oversimplifications (which frustratingly and inexorably lead us to draw erroneous conclusions), we should,\ninstead, systematically account for the totality of the evidence howsoever unpalatable by even-handedly relying on complex and\nmultifactorial reasoning. The demand for sound reasoning is essentially a demand for ultimate explanation, and is linked with a complete\nunderstanding of the pronounced role that you played in permitting my injuries herein\nIn light of the above, it is patently clear that your train of thought is fatally flawed and totally unsupported. You have failed to come up\nwith positive evidence to support your claims, that is, to show beyond any reasonable doubt that irrespective of your conduct, my\nvictimization was an inevitable outcome. On the other hand, I have provided substantial evidence to support the claim that you could\nhave done more to safeguard my funds. Not only have you let me down, but you have also failed to admit that you could and should\nhave done better.\nWhat can Bank of America do?\nPlease be noted that I will not in any way quietly tolerate the consequences of your actions (or more precisely, the lack thereof). Your\nresponse has limited the discussion narrowly to highly technical terms, and insufficient attention has been given to your organizational\ndysfunctions from a common-sense point of view. It is perfectly obvious that you could have, and should have, utilized various riskbased\nexamination procedures and techniques, all of which are within your purview and could have entirely prevented this disastrous\noutcome. It is wildly incorrect to assume that you have exercised your duties by doing the minimum necessary. You have not exercised\nyour duties at all, rather, many of your underlying assumptions have simply gone unquestioned. Instead of being receptive to\nconstructive criticism and improving yourself, you ultimately seek to blame your customers thus absolving yourself of any\nresponsibility.\nAs previously advised, you should have known, suspected, or had reason to suspect that the transactions (or pattern of transactions):\n involve funds the ultimate purpose of which was to fuel an illegal enterprise;\n is intended to disguise funds the ultimate purpose of which was to fuel an illegal enterprise, in an attempt to avoid and thus\nviolate regulations;\n is intentionally designed to defraud your customer;\n serves no legitimate or lawful purpose; and\n involve the use of your services to facilitate criminal activity\nThere are so many other ways in which measures related to fraud prevention and mitigation could have been useful. To the extent to\nwhich you were inconsistent therewith, you are liable for damages. Further factors that should have been taken into consideration\ninclude, but are not limited to, the following:\n The timing, volume, frequency, and nature of the transactions in question;\n The abnormality of such transactions against the background of your experience with me as a customer and other entities\nassociated with the transactions (if any);\n The suspicious nature of such transactions based on my overall risk profile including vulnerability, identification and research\nof high-risk services/products;\n Systemic filtering mechanisms, whether manual or automatic, for the identification of unusual activities; and\n Periodic evaluation of the usefulness, appropriateness and effectiveness of anti-fraud programs, and other associated policies\nand procedures.\nIt is incumbent upon financial institutions to carefully assess all information available about their customers, including vulnerability,\nneeds and customer type. There is a wide range of transactions which, although legitimate, should raise a red flag simply because they\nare inconsistent with the customers typical and ordinary activity. What constitutes reasonable grounds to flag transactions varies\naccording to the facts and circumstances of the particular matter being investigated and the effectiveness of the anti-fraud processes.\nRelevant industry practices at the time of the victimisation:\nYour Organisation is obliged to take some action if it is sufficiently aware of a real possibility that a fraud may be being perpetuated. If\nyou don't question its customers instructions or raise the possibility of a scam with the customer in these circumstances, it may be liable\nif the red flags indicate the customer is:\n particularly vulnerable, or\n if the possibility of fraud was serious or real, not just suspected.\nThere are some recommendations to organisations for protecting customers from financial harm that might occur as a result of fraud or\nfinancial abuse; and gives guidance on how to recognise customers who might be at risk, how to assess the potential risks to the\nindividual and how to take the necessary actions to prevent or minimise financial harm, these recommendations are established as a\ngeneral principle, the organisation should deliver a service that:\n1) Takes a proactive approach to minimising risks, impact and incidences of financial harm and it sets out systems and tools for\nthe prevention and detection of fraud and financial abuse. As a general point, it says organisations should ensure that all systems\nare developed using technologies and methodologies that are effective in the prevention of fraud and financial abuse, through\nauthorised and unauthorised payments, thereby minimising the risk of financial harm to customers. As regards to the detection of\nfraud and financial abuse, it says the organisation:\nA) should have measures in place across all payment channels and products to detect suspicious transactions or activities that\nmight indicate fraud or financial abuse. It then lists the following examples of suspicious activity on customer accounts:\na. multiple cheque books;\nb. sudden increased spending;\nc. transfers to other accounts;\nd. multiple password attempts;\ne. logins from new devices, multiple geographical locations;\nf. sudden changes to the operation of the account; Unusual transactions are transactions whose amount,\ncharacteristics and frequency bear no relation to the economic activity of the customer, exceed normal\nmarket parameters or have no apparent legal justification.\ng. a withdrawal or payment for a large amount;\nh. a payment or series of payments to a new payee;\ni. financial activity that matches a known method of fraud or financial abuse.\nB) organisations should have a process in place to ensure that staff make contact with the customer to verify the financial\nactivity, challenge its authenticity, explain the nature of the suspected or detected","date_sent_to_company":"2024-07-19T23:38:35.000Z","issue":"Fraud or scam","sub_product":"Virtual currency","zip_code":"08807","tags":null,"has_narrative":true,"complaint_id":"9561046","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"BANK OF AMERICA, NATIONAL ASSOCIATION","date_received":"2024-07-19T23:25:30.000Z","state":"NJ","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":null},"highlight":{"complaint_what_happened":["B) organisations should have a process in place to ensure that staff make contact with the customer to verify the financial\nactivity, challenge its authenticity, explain the nature of the suspected or detected"]},"sort":[5.745858,"9561046"]},{"_index":"complaint-public-v1","_id":"6296648","_score":5.2751927,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"Consumer Protection Financial Bureau (CFPB)\n1700 G Street NW Washington, D.C. 20038 United States\nThis is to complain against the Truist Financial Corporation\nURGENCY: HIGH IMPORTANCE: HIGH\n[WITHOUT PREJUDICE]\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX, XXXX I wish to practice my right as a customer of Truist Financial Corporation to use your organisation's service, seeking a formal, impartial investigation to amicably settle my dispute XXXX XXXX XXXX with Truist Financial Corporation.\nIn order to clear up the myriad of letters and correspondences I have hitherto sent to Truist Financial Corporation respecting my complaint, I believe it will substantially strengthen both my case and your understanding, by taking a deeper look at the happenings of my case and analysing the relevant facts in an objective and comprehensive fashion.\nIt is crucial to note that I have been manipulated, socially engineered, and coerced to engage these fraudulent criminals. Much to my embarrassment, I recognize that I am the victim of an investment scam.\nMy complaint to the CFPB has arisen as I do not consider, by any stretch of the imagination, the conduct of Truist Financial Corporation to be commensurate with their legal role and responsibility to their customers. They sell a service to look after their customers, protect their money, and are a financial institution that maintains a traditional relationship and way of working with its customers.\nDuring the complaints process with Truist Financial Corporation, I found their communication ineffective, which further hides their conduct from management and diminishes the service offered to their clients. They are struggling to adapt their business offering in the ever-changing world of IT development. The internet is presenting a real problem that they choose to manage in a way that is not in line with the rules and regulations of CFPB as well as their own internal policy and procedures sold to their clients.\n\nGeneral Obligation:\nCommencing on or around XXXX XXXX XXXX, I fell victim to a multi-layered scam operation run by XXXX which involved me making deposits for a total amount of XXXX XXXX from my Truist Financial account to fraudulent investment firm.\nWhen determining whats reasonable and fair, we should focus on the issue of liability; common queries include, but are not limited to, the following (i) whether Truist Financial Corporation did not take notice of any rule, law, or regulation, and/or possibly missed any material elements of the relevant bylaws or codes of conduct, that may have prevented them from protecting my financial safety; (ii) whether by virtue of Truist Financial Corporations custodianship over my funds or by its control over them, they owed a fiduciary duty to the me and if so, whether that duty was breached; (iii) whether Truist Financial Corporation promoted the transaction(s) in question despite being aware of the nature of the transaction(s) in question (iv) whether Truist Financial Corporation was in compliance with its own policies and procedures; (v) whether Truist Financial Corporation owed duties to myself, what the scope of those duties was, and whether Truist Financial Corporation did not uphold those duties; (vi) whether Truist Financial Corporations conduct was unfair; and (vii) whether Truist Financial Corporation has within its power the ability to, and should, compensate me for the harm that has befallen me.\nUpon identification of such unusual or suspicious activity, it is crucial that the relevant staff member adequately describe the factors making an activity or transaction suspicious, thoroughly depict the extent and nature of this activity, and properly communicate to the customer that such activity meets the relevant criteria of fraud.\nIn providing its services to a customer, a financial institution is required by law to exercise the care and skill of a diligent, prudent banker. In this case, this means that the payment service provider should not turn a blind eye to known facts pointing to a real possibility that their customer is being scammed. In other words, Truist Financial Corporation must have had special knowledge of what was occurring or been alerted to a real possibility of fraud taking place. The financial institution must have known or reasonably ought to have known that I was dealing with a scammer.\nGranted, there is room for diversity of view insofar as reasonableness is concerned. Indeed, there is a sense in which the standard of care of the reasonable person involves in its application a subjective element.\nHowever, it must be remembered that the correct test is always reasonable care in all circumstances, not average care. The fact that most people behave in a certain way may be good evidence that the conduct is reasonable, but this is not necessarily the case. Although reasonableness is a very fluid concept, all of the evidence suggests that Truist Financial Corporation did not foresee the fraud and disregarded even the most obvious dangers in this respect.\nSituations do tend to repeat themselves and it is advisable to examine previous outcomes to see how the standard of the reasonable person should be applied, and that lessons can be learned from the errors of the past.\n \nTruist Financial Corporations Position:\nOn XXXX XXXX XXXX Truist Financial Corporation wrote in a letter: Based on our investigation, Truist denies your claim for reimbursement because our investigation reveals the activity/transaction(s) was authorized.\nOn XXXX XXXX XXXX, Truist Financial Corporation wrote in a letter: You have advised that you were a victim of fraud... The information was keyed according to the Outgoing Wire Transfer Request Agreement, which you confirmed and signed.