{"took":217,"timed_out":false,"_shards":{"total":5,"successful":5,"skipped":0,"failed":0},"hits":{"total":{"value":8,"relation":"eq"},"max_score":null,"hits":[{"_index":"complaint-public-v1","_id":"6618957","_score":16.604462,"_source":{"product":"Debt collection","complaint_what_happened":"I sent several certified letters to Midland asking for validation. I have not received a response, it'sbeen a year. They continue to report the debt to all 3 credit bureaus without validation with me. I do not have debt with Midland Credit. According to the Texas Finance Code Sec. 392.201 REPORT TO CONSUMER.\n\nNot later than the 45th day after the date of the request, a debt collector shall provide to a person in its registry a copy of all information contained in its files concerning that person.\n\nSec. 392.202 CORRECTION OF THIRD-PARTY DEBT COLLECTOR 'S OR CREDIT BUREAU 'S FILES.\n\nAn individual who disputes the accuracy of an item that is in a third-party debt collector 's or credit bureau 's file on the individual and that relates to a debt being collected by the third-party debt collector may notify in writing the third-party debt collector of the inaccuracy. The third-party debt collector shall make a written record of the dispute. If the third-party debt collector does not report information related to the dispute to a credit bureau , the third-party debt collector shall cease collection efforts until an investigation of the dispute described by Subsections ( b ) - ( e ) determines the accurate amount of the debt, if any. If the third-party debt collector reports information related to the dispute to a credit bureau , the reporting third-party debt collector shall initiate an investigation of the dispute described by Subsections ( b ) - ( e ) and shall cease collection efforts until the investigation determines the accurate amount of the debt, if any.\n\n( b ) Not later than the 30th day after the date a notice of inaccuracy is received, a third-party debt collector who initiates an investigation shall send a written statement to the individual : ( 1 ) Denying the inaccuracy ; ( 2 ) Admitting the inaccuracy; or ( 3 ) Stating that the third-party debt collector has not had sufficient time to complete an investigation of the inaccuracy. Reporting inaccurate information to major credit bureaus might constitute defamation of character, as the negative marks on my credit report harm my credit and prevent me from enjoying all the benefits of good credit. Either provides validation of this alleged debt and corrects all inaccurate information you have furnished to the credit bureaus or remove this disputed account from my credit reports. \n\nIf Midland Credit had fail to respond to the validation request within 15 days from the date of receipt, all reference to this account must be deleted and completely removed from my credit file and a copy of such deletion request shall be sent to me immediately It would be advisable that Midland Credit assure that their records are in order before I am forced to take legal action pursuant to the Texas Debt Collection Act, Texas Deceptive Trade Practices/Consumer Protection Act, Fair Debt Collection Practices Act, and Chapter 392 of the Texas Finance Code. This request is being made in order to VALIDATE a debt that Midland Credit company has never contacted me in regards to. This is an attempt to correct their records ; any and all information obtained shall be used for that purpose.\n\nI'm sure their legal staff will agree that non-compliance with this request could put Midland Credit company in serious legal trouble with the FTC and other Texas state or federal agencies. \n\n\nThanks, XXXX XXXX","date_sent_to_company":"2023-02-27T04:34:11.000Z","issue":"Written notification about debt","sub_product":"Credit card debt","zip_code":"77095","tags":"Servicemember","has_narrative":true,"complaint_id":"6618957","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"ENCORE CAPITAL GROUP INC.","date_received":"2023-02-27T04:10:51.000Z","state":"TX","company_public_response":null,"sub_issue":"Didn't receive enough information to verify debt"},"highlight":{"complaint_what_happened":["( b ) Not later than the 30th day after the date a notice of <em>inaccuracy</em> is received, a third-party debt collector who initiates an <em>investigation</em> shall <em>send</em> a written <em>statement</em> to the individual : ( 1 ) <em>Denying</em> the <em>inaccuracy</em> ; ( 2 ) <em>Admitting</em> the <em>inaccuracy</em>; or ( 3 ) <em>Stating</em> that the third-party debt collector has not had sufficient time to complete an <em>investigation</em> of the <em>inaccuracy</em>."]},"sort":[16.604462,"6618957"]},{"_index":"complaint-public-v1","_id":"2648625","_score":11.750383,"_source":{"product":"Debt collection","complaint_what_happened":"I consolidated my loans through FedLoan Servicing ( FedLoan ) after they reached out to me offering better rates than my previous servicer, XXXX, in or around XX/XX/XXXX On or around XX/XX/XXXX, I contacted FedLoan about renewing my income-based repayment paperwork. I faxed in the approved Income Driven Payment Plan Request form ( IDPPR ) with a pay stub and called to be sure that they received my application. I never received an acknowledgment that FedLoan received my application. I called and emailed again inXX/XX/XXXX. I finally spoke with a manager who assured me that my application was under review and was told not to worry about making any payments during the review. The manager said that they would forebear or defer payments during the review process. Despite this assurance, I continued to receive extremely high bills. The manager also said that the email box doesnt work and nobody checks it. I called again inXX/XX/XXXX to check the status of my application after receiving another bill stating that I was late and that account was not in forbearance or deferment. I spoke with a representative who said that there was a note in my file that said that my payments should be on hold for review but that was never done. InXX/XX/XXXX nearly four months after submitting a complete package, I was told my application was declined because they were unable to read the scanned documents. The representative I spoke with said there was an internal error with scanning the documents into their system. She also said that the weather caused the four-month delay in reviewing my application. I have a copy of the scanned IDPPR application which is clearly legible. OnXX/XX/XXXX, I talked to XXXX ( employee number XXXX ) who said that my new application was denied because I marked that I was not on forbearance when I was. This is not accurate and not a valid reason for denial. I told her I wanted to do whatever I needed to do to start making affordable payments. OnXX/XX/XXXX and XX/XX/XXXX, I re-submitted the IDPPR application again. FedLoan continually either did not process the application, or failed to provide a reasonable, monthly payment amount. At this point, a year after consolidation, FedLoan still had not appropriately processed my IDPPR application which forced my account into forbearance or deferment with interest added to the account. In XXXX XXXX, I submitted the online XXXXDPPR form through the Department of Education. Most recently, FedLoan sent me a bill for {$3800.00}, despite the fact that my disclosed paystubs show that this is what I net on a monthly basis. Today, FedLoan still has not appropriately processed my IDPPR application.\nSubstantial Interest has accrued over the past two years due to its errors. It is far easier to push a borrower into forbearance than tell them that there are plans available that would decrease payments and or actually process the IDPPR applications because of the staggering interest that accrues on  high principle loans. FedLoan has engaged in fraud, misrepresentations and omissions, collusion and conspiracy to achieve these ends in the hopes that the borrower grows tired of these tactics, moves it loans, and FedLoan is paid its usurious fees for its institutionalized behavior. \nAdditionally, FedLoan reported these erroneous interest increases to the credit agencies and my credit score has decreased as a result. Please also consider this correspondence to be my formal notice that I disputes the accuracy of the alleged debt in accordance with XXXX of the Texas Debt Collection Act and 809 of the federal Fair Debt Collections Practices Act. Consequentially, your company is obligated to immediately cease all collection efforts until the debt is validated. According to Texas Debt Collection Act 392.202 ( b ) : Not later than the 30th day after the date a notice of inaccuracy is received, a third-party debt collector who initiates an investigation shall send a written statement to the individual : ( 1 ) denying the inaccuracy ; ( 2 ) admitting the inaccuracy ; or ( 3 ) stating that the third-party debt collector has not had sufficient time to complete an investigation of the inaccuracy.\nIn addition, 15 U.S.C. 809 ( a ) ( 5 ) ( b ) states : If the consumer notifies the debt collector in writing... that the debt, or any portion thereof, is disputed... the debt collector shall cease collection of the debt, or any disputed portion thereof, until the debt collector obtains verification of the debt or any copy of a judgment, or the name and address of the original creditor, and a copy of such verification or judgment, or name and address of the original creditor, is mailed to the consumer by the debt collector. If you can not properly validate the debt, the both statutes cited above require your company to immediately cease collection efforts, notify each person who previously received a report containing inaccurate information, and correct the inaccuracy within five business days. Failure to comply with the requirements above may subject your company to civil penalties. Specifically, in an action for violation of the Texas Debt Collections Act, a victim in entitled to actual damages, defined as damages for loss of home, slander of title, harm to credit reputation, and mental anguish. See XXXX XXXX XXXX. v. XXXX, XXXX XXXX XXXX XXXX ( Tex.App.-XXXX XXXX 1996, no writ ). In addition, a victim may also be entitled to exemplary damages, court costs, attorney fees, and interest. Tex. Civ. Prac. & Rem. Code 41.002 ; Tex. Fin. Code 392.403 ( b ).\nFurthermore, violations of the Texas Debt Collections Act are subject to the so-called tie in provision of the Texas Deceptive Trade Practices Act ; which carries with it much more severe penalties. Pursuant to Tex. Bus. & Com. Code 17.50 ( b ) ( 1 ), a victim may be entitled to three times the amount of the economic damages if the violation is found to have been made knowingly. If the violation was made intentionally, a court may award damages of three or four times the amount of economic and mental anguish damages. Id. Finally, a court may award damages of up to {$1000.00} per violation of the federal Fair Debt Collection Practices Act. 15 U.S.C. 813 ( a ) ( 1 ) ( 2 ) ( A ). As I am sure if you fully investigate this alleged debt as required by the TDCA, you will discover you are in error. Any continued attempts to collect this debt will constitute a violation of the above referenced statutes and may result in legal action. The statutes referenced above provide for significant penalties for violators and I am prepared to seek legal action to enforce my rights. I sincerely regret transferring my loans to FedLoan which is clearly fabricating reasons to deny my income-based application to collect unreasonably high interest amounts. This is clearly a payment shock and I fear that I will fall behind on my payments because FedLoan can not properly process an application. I have made payments for years and want to continue making payments. FedLoan is making that impossible.","date_sent_to_company":"2017-08-21T17:47:17.000Z","issue":"False statements or representation","sub_product":"Federal student loan debt","zip_code":"75034","tags":null,"has_narrative":true,"complaint_id":"2648625","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"AES/PHEAA","date_received":"2017-08-21T17:41:23.000Z","state":"TX","company_public_response":null,"sub_issue":"Attempted to collect wrong amount"},"highlight":{"complaint_what_happened":["According to Texas Debt Collection Act 392.202 ( b ) : Not later than the 30th day after the date a notice of <em>inaccuracy</em> is received, a third-party debt collector who initiates an <em>investigation</em> shall <em>send</em> a written <em>statement</em> to the individual : ( 1 ) <em>denying</em> the <em>inaccuracy</em> ; ( 2 ) <em>admitting</em> the <em>inaccuracy</em> ; or ( 3 ) <em>stating</em> that the third-party debt collector has not had sufficient time to complete an <em>investigation</em> of the <em>inaccuracy</em>."]},"sort":[11.750383,"2648625"]},{"_index":"complaint-public-v1","_id":"15156558","_score":9.313251,"_source":{"product":"Payday loan, title loan, personal loan, or advance loan","complaint_what_happened":"b'Should a billing statement include which form of payment method was use to make payment whether it was accepted or denied or the card ending number and it should the cascade billing statement does not provide that detail let cfpb of this and that it would further prove that misrepresenting what actually occurred and who would actually be at fault for a payment not going through when sufficient funds are present add this to the cfpb rebuttal which they failed to properly investigate now providing sufficient \\nevidence also can you look at the month for which the banks statement says payments occured and tell me if I had and prove with numbers I had sufficient funds to pay bill and time of when payment was first do and analyze it against the billing statement cascade spring credit provided for me and tell me when the bank statement and billing statement doesn\\'t not support that payments and interest acquired were erroneous and cross analyze \\nBased on the provided documentsXXXX XXXX XXXX bank statement shows sufficient funds to cover the payments that were returned by Cascade Spring Credit, indicating a discrepancy between the two statements. The bank statements also show that the billing statement from Cascade Spring Credit is missing key details about the payment methods used, which is a violation of TILA and CFPB guidelines.\\nBilling Statement Analysis \\nThe Cascade Spring Credit billing statement shows six attempts to make a payment between XXXX XXXX XXXX XXXX XXXX XXXX XXXX. Five of these payments were \"Returned\". The payment amounts ranged from XXXX XXXX XXXX. The billing statement lacks information on the payment method used (e.g., card type or last four digits).\\n\\nBank Statement Analysis \\nThe bank statement, which is from Chase, covers the period from XXXX XXXX XXXX XXXX XXXX XXXX XXXX  This statement shows a balance of XXXX XXXX XXXX XXXX XXXX, and a balance of XXXX XXXX XXXX XXXX XXXX. It also shows a XXXX XXXX XXXX XXXX XXXX on AXXXX XXXX XXXX. The second XXXX XXXX statement covers the period from XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX the balance was XXXX and on XXXX XXXX XXXX the balance was XXXX. A deposit of XXXX  was made XXXX XXXX XXXX XXXX, bringing the balance up to XXXX. The statement shows a deposit of XXXX XXXX XXXX XXXX XXXX which brought the balance to XXXX. A recurring payment of XXXX was returned on XXXX XXXX XXXX. The bank statement also shows a deposit of XXXXXXXX on XXXX XXXX XXXX, bringing the balance to XXXXComparison and Violations \\nA cross-analysis of the billing statement and bank statements reveals the following:\\nPayment Discrepancy: The bank statements show that on XXXX XXXX XXXX there was a deposit of XXXX  and a \"Returned\" transaction for a recurring payment of XXXX The billing statement from XXXX XXXX XXXX shows \"Returned\" payments on XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  the bank statement showed a balance of XXXX with a deposit of XXXX resulting in a balance of XXXX. A payment of XXXX, as shown on the XXXX billing statement, would not have been able to be covered by the funds in the bank. However, a payment of XXXX as shown on the billing statement for XXXX XXXX XXXX appears to have been covered by the funds. The bank statement does not show the specific payments to Cascade being returned. The billing statement from Cascade does not provide the payment method or card number used for the \"Returned\" payments, which is information that would be necessary to prove who is at fault for the payments not going through.\\nCFPB Complaint: The user\\'s request to add the lack of payment method details to a CFPB rebuttal is a valid point. The billing statement does not provide the level of detail necessary to determine whether the payment failures were due to insufficient funds or an error on the part of the lender. This lack of transparency and detail could be considered a violation of consumer protection laws, as it hinders a consumer\\'s ability to verify the accuracy of their account and payments.\\n\\n\\nProvide bank statements \\nSubmit a follow up complaint to MAG and FTC providing them with this info and documentation requesting broader regulatory review and also one with the tribal regulatory authority\\n\\n Focus on showing payment was blocked due to their system, not your bank.\\n\\nExplain why thats deceptive and unfair.\\n\\nAttach proof (portal errors, bank statement, phone call notes).\\n\\nEviction notice a direct result of the interest charges and damages proof and how it is supporting evidence damage \\n\\nCredit report with XXXX XXXX XXXX XXXX and all the loans not able to pay back do to the interest charges\\n\\nProvide XXXX XXXX XXXX  around the time of loan late payments\\n\\nAnd look to see if there are any overdraft fees around that time and show how it is supporting evidence \\n\\nThere after eviction notice. Cns notes around that time XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX \\n\\n\\nTo CFPB:\\n\\nI respectfully submit this rebuttal to the company\\'s response concerning my complaint originally filed on XXXX XXXX  under complaint number . Their response contains factual inaccuracies, omits relevant details, and fails to address the deceptive and unfair practices involved in the rejection of my timely loan payment.\\n\\n\\n---\\n\\nA. Summary of the XXXX XXXX XXXX for XXXXn\\nThe company\\'s response claims that my loan payment was rejected due to issues associated with my financial institution. However, my evidence shows:\\n\\nSufficient funds were available in my XXXX XXXX  account at the time of attempted payment.\\n\\nThe payment portal issued an error message, not indicating any issue on my bank\\'s end (no insufficient funds or payment returned notification).