\nRefuting Truist Financial Corporations arguments from a purely logical perspective:\nTruist Financial Corporations position is that the features of the situation at hand do not generate a genuine obligation to protect innocent and helpless victims; they are essentially arguing that common-sense-based approaches are doomed to fail, leaving their exclusively technical account of the subject matter as the only meaningful choice. For reasons which are unclear, this extremely serious situation barely gets the attention it deserves even though ample evidence has been offered in support of this complaint.\nIn Truist Financial Corporations view, it is implied that we should not home in (and consequently rely on) unwritten laws, practicality, good judgment, reasonableness, sharpness, sensibleness, past outcomes, and insight when taking appropriate precautions. To underscore, once again, such views are at odds with common sense and are wildly irresponsible.\nImagine a view according to which the one and only thing that can make Truist Financial Corporation morally obligated to do something is having it written down somewhere. Pursuant to this view, if Truist Financial Corporation encounters the suffering of totally naive victims, they are only obligated to intervene in or remedy the situation, to the degree required by written material. This is unbecoming for a reputable establishment such as Truist Financial Corporation.\nI have reviewed the material hereto sent by Truist Financial Corporation carefully, and it, unfortunately, provides no response to my fundamental argument concerning the degree of care. Given its size, influence, and the resources at its disposal, this establishment clearly had a far greater capacity than an individual such as myself had, to determine the level and likelihood of risk that a client such as myself is subjected to and had a duty to intervene as they now do to query in particular out-of-pattern transactions of this kind.\nIt is perfectly obvious that Truist Financial Corporation, inadvertently, employs a subtle approach in addressing some of the key questions in a manner that neither provides me with adequate support nor protects anything other than its own interests.\nIt is Truist Financial Corporation here, who has the burden of proof, to show that it has exercised the duty of care, that is to say, that Truist Financial Corporation adhered to a standard of reasonable care in relation to the matter at issue given its extensive experience compared to mine. It is Truist Financial Corporation that claims that the damages which I have suffered in connection to this matter have not been reasonably foreseeable and that my proposed degree of care is not, and has not been, commensurate with Truist Financial Corporations capacity, experience, expertise, or scope of services in any way. To re-emphasize, Truist Financial Corporations indisputable overriding purpose is by no means to purely execute transactions in a blind and blank fashion, but rather to strike a balance between executing those transactions\n \nand capitalizing on its undeniably vast capabilities to protect consumers thereby enhancing market integrity.\nApropos of the fluidity of the concept of reasonableness, all Truist Financial Corporation has done in this regard is set up a dichotomy of having or not having the legal obligation under consideration, however, that does not go one-inch toward explaining why various regulatory authorities, has maintained that financial institutions can, and should, protect consumers using their systems, advanced technologies, and rich experience.\nTruist Financial Corporation is obliged to take some action if it is sufficiently aware of a real possibility that fraud may be being perpetuated. If you don't question its customers instructions or raise the possibility of a scam with the customer in these circumstances, it may be liable if the red flags indicate the customer is:\n particularly vulnerable, or\n if the possibility of fraud was serious or real, not just suspected.\nThere are some recommendations to organizations for protecting customers from financial harm that might occur as a result of fraud or financial abuse; and gives guidance on how to recognize customers who might be at risk, how to assess the potential risks to the individual and how to take the necessary actions to prevent or minimize financial harm.\nThese recommendations are established as a general principle, the organization should deliver a service that:\n1) Takes a proactive approach to minimizing risks, impact, and incidences of financial harm and it sets out systems and tools for the prevention and detection of fraud and financial abuse. As a general point, it says organizations should ensure that all systems are developed using technologies and methodologies that are effective in the prevention of fraud and financial abuse, through authorized and unauthorized payments, thereby minimizing the risk of financial harm to customers. Regarding the detection of fraud and financial abuse, it says the organization:\nA) should have measures in place across all payment channels and products to detect suspicious transactions or activities that might indicate fraud or financial abuse. It then lists the following examples of suspicious activity on customer accounts:\na. multiple chequebooks;\nb. sudden increased spending;\nc. transfers to other accounts;\nd. multiple password attempts;\ne. logins from new devices, multiple geographical locations;\nf. sudden changes to the operation of the account; Unusual transactions are transactions whose amount, characteristics and frequency bear no relation\n \nto the economic activity of the customer, exceed normal market parameters or have no apparent legal justification.\ng. a withdrawal or payment for a large amount;\nh. a payment or series of payments to a new payee;\ni. financial activity that matches a known method of fraud or financial abuse.\nB) organizations should have a process in place to ensure that staff makes contact with the customer to verify the financial activity, challenge its authenticity, explain the nature of the suspected or detected fraud, and discuss an appropriate plan of action.\nTruist Financial Corporation is yet to show, or otherwise provide me with, a compelling argument that their wide-ranging experience and wealth of specialist knowledge in detecting transactional anomalies were not sufficient to avert the fraud at issue. By contrast, I have provided a multitude of sound and powerful reasons by which requiring their involvement has not only been pressingly relevant but also eminently reasonable and well-justified.\nRather than empathizing with and undertaking substantial efforts to convey their knowledge of the existence of such regulations abroad and thereafter use it to protect and proactively relieve the plight of consumers who have been cheated out of their money and whose role in society is properly fulfilled, positively contributing to local economic growth, development, and sustainability Truist Financial Corporation adopts a rather insouciant attitude toward my financial predicament portrayed herein.\nI am deeply convinced that the disastrous results that I have previously elaborated upon will continue to ensue if no responsibility is adopted by Truist Financial Corporation in relation to this matter. I have also thoroughly detailed why they cannot simply dismiss this problem by strictly adhering to legal technicalities which, after careful reflection, struck me as being nothing more than self-interest. Indeed, it seems to me utterly unfair to disregard fragile, sensitive, and vulnerable consumers who are afflicted by such allegedly malevolent acts, thereby keeping an unjust status quo that is corrupting our society at its core.\nConclusion:\nBased on my analysis, and as confirmed by various authorities concerned with such matters, there is abundant evidence that forward-thinking financial institutions ought to take reasonable steps to forestall fraud, or at least mitigate its risk by using an effective risk management system, demonstrating their undisputed ability to responsibly and pre-emptively respond to questionable transactions in the digital arena. The use of such systems, largely based on newly adopted technologies aimed at effectively navigating the evolving threat landscape, is only one of a number of possible endeavors undertaken in this connection, alongside the application of past knowledge and experience related to popular fraudulent practices.\nAstonishingly, I am pondering how it is that, despite being shown that Truist Financial Corporations business conduct was insufficient insofar as background checks are concerned, they keep refuting their indisputable role and responsibility in connection with the matter herein discussed. The points that I have hitherto made are too crucial to be taken lightly. Truist Financial Corporations non-observance of the fundamental principles of justice that is, to completely overlook and not even remotely try to mitigate the suffering of vulnerable\n \nconsumers is inexcusable given the size of the establishment and the vast resources at its disposal as the direct result of the patronage of clients like myself.\nIf it was, indeed, solely my responsibility, we must then believe at least one of the following clauses: a) financial institutions have absolutely no role whatsoever in preventing and detecting fraud, b) the fraud in question was not reasonably foreseeable, or c) the transactions in question were not sufficiently alarming. It is extremely unfortunate that Truist Financial Corporation pushes quite hard for me to believe all three of these thingsdespite evidence to the contrary.\nIn summary, I respectfully ask your organization to consider my points, given your personal and companywide obligation to provide a fair and reasonable investigation into the complaint.\nI look forward to your input and would gladly cooperate to reach a fair and reasonable outcome. Thank you.\nXXXX XXXX THE REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK\n \nPage 1 of 9\nXXXX XXXX XXXX\nTruist Financial XXXX XXXX XXXX XXXX XXXX, NC\nRe: Demand Letter\nAttn: Claims/Fraud Dept. Dear Sir/Madam,\nFor negotiation purposes only, without effect as to any and all rights\n The goal of this letter is twofold: first, it aims to establish that a duty of care has been breached, inasmuch as you have failed to perform adequate due diligence and/or have not acted in a reasonable and prudent manner to prevent foreseeable substantial damages that I have suffered as a result of a fraud [1]. Second, it shall serve as a formal written demand for reimbursement based on the aforementioned grounds, among others.\nA comprehensive analysis of fraud prevention suggests that by processing atypical, non-routine transactions, and/or by being aware of other fraudulent schemes similar to the one alleged herein and/or ignorance of obvious warning signs of fraud, you have engaged in, is a pattern or a practice of wrongful and negligent conduct which has enabled the commission of a fraud that resulted in my financial and psychological damages. The facts and details concerning the actions in question are set forth hereunder.\nOVERVIEW\n Commencing on or about XXXX XXXX XXXX, I fell victim to a multilayered scam operation orchestrated by XXXX (the Company), with the design, development, manufacture, promoting, marketing, distribution, labeling, and/or sale of illegal and outright fraudulent investment services,\" all of which aim at contributing to the goal of robbing and defrauding clients, through a predetermined cycle of client losses to gains.\n Money was transferred from my account via bank wire, credit card, debit card and through intermediaries named \"XXXX XXXX in the total amount of XXXX XXXX utilizing your services.\n1 FCA: A more effective approach to combatting financial crime (XXXX XXXX XXXX) 1\n \nPage 2 of XXXX XXXX XXXX XXXX\n Additionally, it is vital that you will immediately take all actions within your power to remedy the situation, whether by raising chargeback and recall in respect of the transactions in question or reimburse me and credit my account, for the full amount of these payments, in the total amount of XXXXusd!\n This letter shall thrust into the spotlight, inter alia, the increasingly important role financial institutions play in the fight against financial crime and fraud, and the pressing need for higher levels of supervision and vigilance within your organization.\n Had you looked at the wider circumstances surrounding the above-referenced transactions, this illicit transfer of wealth could have been prevented.\n Executing transactions without proper authority is not only a severe regulatory offense but also an irresponsible and reckless disregard of the customers financial safety.