\\n\\nCascades representative admitted verbally that only one payment entry per day was allowed, regardless of the bank used.\\n\\nTheir payment system lacked transparency and restricted retry options, resulting in a loss of timely payment opportunity despite my readiness and ability to pay.\\n\\n\\nThese facts contradict the companys position and demonstrate systematic negligence or deception in how the payment portal functioned and how they addressed my situation.\\n\\n\\n---\\n\\nB. Relevant Violations and Consumer Rights\\n\\n1. Deceptive Practice  12 U.S. Code  5531 &  5536 (Consumer Financial Protection Act):\\n\\n> Prohibits \"unfair, deceptive, or abusive acts or practices\" (UDAAPs) in connection with any consumer financial product or service.\\n\\n\\n\\nBy offering a portal that misrepresents payment capacity and restricts resubmission while blaming the bank for failure, the company committed a deceptive practice.\\n\\nTheir failure to disclose system limitations (e.g., one attempt per day rule) resulted in financial harm and misinformation.\\n\\nDepriving consumers of a second opportunity to pay on the same day due to arbitrary system restrictions qualifies as an unfair practice.\\n\\n\\n2. Failure to Investigate and Provide Evidence (FCRA & CFPB Guidelines):\\n\\n> Financial institutions responding to CFPB are expected to substantiate claims with clear records.\\n\\n\\n\\nCascade failed to provide documentation validating that the issue was with Chase Bank, such as ACH rejection codes, NSF notice, or bank correspondence.\\n\\nThey did not offer proof that they attempted to assist me in resolving the issue or offer an alternative payment method immediately.\\n\\nTheir lack of documentation or proof of bank failure is a failure to reasonably investigate and respond in good faith.\\n\\n\\n\\n---\\n\\nC. Evidence I Am Submitting in Support of Rebuttal\\n\\n1. Bank statement showing available funds on XXXX XXXX. Screenshot or description of the portal error message (indicating failure, not NSF).\\n\\n\\n3. Phone log or notes from the conversation with Cascades rep admitting the \"one entry per day\" rule.\\n\\n\\n4. Loan billing statement showing the payment was rejected or missed, causing interest and fee accrual.\\n\\n\\n5. Screenshot or timeline showing no other payment method options on the portal at the time.\\n\\nWilling to provide XXXX XXXX XXXX XXXX XXXX when submitting won\\'t be visible due to privacy protection have to be loaded in portal to view.\\n\\n\\n\\n---\\n\\nD. Why This Is a Violation and Justifies Damages\\n\\nThe misrepresentation of payment failure source (blaming my bank without proof) caused credit harm and fee accrual.\\n\\nThe failure to provide a functional, fair portal deprived me of my right to pay on time, especially if limited to one entry daily.\\n\\nCascade\\'s failure to provide evidence or fair recourse constitutes an unfair and deceptive practice.\\n\\nThese practices caused financial and emotional damages, including:\\n\\nLate fees and interest charges\\n\\nDamage to my credit score\\n\\nTime and cost involved in dispute resolution\\n\\nEmotional stress due to false accusations of non-payment\\n\\n\\n\\n\\n---\\n\\nE. Damages and Corrective Action Requested\\n\\nI request that the CFPB consider this rebuttal and:\\n\\n1. Reopen the investigation and request that Cascade Springs/Credit Acceptance:\\n\\nProvide actual bank rejection documentation\\n\\nAcknowledge the portal\\'s limitations\\n\\nWaive all fees and interest accrued from this error\\n\\nRemove any  credit marks caused by this payment issue\\n\\n\\n\\n2. Determine whether this constitutes deceptive conduct unnegativeder UDAAP, which would allow for:\\n\\nStatutory and compensatory damages\\n\\nRestitution of any amounts improperly charged\\n\\nFurther CFPB regulatory action\\n\\n\\n\\n\\n\\n---\\n\\nF. Additional Notes:\\n\\nIf this matter is not resolved fairly, I reserve the right to pursue claims under:\\n\\nMichigan Consumer Protection Act\\n\\nFCRA\\n\\nUDAP laws\\n\\nCivil litigation or arbitration\\n\\nComplaints to the Attorney General of Michigan, FTC, and State Banking Regulators\\n\\n\\nLegal Theories and Violations Potentially Involved\\n\\nA. Deceptive Practices / UDAP (Unfair, Deceptive, or Abusive Acts or Practices)\\n\\nBlocking or restricting repayment options via technical/system design flaws.\\n\\nAdmitting \"only one payment submission allowed per day\" without disclosing this in advance.\\n\\nCausing failed payments despite sufficient funds.\\n\\nCharging interest and fees due to their own system failures.\\n\\n\\n Relevant Law:\\n\\nCFPB: Dodd-Frank Act  12 U.S. Code  5531\\n\\nMichigan Consumer Protection Act (MCPA) (MCL 445.901 et seq.)\\n\\n\\n\\n---\\n\\n---\\n\\nC. Breach of Contract / Good Faith and Fair Dealing\\n\\nIf your contract allowed you to make payments on time, and they sabotaged that ability via flawed systems, it may be a breach.\\n\\nFailure to maintain a reliable payment portal could violate implied duties.\\n\\n\\n\\n---\\n\\n 2. Key Evidence You Need to Gather\\n\\nTo validate and support your CFPB rebuttal and legal claims, gather:\\n\\n Screenshot of payment error\\n\\n Bank statement showing sufficient funds at time of attempted payment\\n\\n Portal error messages or lack of bank rejection notice\\n\\n Recordings or logs from Cascade admitting one payment per day\\n\\n The billing statement showing interest charges or fees after the failed payment\\n\\n Any notice or lack thereof about limitations in the payment system\\n\\n\\n\\n---\\n\\n\\n\\n---\\n\\n 4. \\n>  This number increases if you prove willfulness, repeated violations, or significant negative impact.\\n\\n\\n\\n\\n---\\n\\n Next Steps for You\\n\\n1. Finalize Your Rebuttal to the CFPB:\\n\\nFocus on showing payment was blocked due to their system, not your bank.\\n\\nExplain why thats deceptive and unfair.\\n\\nAttach proof (portal errors, bank statement, phone call notes).\\n\\n higher damages, pursue in civil court or arbitration.\\n\\nKeep detailed records of financial harm and emotional impact.\\n\\n\\n\\n3. Filed With Other Agencies \\n\\nFTC for deceptive practices\\n\\nMichigan AG Consumer Protection Division\\n\\nConsider consulting a consumer protection attorney\\n\\nSummary of Key Issues and Points of Contention\\n\\n1. Cascade Springs Credit\\'s Claims (from their CFPB response):\\n\\nThey assert that:\\n\\nYour account was never past due.\\n\\nNo late fees or collections were applied.\\n\\nNo credit reporting was made by them.\\n\\nNo system error was found on their end.\\n\\nPayment failed due to your bank/card, not their system.\\n\\n\\nThey claim to have closed your account Paid in Full.\\n\\n\\n\\n2. Your Rebuttal and Supporting Evidence:\\n\\nYou attempted payment multiple times.\\n\\nTheir system blocked your card but accepted a different one, without warning that one would fail or not be accepted.\\n\\nPortal errors directly caused an interest increase, leading to negative credit impacts and economic harm.\\n\\nYou suffered emotional distress, and credit damage, and were denied housing and other financing options.\\n\\n\\n\\n\\n\\n---\\n\\n Request:\\n\\nProof of no credit reporting (send a demand letter or get a declaration).\\n\\nCopy of their system logs and payment gateway vendor logs.\\n\\nAn explanation of why your card was blocked and no override or manual support was available.\\n\\nA copy of their loan agreement, with details on payment method disclosures.\\n\\n\\n\\n\\n---\\n\\n 2. \\n---\\n\\n What Must Be on a Legally Compliant Billing Statement (per TILA and Regulation Z)\\n\\nWhether tribal or not, the Truth in Lending Act (TILA) (15 U.S.C.  1601 et seq.) and Regulation Z (12 CFR Part 1026) require lenders to disclose the following on periodic billing statements:\\n\\n1. Creditor/Lenders Identity\\n\\nFull legal name of the lender\\n\\nContact information (address, phone, etc.)\\n\\n\\n2. Payment Information\\n\\nTotal amount due\\n\\nPayment due date\\n\\nBreakdown of the payment (principal, interest, fees, past due, etc.)\\n\\nLate fee information (amount and date assessed or to be assessed)\\n\\n\\n3. Transaction History\\n\\nList of all transactions or charges (e.g., disbursements, interest accrual, fees added, payments received)\\n\\nDates and descriptions of each entry\\n\\n\\n4. Interest Rate and Fees\\n\\nAnnual Percentage Rate (APR)\\n\\nDaily interest rate or method of calculation\\n\\nFees added (e.g., service fees, NSF, late charges)\\n\\n\\n5. Account Summary\\n\\nStarting balance\\n\\nTotal payments and credits\\n\\nNew charges\\n\\nEnding balance\\n\\n\\n6. Dispute Instructions\\n\\n\\n\\n---\\n\\n Sovereign Immunity  Immunity from All Laws\\n\\nEven tribal lenders:\\n\\nCannot misrepresent terms\\n\\nCannot block access to billing records\\n\\nCannot use technical failures as a shield\\n\\nAre still accountable to CFPB and FTC\\n\\n\\nThe CFPB, FTC, and state AGs have successfully sued tribal lenders for abusive practices (e.g., CFPB v. XXXX XXXX XXXX.\\n\\nI would like to note have requested a full billing for which they provided me with and like stated above it lacks important details which is a violation list those violations again and not the legal requirements under TILA\\n\\nWhat Must Be on a Legally Compliant Billing Statement (per TILA and Regulation Z)\\n\\nWhether tribal or not, the Truth in Lending Act (TILA) (15 U.S.C.  1601 et seq.) and Regulation Z (12 CFR Part 1026) require lenders to disclose the following on periodic billing statements:\\n\\n1. Creditor/Lenders Identity\\n\\nFull legal name of the lender\\n\\nContact information (address, phone, etc.)