\n Against this background, and without derogating any of my rights, I hereby hold you liable for financial and emotional harm, and insist that you reimburse my account in full within 14 days from the date of this letter.\nINTRODUCTION\nFinancial crimes and fraud investigations often involve a high degree of sophistication, complexity, and sensitiveness to detail. Accordingly, this letter aims to address the issue at hand as profoundly and fairly as possible, by taking into consideration contextual regulations, laws, and bylaws, as well as guidance, standards and rules promoted by supervisory authorities, relevant codes of practice and (where suitable) what was good industry practice (GIP) at all times relevant hereto. The allegations contained herein are predicated either upon knowledge with respect to myself and my own experience, or upon facts obtained through investigations conducted by qualified third parties. I strongly believe that substantive evidence in support of the allegations set forth herein will be found after an appropriate opportunity for discovery. Key facts supporting the allegations contained herein are known only to the Company and/or are exclusively within their control.\nThe Company cleverly orchestrated a prevalent scheme of deception to lead people to invest significant sums while knowing that those would-be investors would ultimately lose the money that they had entrusted to it. The overall purpose of the scheme, in other words, was to target and defraud people who are often inexperienced and naive, in pursuit of illicit wealth through various fraudulent representations.\nI did not know, and through the exercise of reasonable diligence could not have discovered the fraud that was being perpetrated upon me by the Company. Fraud is commonly conceptualized as\n 2\n\nPage 3 of 9 XXXX XXXX XXXX\nwithholding from the weaker party in a financial transaction (e.g., an investor) information which is necessary to make an informed, rational or autonomous decision.\nIn this regard, even access to adequate information is insufficient to achieve complete autonomy. A complication here is that the weaker party, amateur/unseasoned investors in particular, might have trouble analyzing the data at hand sufficiently well to identify fraudulent schemes. Unfortunately, because financial products are often abstract and complex, theres no easy solution to this problem. Therefore, full autonomy of investors might not only require access to sufficient information, but also access to relevant technologies, know-how, processing capabilities, and resources to analyze the information. A reasonable solution is that financial institutions would be required to promote transparent communication in which they track the understanding of their customers.\nThe false representations and omissions made by the Company have a tendency or capacity to deceive consumers, such as myself, into unwittingly providing funds that fueled the Companys fraudulent scheme and therefore by their nature are jointly immoral, unethical, oppressive, unscrupulous, and substantially injurious to consumers.\nAs a result of the Companys deceptive trade practices, I was deceived into transferring my funds for investment returns that were never delivered. I will certainly never receive any monetary value for the investments considering the way the Company had their scheme rigged thus causing significant economic damage to me. The false statements of material facts and omissions; and the fraudulent transactions the Company perpetrated were unfair, unconscionable, and deceptive practices perpetrated which would have likely deceived any reasonable person under the circumstances.\nMERCHANTS FRAUD SCHEME ALLEGATIONS\nThe Company hired, managed and trained personnel, and collaborated with others as accomplices to their crimes to induce fraud that resulted in my financial and psychological damages. These include, but are not limited to, the following allegations, all of which involve criminal, non-regulated, and malicious activities:\n1. The Company directed and instructed others to work from shell companies that were operating from various unassociated locations across the globe.\n2. The Company opened bank accounts and crypto currency wallets in multiple countries and used them through their accomplices from around the world to conceal and disguise the identity of illegally obtained proceeds so that they appear to have originated through\n 3\n\nPage 4 of 9 XXXX XXXX XXXX\nlegitimate sources.\n3. The Company intentionally committed fraudulent misrepresentation, and falsified its agent\nnames, credentials, competencies, qualifications and location. The Companys name is merely a brand name, officially owned by shell corporations located offshore. In reality, the entire operation is being conducted from elsewhere (supposed location is evidently fictitious), and furthermore, the call center, marketing, and decision making, are all being performed by completely anonymous and hidden entities. Concealing true identities and utilizing front companies as a vehicle for a wide spectrum of financial maneuvers, is a notorious practice of criminal organizations.\n4. The Company has blatantly violated international laws, as it has been practicing without a license and funneling enormous sums of money, through countries and jurisdictions that require registration to operate.\n5. The Company provided direct investment advice - not utilizing 3rd party recommendations (e.g., according to XXXX XXXX)\n6. The Company offered investment services/advice not related to real market/exchange data (e.g.: the manufacture of false charts). The trading platform was purposely manipulated, in a way that each client would ineluctably and unknowingly lose money, as the existence of the trades was fabricated. Instead, the Companys staff and its accomplices simply pocketed the money, using it to purchase various luxurious, non- essential items.\n7. The Company prohibited my ability to withdraw my funds.\n8. The Company was guaranteeing unrealistic returns/yields.\n9. The Company furnished me with bonuses - which are not allowed to be given.\n10. The Company was trading on my behalf (use of remote control of my computer).\n11. My money was not held in a segregated account.\n12. The Company did not advertise/disclose/was not transparent regarding the statistical data\nrepresenting the percentage of total client losses at the company.\n13. The Company did not mention the commission and overnight swaps.\n14. The Company did not read me the risk disclosure prior to my deposit(s).\n15. The Company used high pressure tactics and outbursts, which took a severe toll on my\nhealth.\n4\n\nPage 5 of 9 XXXX XXXX XXXX\nArmed with my personal details, the Companys staff seduced me, until I transferred all my savings to them. They utilized their knowledge of my cultural context, which stressed square and honorable business dealings along with honesty, to maliciously take advantage of my trusting nature.\nPlease take notice that my funds were transferred through means of coercion and under false pretenses.\nAttached, please find supportive statements, screenshots and further evidence.\nEXPOSING YOUR ORGANIZATIONS MISCONDUCT\nI hereby allege that your organization has breached the duty of care that is owed by a financial institution to its clients in circumstances where there are reasonable grounds to suspect that the sole purpose of a payment instruction is to defraud the client. Under such circumstances, you are obliged to refrain from executing the payment instruction until you have been able to conclude that there is a legitimate basis for the instruction. Once the duty is engaged, the duty takes priority over the usual obligation of a financial institution to execute customer instructions promptly. The duty in question is often referred to as the XXXX XXXX well established in the case of XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX).\nThe XXXX XXXX requires financial institutions to take reasonable care and skill when executing the instructions of a client. It is recognized as authoritative by leading academic texts [2]. The duty arises in cases where it can be argued that an ordinary prudent staff member of a financial institution would have a reasonable basis for suspicion that a particular payment instruction would result in the misappropriation of the funds of the client.\"\nWhen the duty does arise, it can be discharged simply by refraining from executing the instruction unless and until such time as the financial institution is able to establish that the instruction relates to a lawful obligation. The financial institution should seek further information and/or documentation from the client in order to help establish this.\nBased on the above, and after conducting a comprehensive review of our communication/interactions, it has become glaringly obvious to me that at best, no adequate\n2 (XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX)\n 5\n\nPage 6 of 9 JXXXX XXXX XXXX\ninformation and/or documentation were sought by your organization, and at worst, no appropriate safeguards were implemented.\nIf a financial institution executed a customers order to transfer money knowing it to be dishonestly given, shutting its eyes to the obvious fact of the dishonesty or acting recklessly in failing to make such inquiries as an honest and reasonable individual would make,\" it would be in breach of its duty of care, even if the payment instruction is made in accordance with the terms of the mandate and the bank is liable for negligence resulting in damages.\nCompliance departments should ensure that staff members understand the legal requirements and that where there are suspicions, these suspicions must be communicated to all relevant personnel whilst being investigated.\nFor the avoidance of doubt, reasonable grounds should not necessarily be interpreted as proof. On the basis of various signs, you should have assumed that something suspicious was going on and suspended transactions until reasonable enquiries could be made to verify that the transactions were properly executed. In other words, I am a victim of your negligence for facilitating the misappropriation of funds, and doing little to safeguard public financial interests. Any reasonable banker would have realized that there were many obvious, even glaring, signs that I am a fraud victim. (XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX [3].\nA financial institution would never be as reckless with its own assets as has been the case with my assets, and if you had treated my assets as though they were your own, this would not have been made possible. The debits made from my account should be reversed as a result of your failure to take proactive measures to protect it, just as you would do if your own assets were in a similar state of peril. It is also libelous/defamatory to make false statements about an individual that adversely affects their credit rating.\nWhen discussing the responsibilities that a bank might incur, it is crucial not to forget the fact that a legitimate complaint by, or cause of action on the part of a client might generate/give rise to further statutory cause of action and/or additional liabilities beholden by a financial institution to the relevant regulatory authority. Obligations/duties beholden by a bank to a regulator are distinct from those beholden to the customer. Moreover, you may be liable to more than one regulatoXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX More often than not, such legal duties spring from the very facts that gave rise to the liabilities to your clients in the first place. Similarly, to the foregoing, I may also have a cause of action against you for breach of mandate as you have negligently transferred my funds without proper enquiry.\nInstead, you should have been working hard with Artificial Intelligence [4] / Big data technologies to discover automated and effective ways not only to detect fraud but also to prevent it. Furthermore, the tremendous amount of data you possess is by no means self-evident let alone to be overlooked, hence by not utilizing it systematically and effectively to pinpoint irregular and suspicious activities you are misleading your customers, who have taken the leap of faith and placed trust and confidence in your honesty, authority, and competence. A plausible assumption here would be that the pattern of the above-mentioned transactions was sufficiently suspicious that it should have been flagged and blocked by your staff, even if you have never encountered similar situations.\nPractically speaking, effective steps to prevent bad actors from taking advantage of future victims (or at least to minimize this possibility) are abundant:\n The use of automated and human review of","date_sent_to_company":"2022-12-20T18:39:13.000Z","issue":"Fraud or scam","sub_product":"Virtual currency","zip_code":"29681","tags":null,"has_narrative":true,"complaint_id":"6296648","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"TRUIST FINANCIAL CORPORATION","date_received":"2022-12-08T23:55:35.000Z","state":"SC","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":null},"highlight":{"complaint_what_happened":["The facts and details concerning the actions in question are set forth hereunder."]