\\n\\n\\n2. Payment Information\\n\\nTotal amount due\\n\\nPayment due date\\n\\nBreakdown of the payment (principal, interest, fees, past due, etc.)\\n\\nLate fee information (amount and date assessed or to be assessed)\\n\\n\\n3. Transaction History\\n\\nList of all transactions or charges (e.g., disbursements, interest accrual, fees added, payments received)\\n\\nDates and descriptions of each entry\\n\\n\\n4. Interest Rate and Fees\\n\\nAnnual Percentage Rate (APR)\\n\\nDaily interest rate or method of calculation\\n\\nFees added (e.g., service fees, NSF, late charges)\\n\\n\\n5. Account Summary\\n\\nStarting balance\\n\\nTotal payments and credits\\n\\nNew charges\\n\\nEnding balance\\n\\n\\n6. Dispute Instructions\\n\\nStatement of your right to dispute charges (under the Fair Credit Billing Act if applicable)\\n\\nHow to do so and time limit (usually 60 days)\\n\\n\\n\\n\\n---\\n\\n Sovereign Immunity  Immunity from All Laws\\n\\nEven tribal lenders:\\n\\nCannot misrepresent terms\\n\\nCannot block access to billing records\\n\\nCannot use technical failures as a shield\\n\\nAre still accountable to CFPB and FTC\\n\\n\\nThe CFPB, FTC, and state AGs have successfully sued tribal lenders for abusive practices (e.g., CFPB XXXX XXXX XXXX XXXX\\n\\nformal letter demanding a compliant billing statement and\\n---\\nCFPB Rebuttal (To Submit Within 60 Days of Company Response)\\n\\nSubject: Rebuttal to CFPB Complaint Response Cascade Springs Credit\\nConsumer NameXXXX XXXX XXXX XXXX XXXX XXXXn---\\n\\nDear CFPB,\\n\\nThis is my formal rebuttal to the response submitted by Cascade Springs Credit regarding my complaint. I dispute their findings on the grounds that they failed to properly investigate the root cause of the payment processing failure and failed to comply with federal disclosure laws, particularly those under the Truth in Lending Act (TILA) and the Dodd-Frank Act regarding unfair, deceptive, or abusive acts or practices (UDAAP).\\n\\n\\n---\\n\\n A. Cascade Springs Violated TILA Billing Statement Requirements\\n\\nI requested a billing statement to review the legitimacy of the interest, late fees, and charges assessed against me. However, the billing statement provided was not compliant with TILA (15 U.S.C.  1601) and Regulation Z (12 CFR  1026).\\n\\nThe document failed to include:\\n\\nThe full legal name of the lender\\n\\nPayment due dates\\n\\nTotal payment amount due\\n\\nInterest rates (APR)\\n\\nBreakdown of charges and how they were calculated\\n\\nAccount summary (starting balance, new charges, payments received, ending balance)\\n\\n\\nThese omissions violate Regulation Z  1026.7 & 1026.6, and deprived me of the ability to verify the legitimacy of the account and the amount owed.\\n\\n\\n---\\n\\n B. Cascade Springs Did Not Properly Investigate the Payment Error\\n\\nI made a good-faith attempt to pay through the portal on [insert date], using a reputable institution (Chase Bank) with sufficient funds. The portal returned an error and did not process the payment, but I did not receive any insufficient funds notification from my bank. That suggests the fault lay with Cascades payment system, not my financial institution.\\n\\nAdditionally, a Cascade representative admitted that only one payment entry is allowed per day regardless of the bank used. If the portal fails once, consumers are locked out, leaving no other means to pay the bill that day. This technical limitation is both unreasonable and deceptive, especially if the system misfires.\\n\\nThis system flaw constitutes a deceptive practice under Dodd-Frank  1031 and reflects bad faith in administering a billing and payment system that penalizes consumers for its own failures.\\n\\n\\n---\\n\\n C. Deceptive Practices and UDAAP Violations\\n\\nCascades failure to:\\n\\nAllow more than one payment submission per day\\n\\nProvide accurate payment failure reasoning\\n\\nDisclose or document the interest or fees charged\\n\\nComply with TILA or consumer billing rights\\n\\n\\nconstitutes unfair and deceptive practices under the Dodd-Frank Act, CFPB regulations, and potentially state UDAP laws (e.g., Michigan Consumer Protection Act if applicable).\\n\\n\\n---\\n\\n D. Economic Harm and Damages\\n\\nAs a result of Cascades failure to allow my timely payment and provide accurate billing:\\n\\nI incurred additional late fees and interest through no fault of my own.\\n\\nMy credit profile may be harmed if negative reporting occurred.\\n\\nI was denied a fair opportunity to dispute or understand the debt.\\n\\nTheir negligent, willful noncompliance caused stress and financial loss.\\n\\n\\nPer TILA  1640(a), I am entitled to:\\n\\nCategory\\tPotential Recovery\\n\\nStatutory Damages\\tUp to XXXXnActual Damages\\tAmount of late fees, interest overcharges, and credit harm\\nAttorneys\\' Fees\\tRecoverable if legal action is taken and judgment won\\nPunitive Damages\\tPotentially applicable due to bad faith and deception\\n\\n\\n\\n---\\n\\n E. Relief Sought\\n\\n1. Full compliance with billing statement laws (TILA, Reg Z).\\n\\n\\n2. Waiver or reversal of all late fees and interest accrued due to payment error.\\n\\n\\n3. Assurance of no negative credit reporting.\\n\\n\\n4. Referral for potential enforcement action or penalty if violations are deemed intentional.\\n\\n\\n5. Permission to seek additional remedies in civil court if necessary.\\n\\n\\n\\n\\n---\\n\\n F. Supporting Evidence Available Upon Request\\n\\nBank records showing sufficient funds at time of attempted payment\\n\\nScreenshots or notes regarding payment portal error\\n\\nCopies of Cascades billing statement lacking legal disclosures\\n\\nRecorded notes from call with Cascade representative confirming 1 payment/day limit\\n\\nCFPB TILA/Reg Z requirements\\n\\n\\n\\n---\\n\\n Closing\\n\\nCascade Springs Credit has acted in bad faith, failed to comply with federal law, and designed a system that harms consumers unfairly. I ask that the CFPB hold them accountable for these violations and provide relief consistent with the consumer protection standards your office upholds.\\n\\nSincerely,\\n[Your Full Name]\\n[Your Address]\\n[Phone Number]\\n[Email Address]\\n\\n---\\nBecause of financial hardship which stems from economic hardship caused by cascade springs credit I because homeless, multiple hospitalizations sleeping outside I lost my phone and because I lost my phone at this point time I am going through the proper channels to retrieve addition records, call logs between myself the consumer and cascade springs in which when find the call on log prove sale representative admitting to one payment try per day and aware that if it doesn\\'t go through even in no fault of your own will still receive additional interest charges \\n\\n SUMMARY OF YOUR ACTIONS TAKEN\\n\\n1.  Affidavit and Information Request Sent to T-Mobile\\n\\nYou created and submitted an affidavit and formal request to XXXX asking for:\\n\\nCall logs for a specific period.\\n\\nOutgoing calls made to Cascade Springs.\\n\\n\\nEmails Sent to Cascade Springs (via XXXXn\\nYou sent multiple complaints, requests for explanation, and notices through your Gmail account.\\n\\nThese emails outlined:\\n\\nThat your card had sufficient funds.\\n\\nThat you made attempted payments that were denied.\\n\\nRequests for clarification and justification.\\n\\nI am coordinating with attorney:Subpoena to XXXXnsubpoena duces tecum compelling T-Mobile to release:\\nCall detail records (CDRs) for your phone number.\\n\\nOutgoing call logs made to Cascade Springs.\\n\\nPossibly text message metadata (not content without a warrant).\\n\\nCopies of previous records requests you\\'ve submitted.\\n\\n\\nLegal basis: Under Michigan and federal laws, XXXX can release this under subpoena if it\\'s relevant to pending litigation or discovery.\\n\\nSubpoena or Motion to Preserve Gmail Records XXXX)\\nFile a court order or subpoena to XXXX requesting:\\n\\nInbox and sent messages between your Gmail address and Cascades email(s).\\n\\n\\nSubject: Rebuttal to Cascade Springs Credit Response  CFPB Case #[Insert Case Number]\\n\\nTo Whom It May Concern:\\n\\nI am submitting this rebuttal in response to Cascade Springs Credits reply to my Consumer Financial Protection Bureau (CFPB) complaint. Their response is factually inaccurate, incomplete, and conflicts with the documented evidence I have or have attempted to preserve through lawful means.\\n\\n\\n---\\n\\nI. Conflict Between Companys Statement and My Records\\n\\nCascade Springs asserts that my payment was rejected due to issues with my financial institution. This is demonstrably false:\\n\\nMy XXXX XXXX account had sufficient available funds on the date the payment was submitted.\\n\\nThe denied payment attempt generated an error within Cascades online portalnot from XXXX XXXX which never issued an insufficient funds (NSF) notice.\\n\\nWhen I contacted Cascade customer service, a representative acknowledged that only one payment attempt per day is allowed, regardless of error, card, or bank. This system design flaw directly obstructed timely repayment.\\n\\n\\nThis establishes a technical error or limitation in Cascades payment systemnot a fault of mine. Their failure to allow further attempts in the same day, coupled with rejecting a valid payment and then applying late fees and interest, constitutes:\\n\\nDeceptive Practices, in violation of the Dodd-Frank Act (12 U.S.C.  5531).\\n\\nFailure to reasonably facilitate payment, violating the principle of good faith and fair dealing.\\n\\nViolation of 15 U.S.C.  1692e(2) (Fair Debt Collection Practices Act), due to the misrepresentation of the nature and amount of debt resulting from a system error.\\n\\n\\n\\n---\\n\\nII. Cascades Failure to Provide Detailed Billing Statements\\n\\nCascade Springs has not provided clear, itemized billing statements as required under consumer protection laws, including:\\n\\nBreakdown of principal, interest, fees, and charges\\n\\nDate-specific itemization\\n\\nNotice of payment denials and method of rejection\\n\\n\\nEven if Cascade operates under tribal lending exceptions, they are still subject to federal consumer protection laws when collecting debt or reporting to credit bureaus. Their refusal to provide itemized statements prevents a borrower from verifying debt accuracya violation of FCRA (15 U.S.C.  1681s-2) and applicable Regulation Z disclosures under TILA.\\n\\n\\n---\\n\\nIII. Preservation and Evidence Retrieval Efforts\\n\\nDue to device issues and cloud service limitations, I currently lack access to certain screenshots and call logs that would definitively prove my payment attempt and communication with Cascade.\\n\\nHowever, I have taken the following active steps to retrieve supporting evidence:\\n\\n1. Submitted a notarized affidavit and records request to XXXX  seeking call logs and text history between [Insert Dates] to confirm communications made to Cascade Springs from my number.\\n\\n\\n2. Requested a subpoena through legal counsel to compel Cascade Springs and/or XXXX  to release customer service call recordings and logs.\\n\\n\\n3. Initiated efforts to recover XXXX XXXX XXXX account access, which contained emails I sent to Cascade documenting repeated failed payment attempts and lack of support responses.\\n\\n\\n4. Willing to submit those emails and logs to the CFPB and any court, once recovered, to prove Cascade was aware of the ongoing issue and failed to resolve it.\\n\\n\\n\\nThese actions show I have made reasonable, lawful attempts to preserve and obtain records, despite the technical barriers. Any missing documentation is not due to neglect or fabrication, but rather third-party access limitations beyond my control.\\n\\n\\n---\\n\\nIV. Legal and Equitable Grounds for Relief\\n\\nI request that the CFPB:\\n\\nInvestigate Cascades payment system limitations and deceptive billing practices\\n\\nRequire Cascade to produce all internal logs and error messages tied to my account\\n\\nInvalidate all fees and negative credit entries that resulted from the rejected payment attempt and technical errors\\n\\nEnforce Cascades duty under the FCRA, TILA, and Dodd-Frank to correct any false or misleading billing or credit reporting\\n\\nRecognize Cascades failure to provide documents under MCL 408.483a (Employee Records Act) if applicable to employment or consumer file requests\\n\\n\\nAdditionally, I seek damages related to:\\n\\nEmotional distress from wrongful late charges and credit harm\\n\\nEconomic harm from negative credit reporting\\n\\nRegulatory fines where willful and bad-faith conduct is proven\\n\\n\\n\\n---\\n\\nV. Closing\\n\\nThis rebuttal, supported by third-party affidavit and pending subpoena requests, demonstrates that Cascades explanation lacks factual basis and fails to address critical violations. I respectfully request this dispute remain open and investigated further. Upon successful data retrieval from XXXX  and other services, I am prepared to submit additional supporting documentation and legal affidavits.\\n\\nSincerelyXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX","date_sent_to_company":"2025-08-07T22:44:26.000Z","issue":"Charged fees or interest you didn't expect","sub_product":"Payday loan","zip_code":"48322","tags":null,"has_narrative":true,"complaint_id":"15156558","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Rosebud Economic Development Corporation","date_received":"2025-08-07T22:34:48.000Z","state":"MI","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'Should a billing <em>statement</em> include which form of payment method was use to make payment whether it was accepted or <em>denied</em> or the card ending number and it should the cascade billing <em>statement</em> does not provide that detail let cfpb of this and that it would further prove that misrepresenting what actually occurred and who would actually be at fault for a payment not going through when sufficient funds are present add this to the cfpb rebuttal which they failed to properly <em>investigate</em> now providing"]},"sort":[9.313251,"15156558"]},{"_index":"complaint-public-v1","_id":"4583087","_score":8.7258005,"_source":{"product":"Credit card or prepaid card","complaint_what_happened":"Summary : I feel that I have been treated unfairly and unreasonably by HSBC Bank, USA, N.A.. I hope with your involvement, they will be reasonable in accessing my experience with their organization and reaching a fair resolution. I am getting your organization involved as HSBC has continued to act unreasonably and unfairly with the involvement of the Arizona Attorney Generals Office, XXXX XXXX XXXX, and the various Credit Reporting Agencies. \n\nGiven your organization federal mandate to focus on the fair treatment of consumers by XXXX XXXX, lenders, and other financial companies I feel you may be best equipped to help us reach a resolution to this matter. Thank you advance for your assistance. \n\nI opened an HSBC Credit Card account on XX/XX/XXXX to take advantage of 0 % APR promotion that they had solicited to me. After opening the account, I immediately draw the {$5000.00} balance of the card to take advantage of the promotion 0 % APR offer. I also immediately attempt to set-up an online profile and payment but am unable to access any account information or set-up automatic payments as HSBC requires a unique PIN that is provided via USPS mail.\n\nI request the PIN from HSBC on numerous ( at least three ) occasions, yet never receive it. On one of those occasion ( XX/XX/XXXX ) I am told that the extenuating circumstances of my case would be escalated to management and resolved, but never received any follow-up from HSBC.\n\nThe account becomes out of sight and out of mind as there is no follow through by HSBC. Eventually, my account is assigned to a debt collector,XXXX XXXX XXXX XXXX. HSBC is unreasonable in admitting their contribution to the situation. I pay off the account in full on XX/XX/XXXX and immediately report the payoff to HSBC. HSBC responds stating the information they are reporting is accurate, although they are continuing to incorrectly report the account with a balance. I am denied credit by XXXX XXXX on XX/XX/XXXX. I launch a complaint through the Credit Reporting Agencies which HSBC reports to ( XXXX, XXXX, and XXXX XXXX on XX/XX/XXXX. HSBC finally updates the inaccurate reporting of the {$4100.00} balance, however, XXXX  still has {$4100.00} write-off in the account status ( when the account was paid in-full ), and XXXX  and XXXX still has charge-off as the account status. ( Credit Reports Attached ) The details of my case are below and attached. \n\n\nTimeline : On XX/XX/XXXX, I opened a HSBC Credit Card account in response to a promotional 0 % APR mailing I received. I used the full $ XXXX balance given the attractive offer to invest in markets. Immediately after receiving the credit card by mail I attempted to register online to set-up automatic payments, but was unable to do so as setting up an online account with HSBC requires a unique individual four-digit PIN that they send you via United State Postal Service and I had not received mine. \n\n\nOn XX/XX/XXXX I proactively reached out to HSBC to notify them that I have not received the required PIN. I ask that they help me set-up automatic payments over the phone, which they say they are unable to accommodate. They tell me another PIN will be sent. I never receive the PIN. ( XXXX Phone Record Attached ) On XX/XX/XXXX I received a call from HSBC that my account is past due. Frustrated - I tell them I had requested a PIN on multiple occasions and have yet to receive one. I also previously asked to set up automatic payments over the phone, but their systems/policy wouldn't allow it. I asked for another PIN to be sent so I can access my account online and set-up payments. They tell me they will send me one in the mail. ( XXXX Phone Record Attached ) On XX/XX/XXXX - I received a call from HSBC that my account is now in collections. Incredibly frustrated, I explain that I have requested the PIN to be able to access my account on numerous occasions and have never received it. Additionally, I have requested automatic payments be set-up over the phone they have been unable to accommodate my request. The collections agent said that he apologies for the error and that my case would be escalated to management/supervisor where it would be fixed/resolved. Assured that this would be corrected, I make a payment in the amount of {$1200.00} to bring my account current and make an additional payment of {$750.00} as a token of good will, explaining I am willing and able to pay the balance in-full based on the follow-up of the