},"sort":[5.2751927,"6296648"]},{"_index":"complaint-public-v1","_id":"10981005","_score":4.6833386,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"XXXX XXXX XXXX XXXX XXXX XXXX\nConsumer Financial Protection Bureau (CFPB)\nXXXX XXXX XXXX XXXX XXXX, DC XXXX\nThis is to complain against RIA XXXX: HIGH\nIMPORTANCE: HIGH\n[WITHOUT PREJUDICE]\nI wish to practice my right as a customer of RIA to use your organisation's service, seeking a formal,\nimpartial investigation to amicably settle my dispute with RIA.\nIn order to clear up the myriad of letters and correspondences I have hitherto sent to RIA respecting my\ncomplaint, I believe it will substantially strengthen both my case and your understanding, by taking a\ndeeper look at the happenings of my case, and analysing the relevant facts in an objective and\ncomprehensive fashion.\nIt is crucial to note that I have been manipulated, socially-engineered and coerced to engage these\nfraudulent criminals. Much to my embarrassment, I recognise that I am the victim of an investment scam.\nMy complaint to the CFPB has arisen as I do not consider, by any stretch of the imagination, the conduct\nof RIA to be commensurate with their legal role and responsibility to their customers. They sell a service\nto look after their customers, protect their money and are a financial institution that maintains a traditional\nrelationship and way of working with its customers.\nDuring the complaints process with RIA, I found their communication ineffective, which further hides\ntheir conduct to management and diminishes the service offering to their clients. They are struggling to\nadapt their business offering in the ever-changing world of IT development. The internet is presenting a\nreal problem which they choose to manage in a way which is not in line with rules and regulations of\nCFPB as well as their own internal policy and procedures sold to their clients.\nGeneral Obligation:\nCommencing on XXXX XXXX, I fell victim to a multilayered scam operation orchestrated by XXXX XXXX (the Fraudsters or Company).\nMoney was transferred from my account in the total amount of XXXX XXXX.\nWhen determining whats reasonable and fair, we should focus on the issue of liability; common queries\ninclude, but are not limited to, the following (i)\nwhether RIA did not take notice of any rule, law, or regulation, and/or possibly missed any material\nelements of the relevant bylaws or codes of conduct, that may have prevented them from protecting my\nfinancial safety; (ii) whether by virtue of RIAs custodianship over my funds or by its control over them,\nthey owed a fiduciary duty to the me and if so, whether that duty was breached; (iii) whether RIA\npromoted the transaction(s) in question despite being aware of the nature of the transaction(s) in question\n(iv) whether RIA was in compliance with its own policies and procedures; (v) whether RIA owed duties\nto myself, what the scope of those duties was, and whether RIA did not uphold those duties; (vi) whether\nRIAs conduct was unfair; and (vii) whether RIA has within its power the ability to, and should,\ncompensate me for the harm that has befallen me.\nUpon identification of such unusual or suspicious activity, it is crucial that the relevant staff member\nadequately describe the factors making an activity or transaction suspicious, thoroughly depict the extent\nand nature of this activity and properly communicate to the customer that such activity meets the relevant\ncriteria of fraud.\nIn providing its services to a customer, a financial institution is required by law to exercise the care and\nskill of a diligent, prudent banker. In this case, this means that the payment service provider should not\nturn a blind eye to known facts pointing to a real possibility that their customer is being scammed. In\nother words, RIA must have had special knowledge of what was occurring or been alerted to a real\npossibility of fraud taking place. The financial institution must have known or reasonably ought to have\nknown that I was dealing with a scammer.\nGranted, there is room for diversity of view insofar as reasonableness is concerned. Indeed, there is a\nsense in which the standard of care of the reasonable person involves in its application a subjective\nelement.\nHowever, it must be remembered that the correct test is always reasonable care in all circumstances, not\naverage care. The fact that most people behave in a certain way may be good evidence that the conduct is\nreasonable, but this is not necessarily the case. Although reasonableness is a very fluid concept, all of\nthe evidence suggests that RIA did not foresee the fraud and disregarded even the most obvious dangers\nin this respect.\nSituations do tend to repeat themselves and it is advisable to examine previous outcomes to see how the\nstandard of the reasonable person should be applied, and that lessons can be learnt from the errors of the\npast.\nRIAs Position:\nPlease find attached all relevant evidence below.\nRIA conspicuously touts their security as a reason to use their service. Specifically, RIA writes on\ntheir website:\nWe work hard to protect you from fraud. That's why we:\n Apply best-in-class security technologies expertise to protect you 24/7, all year round.\n Secure every method of banking we offer including online, mobile, ATM and telephone\nbanking.\n Offer free security software from our trusted tech partners to download on to your devices.\n Frequently train our employees on the latest practices in cyber and physical security.\n Give you the security tips and resources you need to protect yourself from potential threats.\nRefuting RIAs arguments from a purely logical perspective:\nRIAs position is that the features of the situation at hand do not generate a genuine obligation to protect\ninnocent and helpless victims; they are essentially arguing that common-sense-based approaches are\ndoomed to fail, leaving their exclusively technical account of the subject matter as the only meaningful\nchoice. For reasons which are unclear, this extremely serious situation barely gets the attention it deserves\neven though ample evidence has been offered in support of this complaint.\nIn RIAs view, it is implied that we should not home in (and consequently rely) on unwritten laws,\npracticality, good judgement, reasonableness, sharpness, sensibleness, past outcomes, and insight, when\ntaking appropriate precautions. To underscore, once again, such views are at odds with common sense\nand are wildly irresponsible.\nImagine a view according to which the one and only thing that can make RIA morally obligated to do\nsomething is having it written down somewhere. Pursuant to this view, if RIA encounter the suffering of\ntotally naive victims, they are only obligated to intervene in or remedy the situation, to the degree\nrequired by written material. This is unbecoming for a reputable establishment such as RIA.\nI have reviewed the material hereto sent by RIA carefully, and it unfortunately provides no response to\nmy fundamental argument concerning the degree of care. Given its size, influence, and the resources at its\ndisposal, this establishment clearly had a far greater capacity than an individual such as myself had, to\ndetermine the level and likelihood of risk that a client such as myself is subjected to and had a duty to\nintervene as they now do to query in particular out-of-pattern transactions of this kind.\nIt is perfectly obvious that RIA, inadvertently, employs a subtle approach in addressing some of the key\nquestions in a manner which neither provides me with adequate support nor protects anything other than\nits own interests.\nIt is RIA here, who has the burden of proof, to show that it has exercised the duty of care, that is to say,\nthat RIA adhered to a standard of reasonable care in relation to the matter at issue given its extensive\nexperience compared to mine. It is RIA that claims that the damages which I have suffered in connection\nto this matter have not been reasonably foreseeable, and that my proposed degree of care is not, and has\nnot been, commensurate with RIAs capacity, experience, expertise, or scope of services in any way. To\nreemphasize, RIAs indisputable overriding purpose is by no means to purely execute transactions in a\nblind and blank fashion, but rather to strike a balance between executing those transactions and\ncapitalising on its undeniably vast capabilities to protect consumers thereby enhancing market integrity.\nApropos of the fluidity of the concept of reasonableness, all RIA has done in this regard is set up a\ndichotomy of having or not having the legal obligation under consideration, however, that does not go\none-inch toward explaining why various regulatory authorities, has maintained that financial institutions\ncan, and should, protect consumers using their systems, advanced technologies, and rich experience.\nRIA is obliged to take some action if it is sufficiently aware of a real possibility that a fraud may be being\nperpetuated. If you don't question its customers instructions or raise the possibility of a scam with the\ncustomer in these circumstances, it may be liable if the red flags indicate the customer is:\n particularly vulnerable, or\n if the possibility of fraud was serious or real, not just suspected.\nThere are some recommendations to organisations for protecting customers from financial harm that\nmight occur as a result of fraud or financial abuse; and gives guidance on how to recognise customers\nwho might be at risk, how to assess the potential risks to the individual and how to take the necessary\nactions to prevent or minimise financial harm.\nThese recommendations are established as a general principle, the organisation should deliver a\nservice that:\n1) Takes a proactive approach to minimising risks, impact and incidences of financial harm and it\nsets out systems and tools for the prevention and detection of fraud and financial abuse. As a general\npoint, it says organisations should ensure that all systems are developed using technologies and\nmethodologies that are effective in the prevention of fraud and financial abuse, through authorised\nand unauthorised payments, thereby minimising the risk of financial harm to customers. As regards to\nthe detection of fraud and financial abuse, it says the organisation:\nA) should have measures in place across all payment channels and products to detect suspicious\ntransactions or activities that might indicate fraud or financial abuse. It then lists the following\nexamples of suspicious activity on customer accounts:\na. multiple cheque books;\nb. sudden increased spending;\nc. transfers to other accounts;\nd. multiple password attempts;\ne. logins from new devices, multiple geographical locations;\nf. sudden changes to the operation of the account; Unusual transactions are\ntransactions whose amount, characteristics and frequency bear no relation to the\neconomic activity of the customer, exceed normal market parameters or have no\napparent legal justification.\ng. a withdrawal or payment for a large amount;\nh. a payment or series of payments to a new payee;\ni. financial activity that matches a known method of fraud or financial abuse.\nB) organisations should have a process in place to ensure that staff make contact with the\ncustomer to verify the financial activity, challenge its authenticity, explain the nature of the\nsuspected or detected fraud and discuss an appropriate plan of action.\nRIA are yet to show, or otherwise provide me with, a compelling argument that their wide-ranging\nexperience and wealth of specialist knowledge in detecting transactional anomalies were not sufficient to\navert the fraud at issue. By contrast, I have provided a multitude of sound and powerful reasons by which\nrequiring their involvement has not only been pressingly relevant but also eminently reasonable and welljustified.\nRather than empathising with and undertaking substantial efforts to convey their knowledge of the\nexistence of such regulations abroad and thereafter use it to protect and proactively relieve the plight of\nconsumers who have been cheated out of their money and whose role in society is properly fulfilled,\npositively contributing to local economic growth, development and sustainability RIA adopts a rather\ninsouciant attitude toward my financial predicament portrayed herein.\nI am deeply convinced that the disastrous results that I have previously elaborated upon will continue to\nensue if no responsibility is adopted by RIA in relation to this matter. I have also thoroughly detailed why\nthey cannot simply dismiss this problem by strictly adhering to legal technicalities which, after careful\nreflection, struck me as being nothing more than self-interest. Indeed, it seems to me utterly unfair to\ndisregard fragile, sensitive, and vulnerable consumers who are afflicted by such allegedly malevolent acts,\nthereby keeping an unjust status-quo that is corrupting our society at its core.\nConclusion:\nBased on my analysis, and as confirmed by various authorities concerned with such matters, there is\nabundant evidence that forward-thinking financial institutions ought to take reasonable steps to forestall\nfraud, or at least mitigate its risk by using an effective risk management system, demonstrating their\nundisputed ability to responsibly and pre-emptively respond to questionable transactions in the digital\narena. The use of such systems, largely based on newly adopted technologies aimed at effectively\nnavigating the evolving threat landscape, is only one of a number of possible endeavours undertaken in\nthis connection, alongside the application of past knowledge and experience related to popular fraudulent\npractices.\nAstonishingly, I am pondering how it is that, despite being shown that RIAs business conduct was\ninsufficient insofar as background checks are concerned, they keep refuting their indisputable role and\nresponsibility in connection with the matter herein discussed. The points that I have hitherto made are too\ncrucial to be taken lightly. RIAs non-observance of the fundamental principles of justice that is, to\ncompletely overlook and not even remotely try to mitigate the suffering of vulnerable consumers is\ninexcusable given the size of the establishment and the vast resources at its disposal as the direct result of\nthe patronage of clients like myself.\nIf it was, indeed, solely my responsibility, we must then believe at least one of the following clauses: a)\nfinancial institutions have absolutely no role whatsoever in preventing and detecting fraud, b) the fraud in\nquestion was not reasonably foreseeable, or c) the transactions in question were not sufficiently alarming.\nIt is extremely unfortunate that RIA pushes quite hard for me to believe all three of these thingsdespite\nevidence to the contrary.\nIn summary, I respectively ask your organisation to consider my points, given your personal and\ncompanywide obligation to provide a fair and reasonable investigation into the complaint.\nI look forward to your input and would gladly cooperate to reach a fair and reasonable outcome.\nThank you. XXXX XXXX XXXX\nXXXX THE REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK\nXXXX XXXX XXXX\nTo: RIA\nXXXX XXXX, California , United States\nVia Email\n[Without Prejudice]\nAttn: Complaints/Fraud Dept.\nDear Sir or Madam,\nRe: Demand Letter Fraud\nI hope this letter has correctly found itself within your complaints/fraud department as it is essential to me that\nyou become aware of the ordeal I have had to go through.\nCommencing on XXXX XXXX I fell victim to a multilayered scam operation orchestrated by XXXX XXXX (the Fraudsters or Company) with the design, development, manufacturing, promoting,\nmarketing, distributing, labeling, and/or sale of illegal and outright fraudulent investment services, all of\nwhich aim at contributing to the goal of robbing and defrauding clients through a predetermined cycle of the\nclient losses to gains.\nMoney was transferred from my account in the total amount of XXXX XXXX utilizing your services.\nOVERVIEW\n This letter shall thrust into the spotlight, inter alia, the increasingly important role those financial\ninstitutions play in the fight against financial crime and fraud, and the pressing need for enhanced\nsupervision and vigilance within your organization.\n Heres an indisputable fact: had you looked at the wider circumstances surrounding the abovereferenced\ntransaction(s), this illicit transfer of wealth could have been prevented.\n Obviously, there is no consensus with respect to the degree and scope to which regulated and licensed\nfinancial institutions must intervene and block suspicious transactions, and indeed, in so doing,\nfinancial institutions may often cause payments to be slowed down unnecessarily or even some\nlegitimate payments may be rejected, however, please be noted that additional frictions such as slower\npayments (such as delaying payments or freezing funds to investigate) is beneficial to and welcomed\nby vulnerable customers and is widely considered to be a positive practice that is necessary in order to\nmaintain their financial safety, particularly for large-value and/or out of pattern.\n Executing transactions without proper authority is not only a severe regulatory offense but also an\nirresponsible and reckless disregard of the customers financial safety.\n Against this background, and without derogating any of my rights, I hereby hold you liable for\nfinancial and emotional harm as well as medical problems relating to this victimization and insist that\nyou reimburse my account in full within 14 days from the date of this letter.\nINTRODUCTION\nFinancial crimes and fraud investigations often involve a high degree of sophistication, complexity, and\nsensitiveness to detail. Accordingly, this letter aims to address the issue at hand as profoundly and fairly as\npossible, by taking into consideration contextual regulations, laws, and bylaws, as well as guidance, standards\nand rules promoted by supervisory authorities, relevant codes of practice and (where suitable) what was good\nindustry practice (GIP) at all times relevant hereto. The allegations contained herein are predicated either\nupon knowledge with respect to myself and my own experience, or upon facts obtained through investigations\nconducted by qualified third parties. I strongly believe that substantive evidence in support of the allegations\nset forth herein will be found after an appropriate opportunity for discovery. Key facts supporting the\nallegations contained herein are known only to the Company and/or are exclusively within their control.\nThe Company cleverly orchestrated a prevalent scheme of deception to lead people to invest significant sums\nwhile knowing that those would-be investors would ultimately lose the money, they had entrusted to it. The\noverall purpose of the scheme, in other words, was to target and defraud people who are often inexperienced\nand naive, in pursuance of illicit wealth through various fraudulent representations.\nI did not know, and through the exercise of reasonable diligence could not have discovered, the fraud\nthat was being perpetrated upon me by the Company. Fraud is commonly conceptualized as withholding\nfrom the weaker party in a financial transaction (e.g., an investor) information which is necessary to make an\ninformed, rational or autonomous decision.\nIn this regard, even access to adequate information is insufficient to achieve complete autonomy. A\ncomplication here is that the weaker party, amateur/unseasoned investors in particular, might have trouble\nanalyzing the data at hand sufficiently well to identify fraudulent schemes. Unfortunately, because financial\nproducts are often abstract and complex, there is no easy solution to this problem. Therefore, full autonomy of\ninvestors might not only require access to sufficient information, but also access to relevant technologies,\nknow-how, processing capabilities, and resources to analyze the information. A reasonable solution is that\nfinancial institutions would be required to promote transparent communication in which they track the\nunderstanding of its customers.\nAccording to the Federal Trade Commissions interpretations of certain terms (like the words deceptive and\nunfair), the FTC has found that a deceptive act or practice encompasses a representation, omission or\npractice that is likely to mislead the consumer acting reasonably in the circumstances, to the consumers\ndetriment.\nThe federal courts have defined a deceptive trade practice [i] as any act or practice that has the tendency or\ncapacity to deceive consumers and have defined an unfair trade practice as any act or practice that offends\npublic policy and is immoral, unethical, oppressive, unscrupulous, or substantially injurious to consumers.\nThe false representations and omissions made by the Company have a tendency or capacity to deceive\nconsumers, such as myself, into unwittingly providing funds that fueled the Companys fraudulent scheme\nand are therefore, by their very nature, jointly immoral, unethical, oppressive, unscrupulous, and\nsubstantially injurious to consumers.\nAs a result of the Companys deceptive trade practices, I was deceived into transferring my funds for\ninvestment returns that were never delivered. I will certainly never receive any monetary value for the\ninvestments considering the way the Company had their scheme rigged, thus causing significant economic\ndamage to me. The false statements of material facts and omissions as described above; and the fraudulent\ntransaction(s) the Company perpetrated upon me; were unfair, unconscionable, and deceptive practices which\nwould have likely deceived any reasonable person under the circumstances.\nMERCHANTS FRAUD SCHEME ALLEGATIONS\nThe Company hired, managed, and trained personnel, and collaborated with others as accomplices to\ntheir crimes to induce fraud that resulted in my financial and psychological damages. These include,\nbut are not limited to, the following allegations, all of which involve criminal, non-regulated, and\nmalicious activities:\n1. The Company directed and instructed others to work from shell companies that were operating\nfrom various unassociated locations across the globe.\n2. The Company opened bank accounts in multiple countries and used them through their\naccomplices and strawmen from around the world to conceal and disguise the identity of\nillegally obtained proceeds so that they appear to have originated from legitimate sources.\n3. The Company intentionally committed fraudulent misrepresentation, and falsified its agent names,\ncredentials, competencies, qualifications and location. The Companys name is merely a brand name,\nofficially owned by shell corporations located offshore. In reality, the entire operation is being\nconducted from elsewhere (supposed location is evidently fictitious), and on top of that the call center,\nmarketing, and decision making, are all being performed by completely anonymous and hidden\nentities. Concealing true identities and utilizing front companies as a vehicle for a wide spectrum\nof financial maneuvers is a notorious practice of criminal organizations.\n4. The Company has blatantly violated international laws, as it has been practicing without a\nlicense and funneling enormous sums of money, through countries and jurisdictions that require\nregistration to operate.\n5. The Company provided direct investment advice - not utilizing 3rd party recommendations (e.g.,\naccording to Bloomberg TV/Investing.com)\n6. The Company offered investment services/advice not related to real market/exchange data\n(manufacturing false charts etc.). The trading platform was purposely manipulated, in a way that\neach client would ineluctably and unknowingly lose money, as the trades were simply\nconcocted. Instead, the Companys staff and its accomplices simply pocketed the money, using\nit to purchase various luxurious, non-essential items.\n7. The Company prohibited my ability to withdraw my funds.\n8. The Company was guaranteeing returns/yields (unrealistic ones).\n9. The Company furnished me with bonuses - which are not allowed to be given.\n10. My money was not held in a segregated account.\n11. The Company did not advertise/disclose/was not transparent regarding the statistical data representing\nthe percentage of total client losses at the company.\n12. The Company did not mention the commission and overnight swaps.\n13. The Company did not read the risk disclosure prior to my deposit(s).\n14. The Company used high pressure tactics and outbursts, which took a severe toll on my health.\n15. Armed with my personal details, the Companys staff seduced me into transferring all of my\nsavings to them. They utilized their knowledge of my cultural context, which stressed square\nand honorable business dealings along with honesty, in order to maliciously take advantage of\nmy trusting nature.\nPlease take notice that my funds were transferred through means of coercion and under false pretenses.\nAttached, please find supportive statements, screenshots, and further evidence.\nEXPOSING YOUR ORGANIZATIONS MISCONDUCT\nI hereby allege that your organization has completely failed to adequately investigate the circumstances\nsurrounding the transaction(s) in question and willfully blinded itself to obvious red flags.\nMany suspicions should have arisen at your organization as an issue of great concern, with respect to the\nunusual activity taking place in my account. Despite the regulatory and statutory requirements your\norganization should abide by as a licensed and regulated financial institution and instead of detecting\npatterns, drawing certain conclusions, and taking actions accordingly you at best, merely and insufficiently\nperformed some hasty and haphazard reviews of the transaction(s) or possibly asked only minimal generic\nquestions regarding the suspicious activities, and at worst, shut your eyes completely rather than being careful,\nmethodical, and vigilant. Had you bothered, you would probably have realized that the funds were associated\nwith fraud and financial crime, rather than some other legitimate revenue/activity.