escalation. Again I never received a PIN, nor any follow-up from HSBC. ( XXXX Phone Record Attached ) ( Attached Credit Reports reflect payment ) In XX/XX/XXXX, I received a letter from XXXX XXXX XXXX XXXX that my account was assigned to them to collect the debt on my HSBC credit card. ( Letter Attached ) In XX/XX/XXXX, I received another letter from XXXX XXXX XXXX XXXX offering me to resolve my indebtedness for {$2800.00}, versus the account balance of {$4100.00}. ( Letter Attached ) In or around XXXX XXXX, I reached out to XXXX XXXX  XXXX  XXXX  explaining there is likely a misunderstanding around my account. I always had the intention, ability, and willingness to pay the account in full and on-time. XXXX XXXX XXXX XXXX states they will contact HSBC. \n\n\nXX/XX/XXXX, I am told HSBC 's position remains unchanged. I file a formal complaint with the credit reporting agencies and the AZ Attorney General 's Office. On XX/XX/XXXX, I file disputes with HSBC and XXXX  and XXXX  disputing the accuracy of the account. \n\n\nXX/XX/XXXX, I receive email ( attached ) that my case ID : XXXX is assigned the complaint number XXXX and assigned to XXXX XXXX. ( Email Attached ) XX/XX/XXXX - I receive the attached letter from HSBC that my complaint / dispute was reviewed and determined to be accurate. No changes are to be made and the case is to be closed. ( Letter Attached ) XX/XX/XXXX - I email XXXX XXXX ( attached ) asking for additional information regarding their conclusion. ( Email Attached ) XX/XX/XXXX - I receive the attached letter stating they did mail the PIN ( although I never received it ). And that there was no evidence of bank error. ( Letter Attached ) XX/XX/XXXX - I email XXXX explaining I never received the PIN, and was promised this matter was going to be resolved by management when I made the payment on XX/XX/XXXX, the conversation happened on a recorded line and would be discoverable under any reasonable investigation into my complaint. ( Email Attached ) Throughout XX/XX/XXXX - I work with XXXX XXXX XXXX XXXX to see if they can negotiate cleaning up the credit reporting for a full payoff of the debt. \n\n\nXX/XX/XXXX - I receive an email from XXXX XXXX XXXX attached XXXX which states that \" a search for telephone records associated the number yielded no results ... our position remains unchanged '' ( Email Attached ). My phone records show the inaccuracy or incompleteness of their search. \n\n\nXX/XX/XXXX - I send XXXX XXXX and XXXX XXXX XXXX Interim Head of Customer Relations at HSBC, who XXXX has CC on correspondence ) additional details regarding my case via email. ( Email Attached ) XX/XX/XXXX Frustrated without any response or resolution from HSBC with the updated information, I pay off the account in-full {$4100.00} via XXXX XXXX at XXXX XXXX XXXX XXXX. I am provided the payment confirmation number XXXX. I immediately email HSBC notifying them of the payment. ( Email Attached ) ( XXXX XXXX Statement Showing Payment Attached ) ( XXXX XXXX XXXX XXXX Proof of Payment Attached ). \n\n\nXX/XX/XXXX - I receive a letter from HSBC stating that they reviewed my case, there's no evidence of bank error, and they consider the case closed. Additionally, XXXX 's response incorrectly references the Attorney General of Nevada, when in fact the complaint has been filed with the Attorney General Office of Arizona. Although, this may simply be an oversight I fear it shows the lack of reasonable effort their organization has taken to address my concern and correct this issue. ( Letter Attached ). \n\n\nXX/XX/XXXX - I received a letter from XXXX XXXX that my recent credit application was denied, because of a charged-off account on my credit history. I immediately pull my credit reports to find that the HSBC account is still incorrectly showing a balance of {$4100.00} and they have not updated the account to show the XXXX payment. XXXX XXXX XXXX XXXX Denial Letter Attached ) ( Credit Reports Attached ) XX/XX/XXXX I file a formal dispute with XXXX, XXXX, and XXXX ) on XX/XX/XXXX ( Dispute Letters Attached ). Each respond over the next 30-days, correcting the inaccuracy of the {$4100.00}, however, XXXX  still has {$4100.00} write-off in the account status ( when the account was paid in-full ), and XXXX  and XXXX still has charge-off as the account status. ( Dispute Letters and Response Letters Attached ) ( Credit Reports Attached )","date_sent_to_company":"2021-07-28T23:49:48.000Z","issue":"Other features, terms, or problems","sub_product":"General-purpose credit card or charge card","zip_code":"85255","tags":null,"has_narrative":true,"complaint_id":"4583087","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"HSBC NORTH AMERICA HOLDINGS INC.","date_received":"2021-07-28T21:22:53.000Z","state":"AZ","company_public_response":null,"sub_issue":"Other problem"},"highlight":{"complaint_what_happened":["HSBC is unreasonable in <em>admitting</em> their contribution to the situation. I pay off the account in full on XX/XX/XXXX and immediately report the payoff to HSBC. HSBC responds <em>stating</em> the information they are reporting is accurate, although they are continuing to incorrectly report the account with a balance. I am <em>denied</em> credit by XXXX XXXX on XX/XX/XXXX. I launch a complaint through the Credit Reporting Agencies which HSBC reports to ( XXXX, XXXX, and XXXX XXXX on XX/XX/XXXX."]},"sort":[8.7258005,"4583087"]},{"_index":"complaint-public-v1","_id":"14479151","_score":7.8161926,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"This complaint is a formal challenge to TransUnions ongoing failure to reinvestigate and correct the inaccurate reporting of my XXXX XXXX XXXX and XXXX XXXX credit card accounts. I am not disputing the existence of these accounts, but rather challenging the following : False and Unverifiable Ownership Claims Improper Billing After Account Closure Deceptive Settlement Practices Misreporting of Payment Activity Failure to Verify Information with Evidence Refusal to Correct or Delete Unverifiable Data XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX Dispute Investigations Challenged : CFPB Complaint # XXXX Response dated XX/XX/XXXX TransUnion Investigation Results dated XX/XX/XXXX TransUnion Investigation Results XXXX XX/XX/XXXX Despite submitting extensive documentationincluding bank records, settlement communications, and contradictory letters from the furnishers themselvesTransUnion marked both accounts as verified as accurate on XX/XX/XXXX and XX/XX/XXXX, and issued a vague investigation summary in the XX/XX/XXXX, response to CFPB Complaint # XXXX. This repeated pattern of superficial responses and refusal to correct known inaccuracies violates my rights under the Fair Credit Reporting Act ( FCRA ). \n\nSupporting evidence previously submitted in full. This complaint includes only updated investigation results, creditor letters, and SEC ownership documents to avoid duplication. \n\nThe issues outlined in this challenge apply to all three reinvestigation attempts, as they reflect a systemic failure by TransUnion to conduct a good faith and meaningful investigation in accordance with FCRA 611 ( a ) and Metro 2 compliance standards. \n\nThe sections that follow will outline specific discrepancies, timeline contradictions, ownership concerns, and regulatory violations supporting my request for full deletion or immediate correction of both accounts. \n\n1. Unverifiable Ownership Supported by SEC Filings ( EX-10.2 ) XXXX XXXX XXXX XXXX  is not the legal owner of the debts associated with XXXX XXXX XXXX XXXX XXXX  accounts. As shown in the attached Amended and Restated Receivables Sales Agreement ( EX-10.2 ) between XXXX XXXX XXXX XXXX  and XXXXXXXX XXXX XXXX XXXXXXXX ( a subsidiary of XXXX XXXX XXXX XXXX XXXX Bank hereby agrees to sell, transfer, assign, set-over, and otherwise convey to Receivables Purchaser, without recourse one hundred percent ( 100 % ) of the Receivables generated by Bank EX-10.2, Section 2 ( a ) This agreement confirms : 100 % of credit card receivables are sold by the XXXX XXXX XXXX \nThe sale is without recourse and structured as a true sale, not a secured loan. \nThe Bank retains only servicing duties, not ownership. \n\nAs a result, XXXX XXXX XXXX XXXX  lacks legal standing to furnish tradeline data or pursue settlement collection after sale. Therefore, XXXX XXXX and XXXX XXXX brands under this structureare not legally reporting with verified ownership authority. Any credit reporting after the transfer constitutes a violation of the FCRA and must be corrected. This confirms XXXX, XXXX XXXX nor XXXX XXXX had the authority to credit report or collect on the account and neither entity retains ownership. So what entity verified and or validated this account? \n\nXXXX. Illegally Billing After Account Closure Contradictory letters and billing statements reveal that both XXXXXXXX XXXX XXXX XXXX XXXXXXXX XXXX continued to charge fees and send billing statements for 6 months after the accounts were officially closed. This is illegal and violates federal consumer protection standards, including the Credit CARD Act and FCRA. \nXXXX XXXX Account closed on XX/XX/XXXX, per creditor response letters. \nDespite this, XXXX XXXX continued billing late fees through at least XX/XX/XXXX, disguised as settlement activity. \nTheir XX/XX/XXXX, letter explicitly admits : The fees continued to bill on the unpaid balance correctly.This is legally questionable. Once the