\nIn light of the above, and after conducting a comprehensive review of our communication/interactions,\nit has become glaringly obvious to me that no adequate information and/or documentation were sought\nby your organization, at best, and at worst no appropriate safeguards were implemented.\nIf a financial institution executes a customer order to transfer money knowing it to be dishonestly given,\nshutting its eyes to the obvious fact of the dishonesty, or acting recklessly in failing to make such inquiries as\nan honest and reasonable individual would undergo, it would be in breach of its duty of care, even if the\npayment was made in accordance with the terms of the mandate, and the financial institution should still be\nliable for negligence resulting in damages.\nCompliance departments should ensure that staff members understand the legal requirements and where there\nare suspicions, these suspicions be communicated to all relevant personnel whilst being investigated.\nFor the avoidance of doubt, reasonable grounds should not necessarily be interpreted as proof. On the basis of\nvarious signs, you should have assumed that something suspicious was going on therefore should have\nsuspended transaction(s) until reasonable enquiries could be made to verify that the transaction(s)\nwas/were properly executed. In other words, I am a victim of your negligence for facilitating the\nmisappropriation of funds, and doing little to safeguard public financial interests. Any reasonable staff\nmember would have realized that there were many obvious, even glaring, signs that I was being defrauded.\n(XXXX XXXX XXXX (in liquidation) v XXXX XXXX XXXX XXXX XXXX [XXXX] XXXX XXXX) [ii]\nYou knew or should have known that the funds being transferred through your services did not rightfully\nbelong to the recipient fraudsters. Similarly, you knew or should have known that the funds being transferred\nthrough your services serve no legitimate or lawful purpose. You turned a blind eye to the crimes that you\nhave facilitated and thus provided an array of essential money transfer services, acting as a vehicle, with the\nawareness that it was enabling the fraudsters to commit crimes and enrich themselves with the funds of their\nvictims.\nYour services undoubtedly served as a crucial element in the fraudulent scheme detailed herein, and you were\neither unaware of your complicity in the fraud, or, more worryingly, completely aware and silent. Had you\nconducted an adequate account analysis, you would have discovered the nature of the recipient, and\nsubsequently, disclosed and reported the fraudsters activities to law enforcement authorities/agencies and\nregulators. Instead, to satisfy your financial interests, you conveniently closed your eyes, even though you\nundeniably had, at all material times, the necessary controls and resources to influence, whether directly or\nindirectly, those particular transactions.\nYou also had the duty to stop those crimes, yet you refused to do so because you were more interested in\nenriching yourself, even if it meant furthering those crimes and allowing them to cause massive financial\nlosses to plenty of victims many of whom are probably your customers. Therefore, it is clear that you did\nnot have in place adequate security measures to properly safeguard my assets hence, you have\nirreparably harmed me and, if not enjoined, will continue to irreparably harm other victims as well as\ntheir loved\nones and associates. You have irreparably harmed me and, if not enjoined, will continue to irreparably\nharm the general public, and our society deserves better.\nA financial institution which wrongly pays money away when it has no authority to do so will usually be\ntreated as if it had paid using its own funds, not those of its customer.\nWhen discussing the responsibilities that a financial institution might incur, it is crucial not to forget the fact\nthat a legitimate complaint by, or cause of action on the part of, a client might generate/give rise to further\nstatutory cause of action and/or additional liabilities beholden by a financial institution to the relevant\nregulatory authority. Obligations/duties beholden by a financial institution to a regulator are distinct from\nthose beholden to the customer. Moreover, you may be held liable to more than one regulator.\nAs a regulated and licensed financial institution, you have strict statutory and regulatory obligations to\nmonitor transactions and report any suspicious activities to law enforcement authorities. The importance of\nimplementing robust internal systems to detect and report money laundering and other suspicious activities\nhas been continuously emphasized in the industry in addition to having the appropriate policies, procedures\nand internal controls in place to ensure ongoing compliance in respect to the aforementioned systems. You\nshould have analysed and distinguished thereafter between that which may be normal activity and that which\ncould suggest an illegal activity. This is a well-known standard industry practice which plays a substantial role\nin preventing criminals from liquidating and laundering funds.\nFRAUD\nActual fraud can be described, inter alia, as suppression of that which is true, by one having knowledge or\nbelief of the fact. Therefore, due to your actual knowledge that such scams are so prevalent, you are liable for\ndamages. Similarly, due to the fact that you knew or were grossly negligent in not kn","date_sent_to_company":"2024-11-30T09:15:06.000Z","issue":"Fraud or scam","sub_product":"International money transfer","zip_code":"XXXXX","tags":null,"has_narrative":true,"complaint_id":"10981005","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Ria Envia, LLC","date_received":"2024-11-30T08:54:09.000Z","state":null,"company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["To\nreemphasize, RIAs indisputable overriding purpose is by no means to purely execute transactions in a\nblind and blank fashion, but rather to strike a balance between executing those transactions and\ncapitalising on its undeniably vast capabilities to protect consumers thereby enhancing market integrity."]},"sort":[4.6833386,"10981005"]},{"_index":"complaint-public-v1","_id":"16983019","_score":2.4256747,"_source":{"product":"Mortgage","complaint_what_happened":"b\"Summary\\n\\nShellpoint / XXXX have created a pattern of payment re-aging, unapplied funds, and fabricated fees on my post-discharge mortgage account. Agents repeatedly invoked bankruptcy disclaimersThis is not an attempt to collect a debt due to your discharged bankruptcywhile simultaneously quoting balances and demanding payment. One agent stated, Thats why I think Im a little confused, admitting they could not reconcile my payments inside their own system. These actions violate RESPA (Reg X), TILA (Reg Z), FDCPA, and 11 U.S.C. 524(i).XXXX XXXX XXXX XXXX payment held unappliedXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX. Only XXXX XXXX was credited; the remainder was re-aged to XXXX which was already paid.XXXX XXXX XXXX XXXX XXXX XXXX XXXX online after the portal falsely showed a balance due. That payment disappearedXXXX XXXX XXXX XXXX XXXX XXXX to close out XXXX Agent confirmed the loan was current.XXXX XXXX XXXX Portal briefly displayed the XXXX XXXX payment, then shifted to show XXXX XXXX due for XXXX Later a representative told me, I think that went to XXXX, which is impossible. This is deliberate payment re-aging.\\XXXX XXXX Calls Multiple representatives gave conflicting balances. One said, Thats why I think Im a little confused, proving the account cannot be reconciled from their screens. They then assessed XXXX XXXX8 in late fees and a XXXXXXXX property-inspection fee. When I asked for the inspection date or proof, none existed; the agent simply placed me on hold.\\nStatute\\nCitation\\nConduct\\nRESPA (Reg X)\\n12 C.F.R. 1024.17(k)(1)\\nFailed to credit payments as received; re-aged XXXX XXXX payment to XXXX XXXXXXXXnCharged unverified property-inspection fees\\n XXXXIgnored error-resolution duties after admitting confusion\\n XXXXFailed to maintain one accurate transactional history\\nTILA (Reg Z)\\n12 C.F.R. 1026.36(c)(1)\\nDid not promptly apply payments\\nFDCPA\\n15 U.S.C. 1692e(2)(A)\\nMisrepresented amount / legal status of debt\\nBankruptcy Code\\n11 U.S.C. 524(i)\\nAltered post-discharge payment application and demanded sums inconsistent with discharge\\n\\nConsumer Harm\\n\\t\\tFalse delinquency of roughly XXXX XXXX despite full, timely paymentsXXXX XXXX XXXX payment induced by inaccurate portal display.\\n\\t\\tUnearned XXXX XXXX XXXXate fees and XXXX property-inspection fee.\\n\\t\\tContinuous calls using bankruptcy disclaimers while still quoting balancesconfusing and unlawful post-discharge collection.\\n\\t\\tEmotional distress and risk of wrongful foreclosure.\\n\\n\\n\\nRequested Relief\\n\\t1.\\tFull reconciliation of all payments from XXXX XXXX forward.\\n\\t2.\\tWritten confirmation of correct principal balance and application of each payment.\\n\\t3.\\tRefund of duplicate payments, late fees, and the XXXX inspection fee with interest.\\n\\t4.\\tRemoval of any negative credit reporting.\\n\\t5.\\tDisclosure of internal ledger and proof of any claimed property inspection.\\n\\t6.\\tCertification of corrective action to prevent future payment re-aging.\\n\\n\\n\\nSupporting Evidence (to attach)\\n\\t\\tRecordings and transcripts XXXX XXXX XXXX XXXX XXXX calls).\\n\\t\\tPortal screenshots showing XXXX XXXX XXXX XXXX XXXX XXXX due.\\n\\t\\tBank confirmations for XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX\\t\\tAny correspondence referencing payment application task completed.\\n\\n\\n\\nComplainant Statement\\n\\nShellpoint / XXXX repeatedly misapplied verified payments, told me my funds went to XXXX, added property-inspection fees that never occurred, and invoked bankruptcy language while still demanding money. One agent openly admitted, Thats why I think Im a little confused. These actions violate RESPA, TILA, FDCPA, and 11 U.S.C. 524(i). I request full CFPB and state enforcement review, restitution of all misapplied funds, and sanctions for systemic payment re-aging and fee fabrication.XXXX XXXX XXXX XXXXXXXXI'm sorry, we are unable to make an account match using the last four digits of the Social Security number you entered please try again please enter the last four digits of your Social Security number followed by the pound key We see the number you are calling from today is XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX. Is this a good number to call using our automatic telephone dialing system for future calls to allow us to use this phone number press one if you would like to opt out press two. Thank you we will update this phone number on your loan. If you are a homeowner in an active or discharged bankruptcy, you may have received a periodic billing statement from us. Recently borrowers in an active or discharged bankruptcy previously did not receive statements unless requested the XXXX XXXX mortgage servicing rule requires mortgage services to send modified periodic statements to consumers who have filed for bankruptcy. These rules went into effect on XXXX XXXX XXXX XXXX If you do not wish to receive periodic billing statements, you may request in writing that we see sending periodic statements. Our records indicate that you requested a payment application task on your loan. The task has been completed. No further action is needed from you at this time you can review the results by going to shell point mtg XXXX and reviewing the change on your transaction history, please choose one of the following options to self service your loan to pay by phone using our your call is being transferred please hold thank you for calling Shell point mortgage servicing. Please be advised we are a debt collector. This is not an attempt to collect a debt due to your bankruptcy for training and quality purposes. Your call may be monitored or recorded your estimated wait time is less than two minutes. All of our agents are assisting other customers if you would like to hold your place in queue and have the system call you back press one otherwise please hold for the next available agent call may be returned between XXXX XXXX XXXX XXXX XXXX XXXX XXXX Thank you for calling XXXX. My name is so nice of XXXX and what a recorded line. Who do you have a pleasure speaking with today? \\n\\nYou\\nHi, my name is XXXX XXXX \\n\\nParticipant\\nThank you, XXXX be for verification purposes. Can you please verify the mailing address along with the last four of the Social Security number and account? XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX TN XXXX