account is closed and restricted, the creditor can not bill additional monthly fees unless expressly permitted in a settlement contract, which they refused to provide as stated in all of their letters. \n\nKey Timeline & Amounts : XX/XX/XXXX email : Account balance stated as {$390.00} XX/XX/XXXX email : Account balance increased to {$430.00} a {$41.00} increase in under XXXX weeks without explanation XX/XX/XXXX : I paid a total of {$400.00} Remaining amount due ( based on {$430.00} ) : {$34.00}, or at most {$75.00} if you consider the higher balance Despite this, I made additional payments : {$41.00} on XX/XX/XXXX {$50.00} on XX/XX/XXXX Yet on XX/XX/XXXX, I received another email stating I owed {$100.00}, with {$73.00} due to bring the account current. If the account was closed in XXXX how would {$73.00} bring the account current. Internal billing errors do not excuse this abusive behavior. \nXX/XX/XXXX email : Claimed account was past due {$150.00} I paid {$120.00} over the {$75.00} potentially remainingyet continued receiving emails stating I was past due and being forced into an unverifiable settlement arrangement with no written terms, no proof of what the fees represented, and no disclosure of why my balance continued increasing. \n\nSummary : I made four post-closure payments, totaling {$520.00}, on an account they admitted was closed. The additional billing was illegal, lacked transparency, and held no contractual justification. \n\nXXXX XXXX Account closed on XX/XX/XXXX, per creditor response letters. \nYet XXXX XXXX also continued charging fees and requiring payments through XX/XX/XXXX, with the same vague language as XXXX XXXX. \nIn the XX/XX/XXXX, letter, they stated the account continued to bill on the unpaid balance correctly after closuredespite no legal or contractual authority to do so. \nKey Timeline & Amounts : XX/XX/XXXX email : Balance stated as {$440.00} XX/XX/XXXX email : Balance increased to {$450.00} XX/XX/XXXX : I paid {$400.00} Remaining amount should have been no more than {$54.00} {$50.00} payment on XX/XX/XXXX made under pressure from phone agents claiming fees would continue even though the account was closed Yet : XX/XX/XXXX email : Balance claimed was {$160.00}, with {$110.00} due XX/XX/XXXX email : Account reported as {$200.00} past due In total, I paid {$450.00} after closure on an account that shouldve only had a {$54.00} balance. There was no explanation for how balances increased to over {$200.00} after closure. I received monthly billing statements for 7 consecutive months with no activity, and again was never provided with written settlement terms despite multiple requests. \n\nAccording to federal billing standards and the Credit CARD Act, once a credit card account is closed and restricted : No further interest or fees should accrue unless transparently disclosed Creditors can not bill as if the account is still open without violating consumer rights Neither XXXX XXXX XXXXor XXXX XXXX  met these standards. They failed to explain what fees were being charged, how balances increased post-closure, or why settlement terms could not be documented. This pattern of ongoing billing on closed accounts, paired with refusal to provide settlement confirmation, constitutes illegal, unfair, and abusive practices under UDAAP, the FCRA, and the CARD Act. In additional all of this illegal creditor behavior on account they do not have ownership on, but Transunion verified and validated accounts as reporting accurately. All of this was documented in my XX/XX/XXXX CFPB complaint. \n\nXXXX. Contradictory Statements by Furnishers The written responses provided by XXXX XXXX XXXX XXXX XXXX XXXX  contain multiple contradictions, making it clear that the information reported to TransUnion was not only unverifiable but based on inconsistent and unreliable records. These contradictions reinforce the conclusion that TransUnion failed to properly investigate under the FCRA. \n\nXXXX. Payment Denial vs. ConfirmationIn the CFPB responses dated XX/XX/XXXX and XX/XX/XXXXXXXX XXXX XXXX claimed that only a {$55.00} payment had been received, and XXXX XXXX claimed only a {$54.00} payment had been received. However, in subsequent responses dated XX/XX/XXXX and XX/XX/XXXX, both furnishers confirmed that all payments from XX/XX/XXXX through XX/XX/XXXX had been received and properly posted. These are the exact payments I referenced in my initial disputes, including the {$300.00} and {$100.00} payments made in XX/XX/XXXX, that they also stated to have never received. \n\nThis directly contradicts their earlier denial of those same payments and clearly demonstrates that their recordkeeping is flawed, and their credit reporting can not be relied upon. TransUnions decision to mark these tradelines as verified based on such conflicting information shows a failure to review or assess the accuracy of the evidence provided by the furnishers. \n\nXXXX. Post-Closure Billing In multiple lettersincluding the XX/XX/XXXX responsesboth furnishers acknowledge that the accounts were closed due to delinquency in XX/XX/XXXXXXXX XXXX XXXX XXXX XXXX  and XX/XX/XXXX XXXX XXXX XXXX XXXX  Despite this, both companies continued to bill fees and send monthly statements well into XX/XX/XXXX. This contradicts their own closure dates and suggests that they improperly treated the accounts as active long after they were legally closed and restricted. The billing of late fees and continued monthly updates during this period is misleading, unlawful, and unsupported by any transparent contractual basis. \n\nXXXX. Settlement Completed After Closure In the XX/XX/XXXXXXXX XXXX XXXX XXXX letter, the creditor states that the settlement was completed on XX/XX/XXXX. However, they had already confirmed that the account was closed on XX/XX/XXXX. This means they continued billing, collecting, and reporting the account for over seven months after it was no longer open. This timeline is inherently contradictoryan account can not simultaneously be closed and restricted and active and accruing fees toward a settlement. These contradictions show that no accurate or consistent account history exists. \n\nXXXX. Claims of Original Creditor StatusNeither XXXX XXXX XXXX XXXX XXXX  clearly identify XXXX XXXX XXXX XXXX XXXX the original creditor in their CFPB responses. Instead, they repeatedly state that no third party is involved, which is false and misleading by omission. This omission is significant, because it misrepresents the true ownership structure of the accounts and conceals the securitization and sale of the receivables. \nSEC-filed documentationspecifically the Amended and Restated Receivables Sales Agreement ( EX-10.2 ) proves that XXXX XXXX XXXX XXXX sells 100 % XXXX its receivables ( credit card debt ) to XXXXXXXX XXXX XXXX XXXX XXXX subsidiary XXXX XXXX XXXX XXXX, without recourse . The agreement states : Bank hereby agrees to sell, transfer, assign, set-over, and otherwise convey to Receivables Purchaser, without recourse one hundred percent ( 100 % ) of the Receivables generated by Bank EX-10.2 , Section 2 ( a ) This confirms that XXXX XXXX XXXX XXXX  does not retain ownership of the accounts and has no legal standing to furnish derogatory tradelines or collect post-sale. Its role is limited to servicing. Therefore, by failing to acknowledge the role of XXXX or XXXX, and by denying any third-party involvement, the furnishers have provided materially false and misleading information. \n\nThis misrepresentation of ownership and reporting authority directly violates the Fair Credit Reporting Act ( FCRA ) and undermines the legal basis for TransUnions verification of these tradelines. \n\nWhy These Contradictions Are Legally Significant and Undermine Verification Each of the contradictions outlined above represents a direct violation of the Fair Credit Reporting Act ( FCRA ) and the Credit Reporting Agencies ' duty to ensure the maximum possible accuracy of consumer credit information. According to FCRA 611 ( a ), TransUnion is legally obligated to conduct a reasonable reinvestigation of any disputed account. That includes evaluating whether the information furnished is consistent, supported by documentation, and based on accurate account records. None of those conditions were met here. \nThe payment denial vs. confirmation issue proves that furnishers initially misrepresented the facts of payment history. This means material account data was falseyet TransUnion still marked the information as verified, despite having my bank records and the creditors later confirmations that all payments were received. \nThe post-closure billing contradiction shows that both furnishers treated the accounts as active months after closure, billing fees and updating balances. This is not just misleadingit is illegal under federal law, including the Credit CARD Act, which restricts new charges or fees after closure unless properly disclosed and contractually agreed. TransUnion 's failure to question or investigate this ongoing billing activity on closed accounts shows gross negligence in their reinvestigation. \nThe settlement completion after account closure contradiction makes clear that the furnishers were applying settlement terms to accounts that were no longer legally collectible in the same way. The fact that balances were still increasing and being reported as past due months after closure, without written settlement documentation, renders the