XXXX XXXX XXXXnParticipant\\nThank you and I see the loan you are calling about your XXXX XXXX XXXX We thank you and your family for your sacrifices and service of our country and our honor to help us our customers and also I'll just get to inform you by breaking is a bad collector. This is not an attempt to collect a debt due to your district bankruptcy and XXXX XXXX Do we have your permission to contact you within the next seven days via call or text using \\n\\nYou\\nYes \\n\\nParticipant\\nour dial if it is needed is it your cell phone number ending in XXXX XXXXYou\\nYes \\n\\nParticipant\\nAnd do you want also to set this up the primary contact of yours? \\n\\nYou\\nYeah \\n\\nParticipant\\nOf a perfect and also XXXX XXXXI'll just need to inform you that your account is currently for a total of XXXX including the total liter see if XXXX and the other fee of XXXX and also if you have some free time, give me visit the web online to check the status of your account and you can set up there for ACH for the payment biweekly and send one please and how many help you for today? \\n\\nYou\\nOK, what is what is the XXXX for? \\n\\nParticipant\\nThat is for the other fees \\n\\nYou\\nWhat fees? \\n\\nParticipant\\nFor the property inspection if you are on 30 days \\n\\nYou\\nWhen was our property inspection? \\n\\nParticipant\\ndelinquent on your yes That property \\n\\nYou\\nWhen was the property inspection done? \\n\\nParticipant\\ninspection if you are on 30 days OK offer for this one let me go ahead and double check. OK go for the \\n\\nYou\\nOK, I'm going \\n\\nParticipant\\nproperty inspection. Let me go ahead and check. When did this property inspection was fine OK and then I'll be back off so would you mind if I put this on hold for about one to two minutes thank you kind to stay on the line. \\n\\nYou\\nOK, go ahead. Go ahead. XXXX XXXX XXXX XXXXSing your loan press one to talk to a loan officer about refinancing your please select one of the following options to be connected to your loan servicer for new rest press two for XXXX thank you for calling Shell point mortgage servicing, but I couldn't be XXXX XXXX Please enter the last four digits of your Social Security number, followed by the pound key We see the number you are calling from today is XXXX XXXX XXXX XXXX XXXX XXXX XXXX Is this a good number to call using our automatic telephone dialing system for future calls to allow us to use this phone number press one if you would like to opt out press two, thank you, we will update this phone number on your loan. If you are a homeowner in an active or discharged bankruptcy, you may have received a periodic billing statement from us recently borrowers in an active or discharged bankruptcy previously did not receive statements unless requested the XXXX XXXX mortgage servicing rule requires mortgage services to send modified periodic statements to consumers who have filed for bankruptcy. These rules went to effect on XXXX XXXX XXXX XXXX If you do not wish to receive periodic billing statements, you may request in writing that we see sending periodic statements. Our records indicate that you requested a payment application task on your loan. The task has been completed. No further action is needed from you at this time you can review the results by going to shell point mtg XXXX and reviewing the change on your transaction history, please choose one of the following options to self service your loan to pay by phone using our free automated phone system press one for Shell point mortgage servicing contact information press two. For general loan information press, three for escrow your call is being transferred. Please hold thank you for calling Shell point mortgage servicing. Please be advised. We are a debt collector. This is not an attempt to collect a debt due to your bankruptcy for training and quality purposes your call may be monitored or recorded your estimated wait. Thank you for contacting XXXX mortgage servicing. My name is XXXX XXXX on a recorded line with whom do I have a pleasure of speaking? \\n\\nYou\\nYes, my name is XXXX XXXX XXXXParticipant\\nXXXX XXXX, how are you today? \\n\\nYou\\nHow are you doing? \\n\\nParticipant\\nI'm doing well, sir thank you so much for asking the pain before we speak in detail as to why you're calling. Could I please have you provide your mailing address and the last four of your social please? \\XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXParticipant\\nAll right, I want to thank you XXXX XXXX XXXX for verifying that information, sir before we speak in detail please allow me a moment to offer you to say thank you to you and your family for your sacrifice and service of our country. We are honored to have you as a \\n\\nYou\\nThanks \\n\\nParticipant\\ncustomer. I also have informed you, sir, that we will get servicing is a debt collector. This is not an attempt to collect a debt due to the status of your bankruptcy discharge XXXX XXXX if we have to contact you in the next seven days with your updated information, do we have your permission to call? And this permission include automated text messages and automated calls as well \\n\\nYou\\nSure Right \\n\\nParticipant\\nOK, so I do see where your account is eligible to schedule out up to three post payments and all the account also shows that you last called in last week XXXX XXXX XXXX XXXXWhat are you talking about schedule out? \\n\\nParticipant\\nJust like you would write a post check you can write on that check a date just like you would write a \\n\\nYou\\nWhat do you mean oh no no no no no no no \\n\\nParticipant\\npostage \\n\\nYou\\nno no I'm about. I'm supposed to get a check for around three XXXX XXXX XXXX XXXX XXXX she said to be like 7 to 10 days. I'm supposed to have a payment for XXXXXXXX XXXX XXXX XXXXpplied and that was made on XXXX XXXX so I'm just checking the status that. \\n\\nParticipant\\nOK, so what I am seeing on the account at this time looks like the most recent payment we received was on the XXXX XXXX and that brought your \\n\\nYou\\nFor how much? \\n\\nParticipant\\npayment up Seeing That was XXXX XXXX XXXX \\n\\nYou\\nAnd that paid off XXXX correct? \\n\\nParticipant\\nThat oh yes, sir, that was enough to cover the month of XXXX that is correct and now the account has been up \\n\\nYou\\nOK, so there was another payment on there. There's another payment that came in on the XXXX XXXX where is that one? \\n\\nParticipant\\nI don't see that payment has been received posted to the account as of yet and I do see on the XXXX you made a payment over the Internet \\n\\nYou\\nRight right for a whole month XXXX towards that payment \\n\\nParticipant\\nThat payment was applied to the month of XXXX XXXXNo, we already paid XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXnParticipant\\nIt shows on the XXXX that you made a payment for XXXX and that was the full amount due which was applied to the amount \\n\\nYou\\nYou're saying we made a pic so let me \\n\\nParticipant\\nYeah, that took \\n\\nYou\\nunderstand something there's XXXX who is sitting in XXXX unapplied we made a payment for XXXX XXXX XXXX XXXX OK so now that if we take XXXX XXXX of that and put it in of XXXX that pays off XXXX so then what are you doing with taxes you put that in XXXX right so then I call in XXXX and I gave her the XXXX because she says that's how much I owe and if she stated on the XXXX we're paid off however, now you have an extra payment where is that payment at? \\n\\nParticipant\\nSorry, I don't show that the payment on the XXXX Let me see says on the XXXX XXXX XXXX XXXX XXXX you added a payment of XXXX XXXX XXXX XXXX XXXX and that was the amount that was posted To XXXX So you paid for XXXX XXXX XXXX XXXX then on XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX how much money do we pay total? \\n\\nParticipanXXXX XXXX XXXX XXXX XXXX XXXX XXXX you're referring to that was on XXXX XXXX XXXXYou\\nThat's right that sitting in XXXX right and then there's a problem here because you see the payment on XXXX XXXX XXXX XXXX all right so that payment was made on XXXX XXXX actually on our payment history it's on our bank account those payments you drafted out but the prom now is you're only telling me XXXX XXXX but in fact we paid off XXXX we paid off XXXX and then you got an extra payment so I need to know where that payment is \\n\\nParticipant\\nThat's what we're a little bit confused when we receive a payment on XXXX XXXX you have credit on the account of XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX yesterday we spoke to somebody yesterday XXXX we had XXXX on paid balance towards our account. We were told that that would be distributed for XXXX XXXX and you guys are going to dismiss a check back and for XXXX XXXX XXXX XXXX XXXX apparently you guys have been with holding unapplied balances which is against spot. And sending out foreclosure notices basically say you gotta pay by the XXXX that you're three months behind but see the prime is you can't be behind if you're holding money so we just need our money we need you guys to put it on XXXX XXXX XXXX XXXX, and since our check like you agreed to \\n\\nParticipant\\nI'm not sure there's been a price on XXXX XXXX Looks like I'll \\n\\nYou\\nYeah, you guys yeah apparently \\n\\nParticipant\\ncontact and apply. \\n\\nYou\\nSorry \\n\\nParticipant\\nLooks like all parents have an applied \\n\\nYou\\nNo, they haven't. We have XXXX an unplayed unapplied money. Going back three years see what you're doing as you keep putting us into arrears OK so that we are never ahead but the problem is we're already ahead This is taken care of Sunday a letter was sent to you guys XXXX XXXX we called that was taken care of. She stated got recording everything so I mean gotta have it done. She stated yes I see us XXXX here we're going to, but how do you want me to do this? I said pay XXXX XXXX and then send a check for XXXX XXXX So it was already made \\n\\nParticipant\\nOK, so if you sent a letter but it's being reviewed by our payment processing department but at this time I don't see an unpaid burn on applied balance of XXXX I'm not showing anything and \\n\\nYou\\nWell, they told me but yeah yeah I spoke to you guys yesterday \\n\\nParticipant\\nunapplied \\XXXX you told me you have XXXX unapplied and then you you told me you were gonna pay for XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX \\n\\nParticipant\\nThat's not what I'm saying I am not saying there was an unapplied balance of XXXX yesterday. I'm sitting there wasn't an \\n\\nYou\\nBut there is there is a unified balance, but there is an \\n\\nParticipant\\nunapplied. \\n\\nYou\\nunified balance. No, it's it's more than no you have to go back three XXXX XXXX XXXX that was applied to your XXXX payment \\n\\nYou\\nyears. No you have to go back three years. OK what you're doing is taking the unapplied payments and putting them in another account you're moving them Do you understand you guys I've been sued for this stuff you guys have already been sued for this several \\n\\nParticipant\\nWhere would we move into? \\n\\nYou\\ntimes OK under arrest, but you can't do what you're doing \\n\\nParticipant\\nWell, sure if we don't have a full deal and we can't apply to have to sit on a bike at this point \\n\\nYou\\nWell, why don't you audit it so audit my account so audit my account \\n\\nParticipant\\nAs I advised as I advised already, sir, payment processing is reviewing your account because you sent an email but at this time I do not see that there's XXXX XXXX XXXX XXXX XXXXThen how come yesterday there \\n\\nParticipant\\nwas a high balance of three. I'm not sure I'm not that person, sir but looking at your account yesterday, there was not a balance of \\n\\nYou\\nwas \\n\\nParticipant\\nXXXX when you're on a bike. \\n\\nYou\\nThere was yesterday I mean, I got recorded talking dispute that \\n\\nParticipant\\nOK sir so if you'd like, you can definitely go ahead and check on our website which will show that there was an \\n\\nYou\\nYeah, your website so that's the \\n\\nParticipant\\nunapplied. I'm sorry I \\n\\nYou\\nproblem. Yeah, it doesn't work. \\n\\nParticipant\\ninterrupted you. Go ahead. \\n\\nYou\\nYeah, the problem with you guys is you say one thing somebody else says something else your website says something else but none of us the truth. You're all contradicting each other. The website does not equal what you're saying you see the problem we're having. \\n\\nParticipant\\nNo sir, because the website shipping matching my payment history and my payment history does not show an \\n\\nYou\\nIt's not matching your payment history \\n\\nParticipant\\nunapplied for XXXX XXXXYou\\nWait, let me ask you this I called on the \\n\\nParticipant\\nyesterday XXXX. I spoke to one of your idiots. I said listen there's two XXXX. Excuse me there is \\n\\nParticipant\\nOK sir, I will not tolerate you being \\n\\nYou\\nXXXX sitting in \\n\\nParticipant\\ndisrespectful. I understand you are XXXX. No I'm not \\n\\nParticipant\\nfrustrated \\n\\nYou\\nfrustrated to listen to me. I'm your \\n\\nParticipant\\nOK \\n\\nYou\\ncustomer there was XXXX and unapplied payments in XXXX OK we were told that we only owed XXXX XXXX all right so then we call on the XXXX and then we speak to one of your individual individuals. He says yeah well what happened was you have XXXX on the site in XXXX? OK then he says my wife made a payment foXXXX XXXX XXXX XXXX then he says it that money went to XXXX XXXX XXXX XXXX XXXX XXXX XXXX but then all of a sudden he came back and said you need a calculator and I'm like I don't need a calculator because what happens is you take XXXX XXXX XXXX that complete XXXX and then you've got another XXXX left over whatever whatever it is and XXXX XXXX So and then he tells us that oh well, you still owe XXXX XXXX XXXX XXXX so you see your math just does not add up. You guys tell one story and then you change it again. You see the problem \\n\\nParticipant\\nAnd we take that out for your XXXX XXXX XXXX XXXX So \\n\\nYou\\nI'm sorry so wait wait I'm sorry on \\n\\nParticipant\\nthen \\n\\nYou\\nXXXX XXXX XXXX XXXX XXXX XXXX was made right \\n\\nParticipantXXXX XXXX yes and I went and applied which was the XXXX XXXX XXXX XXXXou\\nWhere is it? Where is that money at? \\n\\nParticipant\\nadvised it was the XXXX XXXXou\\nBut it was just unapplied, right \\n\\nParticipant\\nWhen trying to apply \\n\\nYou\\nRight OK so it was unapplied for XXXX My wife made a payment for XXXX XXXX XXXX XXXX XXXX correct \\n\\nParticipant\\nYes, there was a payment for XXXX XXXX XXXX XXXX XXXXou\\nOK right Then XXXX XXXX went to XXXX right? \\n\\nParticipant\\nNo sir, 3 XXXX XXXX XXXX XXXX SXXXX \\n\\nYou\\nWhere's my XXXX at? \\n\\nParticipant\\nThat was in the payment because you had made the payment of \\n\\nYou\\nNo wasn't you just told me you just told me that I had \\n\\nParticipanXXXX XXXX there that was \\n\\nParticipant\\nOK sir \\n\\nYou\\nunapplied but yet you just told me and my wife made a payment for XXXX XXXX which went to 3XXXX XXXX XXXX XXXX so where's my XXXX payment? The balance it wasn't applied \\n\\nParticipant\\XXXX XXXX XXXX XXXX XXXX XXXX \\n\\nYou\\nRight \\n\\nParticipant\\n- XXXX because that's what your XXXX payment was was \\n\\nYou\\nHa ha, right \\n\\nParticipant\\nXXXX if you \\n\\nYou\\nHa ha, right \\n\\nParticipant\\XXXX XXXX XXXX\\nSo how much money? \\n\\nParticipant\\nSo then that left \\n\\nYou\\nRight in case no OK so how much money out of that XXXX with the \\n\\nParticipant\\nGo ahead \\n\\nYouXXXX \\n\\nParticipant\\nI got XXXX well we first had the XXXX in there so let's go ahead and go XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX \\n\\nYou\\nOK, did that pay it off? \\n\\nParticipant\\nThat paid for XXXX XXXXn\\nYou\\nOK, what about XXXX then because we still have money left over right? \\n\\nParticipant\\nYou had XXXXXXXX left over a payment was made \\n\\nYou\\nOK \\n\\nParticipant\\nyesterday foXXXX XXXX XXXX which \\n\\nYou\\nHa ha \\n\\nParticipant\\ncompleted your XXXX payment \\n\\nYou\\nNo \\n\\nParticipant\\nleaving XXXX and the unapplied \\n\\nYou\\nI'm sorry when was the payment before that one yesterday? \\n\\nParticipant\\XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX \\n\\nYou\\nNo, it wasn't. It was made on XXXX XXXX XXXX XXXX You took it on my bank account \\n\\nParticipant\\nI'm showing a payment of seven XXXX XXXX XXXXYou\\nNo, you took out it's showing my bank account you took out XXXX XXXXor the month of XXXX See now we have a problem because your numbers don't match up so where is my XXXX you guys just took out my bank account then \\n\\nParticipant\\nI showed the XXXX XXXX and you advise that you already \\n\\nYou\\nNo \\n\\nParticipant\\nsent a complaint so it is being reviewed by our payment \\n\\nYou\\nBut I'm asking you about my accounting right but I'm asking you about a \\n\\nParticipant\\nprocessing \\n\\nYou\\npayment \\n\\nParticipant\\nAgainst her that has to be done by our payment processing department since they're reviewing it because you're \\n\\nYou\\nBut you just told me yoXXXX XXXX XXXXrticipant\\ninsisting there's XXXX XXXX \\n\\nYou\\nYou're supposed to understand what's going on but yet you can't find my payment from Sunday You just told me it was paid \\n\\nParticipant\\nI can sure \\n\\nYou\\nXXXX paid for \\n\\nParticipant\\nshow that your XXXX XXXX is paid for \\n\\nYou\\nOK, but when was that payment made for \\n\\nParticipant\\nAnd there's nothing \\n\\nYou\\nXXXX but when was that payment made for \\n\\nParticipant\\nremaining in your pipe The remainder amount of \\n\\nYou\\XXXX? \\n\\nParticipant\\nseven XXXX XXXX as I had advised numerous times now was made on XXXX XXXX that \\n\\nYou\\nFor XXXX XXXX XXXX XXXX \\n\\nYou\\nYou're telling me XXXX XXXX XXXX XXXX XXXX XXXX right Is that correct? \\n\\nParticipant\\nYes \\n\\nYou\\nOK, so that was for what month \\n\\nParticipant\\nCompleted XXXX \\n\\nYou\\nOK, so then XXXX XXXX another payment was made foXXXX XXXX Where is that money? \\n\\nParticipant\\nI am not saying that one at this time so I can reach out to XXXX There's nothing in your \\n\\nYou\\nSays it's unapplied \\n\\nParticipant\\nunapplied, sir. There's nothing there. \\n\\nYou\\nSo I made it so you're telling me the payment was already made but then I made another payment That's unapplied you just told me that the payment that I made for XXXX XXXXompleted the XXXX repayment correct? \\n\\nParticipant\\nCorrect that was made on \\n\\nYou\\nRight, but there was another payment made for \\n\\nParticipant\\nXXXX XXXX XXXX XXXX XXXXr that now \\n\\nParticipant\\nOK again I'm \\n\\nYou\\nBut we're missing \\n\\nParticipant\\nI'm not seeing that payment, sir. You're saying it came out of your checking account. OK that's great. \\n\\nYou\\nI'm seeing it right here in front of me. I'm looking at the payment history right here. I'm looking at the payment. I see it right here \\n\\nParticipant\\nNow you're saying \\n\\nYou\\nunapplied since XXXX XXXX XXXXParticipant\\nYeah, you're seeing the XXXX \\n\\nParticipant\\nunapplied balance go from the unapplied with that XXXX XXXX XXXX XXXX XXXX XXXXYou\\nHa ha \\n\\nParticipant\\ncombined and it went towards your XXXXXXXX XXXX XXXXYou\\nSo what about the XXXX XXXX where that go? \\n\\nParticipant\\nThat is what was coming out of the unapplied \\n\\nYou\\nIt wasn't that was the money that it was a payment I made I made a payment for \\n\\nParticipant\\nOK sir, \\n\\nYou\\nXXXX XXXXParticipant\\nagain I am not seeing that and seeing the seven XXXX XXXX goes with the \\n\\nYou\\nOK, so I just wanna ask you one more question here \\n\\nParticipant\\nunapplied to create XXXX XXXX XXXX and the apply XXXX XXXXu\\nOK, so XXXX was paid off right then you told me that some of that money was left over something that money was left over for \\n\\nParticipant\\nXXXX has been XXXX then you said to complete XXXX I had to pay XXXX right \\n\\nParticipant\\nI said that you did pay XXXX yes \\n\\nYou\\nTo complete XXXXr correct to complete XXXX right again a payment was made for XXXX for the complete month of XXXX so that's an extra payment there \\n\\nParticipant\\nAgain, I'm not seeing that here, sir so I can definitely reach out to my payment \\n\\nYou\\nSo how come my numbers look different than \\n\\nParticipant\\nprocessing department, but I'm not seen that \\n\\nYou\\nyours? \\n\\nParticipant\\nI am not sure sure I can't see what you're looking at. I can see what I'm looking at which is your payment. \\n\\nYou\\nI'm looking it says payment history it is I'm looking at payment history. It says XXXX XXXX XXXX a payment for XXXX was applied or it says applied payment now and you took it out of my bank account and it's just unapplied it's just like sitting see that's the prom you don't you don't even know where this payment is. You guys weren't even know where the XXXX is now. Now you understand what's going on you guys aren't applying money properly Do you have a \\n\\nParticipant\\nI got her. I'm just \\n\\nYou\\nsupervisor do you have anybody? I can talk to that knows what they're doing \\n\\nParticipant\\nshowing that what I'm very well aware of what I'm doing, sir \\n\\nYou\\nOK, where did the payment XXXX XXXX XXXX go it's on my payment history. I'm looking at it right now. Where is it? \\n\\nParticipant\\nYes, it went from your unapplied to your regular monthly payment for \\n\\nYou\\nIt could've \\n\\nParticipant\\nXXXX \\n\\nYou\\ngone from my monthly payment. You just told me a payment was made. There was a payment in XXXX XXXX XXXX XXXX sitting in XXXX unapplied correct my wife made a payment for my wife made a \\n\\nParticipant\\nCorrect \\n\\nYou\\npayment XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX that went to whatever it was went to XXXX to pay it off right Correct \\n\\nParticipant\\XXXX XXXX was from the \\n\\nYou\\nbut \\n\\nParticipant\\noriginal on balance and XXXX XXXXYou\\nOK \\n\\nParticipant\\XXXX XXXX XXXX XXXX you made went to your XXXX payment \\n\\nYou\\nOK, and then how much was left over \\n\\nParticipant\\nThat left \\n\\nYou\\nHow much was left over they went to \\n\\nParticipant\\nXXXX XXXX XXXXParticipant\\nAre you going to allow me to answer, sir? \\n\\nYou\\nYes, go ahead \\n\\nParticipant\\nThank you XXXX XXXXYou\\nAnd that was from the XXXX XXXX payment correct? \\n\\nParticipant\\nThat was what was left over of the XXXX XXXX XXXXYou\\nOK and then and then a payment so then yesterday a payment was made for XXXX whatever is a complete XXXX XXXX? \\n\\nParticipant\\nCorrect and we XXXX XXXX XXXX XXXX XXXX XXXX Shellpoint representatives admitted that a XXXX XXXX payment existed in unapplied status, contradicted themselves about its destination, and then erased a previously confirmed XXXX XXXX unapplied balance.\\nThe same call captured two separate employees describing entirely different account realities within minutes of each other.\\n\\nEvidence (verbatim excerpts):\\n\\nI do see there was a balance in the unapplied of XXXX XXXXOK yes, I dont see that it was about XXXX XXXX applied yesterday.\\nSupervisorXXXX XXXX XXXX theres another payment that was made that put your unapplied balance at XXXX XXXX completing XXXX payment.\\n\\nEach statement conflicts with the others. The first recognizes an unapplied payment; the second claims the funds were applied yesterday; the third insists the same payment completed XXXX a month already paid through prior remittances.\\n\\nInterpretation:\\nThis sequence demonstrates a systemic data-integrity failure rather than a single mis-keyed entry.\\nShellpoints staff are reading from live account screens that change while the customer is on the line meaning the ledger is being rewritten in real time to reconcile internal errors or conceal unapplied balances.\\nSuch volatility violates:\\n\\t\\tRESPA 1024.38(b)(3)(i) failure to maintain accurate and accessible records.\\n\\t\\tRESPA 1024.35(a) servicer notice of error (were a little confused) triggers investigation duty.\\n\\t\\tTILA 1026.36(c)(1) failure to credit payments as of date received.\\n\\t\\tBankruptcy Code 524(i) post-discharge tampering with payment application.\\n\\nThe conflicting explanations unapplied, applied yesterday, completed XXXX confirm ledger re-aging and manual overrides.\\nNo servicer could produce three mutually exclusive account states unless data are being altered outside ordinary automated posting rules.\\n\\nRisk Impact:\\nThis behavior shows a system-level vulnerability where borrower payments can be suspended, moved backward to earlier months, or erased without audit transparency.\\nThe XXXX XXXX call provides a living snapshot of that process: funds appear in the system, vanish, then reappear labeled applied, enabling Shellpoint to (1) fabricate delinquency, (2) assess late fees and inspection charges, and (3) justify foreclosure notices while still holding consumer money.\\nSuch conduct jeopardizes compliance with federal servicing standards and exposes investors and borrowers to material misrepresentation of cash-flow integrity.\\n\\n\\n\\nSystemic Alignment\\n\\nThe same mis-allocation pattern appears across every month since XXXX XXXX\\t\\tpayments first recorded as unapplied,\\n\\t\\tlater re-aged to prior months,\\n\\t\\tfollowed by fee creation and conflicting balances.\\n\\nThis repetition confirms a servicing algorithm or manual policy, not human error.\\nShellpoints own agents admitted confusion (thats why I think Im a little confused) because their interface dis\"","date_sent_to_company":"2025-11-03T23:01:28.000Z","issue":"Trouble during payment process","sub_product":"VA mortgage","zip_code":"37066","tags":"Servicemember","has_narrative":true,"complaint_id":"16983019","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Shellpoint Partners, LLC","date_received":"2025-11-03T22:35:45.000Z","state":"TN","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Payment process"},"highlight":{"complaint_what_happened":["\\n\\nYou\\nHi, my name is XXXX XXXX \\n\\nParticipant\\nThank you, XXXX be for verification purposes. 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