reporting inherently unverifiable. \nThe claim that no third party was involved, despite clear evidence from SEC documents that all receivables were sold to a third-party entity ( XXXX XXXX ), represents an intentional concealment of the actual creditor structure. This omission invalidates any claim that the furnishersor XXXX XXXX XXXX XXXXXXXX ongoing legal authority to report or collect on the debt. The FCRA requires accurate reporting of both account status and ownership, and TransUnion had a duty to investigate the ownership when I provided this documentation. \nGiven these contradictions, TransUnion could not have reasonably verified the accuracy of these accounts without either ignoring or disregarding the conflicting evidence and lack of supporting documentation. Therefore, TransUnion is in violation of FCRA 611, and the continued reporting of these tradelines is unlawful. These accounts must be corrected to reflect their true post-settlement statusor deleted entirely as unverifiable, misleading, and harmful to the consumer. \n\nTransUnion Continued Reporting After Account Closure Violates FCRA Accuracy Requirements Both the XXXX XXXX  and XXXX XXXX accounts were formally closed in XX/XX/XXXX and XX/XX/XXXX, respectively. This is not speculativeit is clearly documented within TransUnions own credit report entries, which list the closure months explicitly. \nDespite this, TransUnion continued to allow furnishers to report balances, delinquencies, and settlement activity on these closed accounts well into XXXX, with past due statuses and payment updates reflected through XX/XX/XXXX. \n\nMost egregiously, TransUnion allowed : Past due balances to be reported in months when the accounts were already closed Monthly activity updates for accounts with no legitimate post-closure usage Settlement remarks and delinquency notations based on unverifiable, post-closure charges Ongoing tradeline updates without properly marking the accounts as Closed To date, TransUnion has still failed to notate either account as Closed, which creates the false impression that these are active or collectible debts. This is inaccurate and harmful, and it directly contradicts the closure information TransUnion already had on file. \nNothing should be reported on a closed accountespecially not delinquency notations or continued balance updates. Once an account is closed and restricted, it must reflect only its final resolved status. \n\nViolation of FCRA 607 ( b ) Under the Fair Credit Reporting Act, TransUnion is legally obligated to : Follow reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates. FCRA 607 ( b ) That obligation does not permit blind reliance on furnishers, especially when : The account is documented as closed No purchases or charges occurred post-closure No written settlement documentation exists The consumer has provided contradictory evidence showing overpayment and incorrect balances By continuing to report : Post-closure delinquency and balance activity Settled status based on no formal agreement Past due amounts for periods when accounts were not even legally billable TransUnion affirmatively misrepresented the nature, status, and accuracy of both accounts. \n\nCRA Liability Is Independent of the Furnisher Even if a furnisher continues sending data after closure, TransUnion is not absolved of its responsibility under the FCRA. Regulatory guidance and case law are clear : a credit reporting agency must : Independently assess whether the data is internally consistent, Confirm that it is factually supported, And determine whether it is legally reportable. \n\nIn this case, none of that occurred. TransUnion ignored the closure dates, overpayment evidence, and contradictory furnisher statements, and chose to continue publishing derogatory data on two accounts that should have been resolved or removed.\n\nTransUnions decision to continue reporting both accounts well into 2024, while knowing they were closed in 2023, is a clear violation of FCRA 607 ( b ). It contradicts their own records, fails to meet basic verification standards, and further confirms that the accounts are inaccurate, unverifiable, and legally reportable only if corrected or deleted entirely. \n\nTransUnions Settled for Less Than Full Balance Remark Is Misleading and Unsubstantiated TransUnion currently reports both the XXXX XXXX XXXX XXXX XXXX XXXX  accounts with the derogatory remark : SETTLED LESS THAN FULL BALANCE. \nThis is factually inaccurate, legally unsupported, and damaging to my credit profile. The remark implies that I failed to fulfill my repayment obligations when I, in fact, overpaid both accounts based on the actual balances stated at the time of closurenot on the inflated post-closure fees later added by the furnishers. \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 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  Overpayment : {$140.00} These are overpayments when measured against the balances provided by the furnishers in their own emails at the time of closure. The only reason the balances later appeared to increase was because unauthorized fees and charges were added post-closure, which I repeatedly disputed as unlawful and unsupported. I did not agree to those fees, nor did I authorize continued billing after account closure. \nAll of this informationincluding my bank statements, creditor emails showing original balances, and objections to the additional feeswas submitted in my initial disputes and was available to TransUnion during their reinvestigation. \n\nTransUnions Verification Failure Despite receiving this supporting documentation, TransUnion : Failed to reconcile the true account balances with the payments made Did not obtain or request any written settlement agreement to justify the settled for less remark Ignored clear evidence that I paid more than what was owed at closure This remark was accepted from the furnisher without verification, despite the fact that the furnishers themselves admitted in their XX/XX/XXXX letters that no settlement letter could be located. \nIn the XX/XX/XXXX, XXXX XXXX letter, they stated : Your request for a copy of the letter confirming the settlement terms was reviewed. We do not locate a letter regarding a settlement offer dated XXXX. \nSo how was TransUnion able to verify a settlement occurred, let alone claim it was settled for less, if the creditor couldnt even produce documentation to support it? \nViolation of FCRA and Metro 2 Guidelines Under the Fair Credit Reporting Act ( FCRA ) and Metro 2 industry standards, TransUnion is not permitted to : Rely solely on furnisher data that is contradicted by consumer evidence Report settled for less status without written, verifiable settlement terms Ignore overpayment evidence and knowingly furnish inaccurate derogatory remarks This conduct violates : FCRA 607 ( b ) failure to ensure accuracy FCRA 611 ( a ) failure to reinvestigate properly Metro 2 guidelines prohibition on reporting settlement status without documentation 4. Failure to Provide Settlement Letter Despite confirming that I was enrolled in a settlement arrangement, neither XXXX XXXX XXXX XXXX XXXX XXXX XXXXr provided a written agreement outlining the settlement terms, payment schedule, or total payoff amount. Instead, they both stated that a settlement letter would only be issued after all payments had been madeleaving me with no written confirmation during the active settlement period. \n\nThis was not a one-time miscommunication. I received multiple settlement offer emails over several months, and I accepted the initial offer because the furnishers kept billing fees on a closed account and refused to stop unless a settlement was reached. However, even after I accepted that first settlement offer, I continued receiving new settlement emails each monthwith different amounts and terms. \n\nWhen I contacted their customer service to ask why settlement offers continued arriving after I had already accepted one, I was told they had no record of ever sending a settlement offer at all. This was deeply concerning. Their denial of the very email offers I received ( and accepted ) led me to request formal documentation proving I was enrolled in a settlementbut they repeatedly refused to provide it, as clearly shown in their CFPB response letters. \n\nFrom XXXX XXXX ( XX/XX/XXXX ) : The agent informed you a letter would be sent upon completion of the last settlement payment and to call to confirm it was completed. \nThis left me without any settlement letter during the full payment periodmeaning I had no protection if the terms changed or if they later misapplied payments. \n\nFrom XXXX XXXX ( XX/XX/XXXX ) : Only XXXX payment of {$54.00} has been received for the settlement... In the absence of any evidence of error in our reporting of the account, we are unable to fulfill the request to remove the account from the credit bureau reports. \nThis statement dismisses the multiple payments I made and my proof of those paymentsand relies on the existence of a settlement they simultaneously deny ever offering or documenting. \n\nFrom XXXX XXXX ( XX/XX/XXXX ) : We did not locate a copy of a letter confirming the settlement offer you referenced. \nThis contradicts their earlier acknowledgment that I was in a settlement and further demonstrates their internal records are incomplete, inconsistent, or deliberately withheld. \n\nFrom XXXX XXXX XXXX XXXX XXXXXX/XX/XXXX ) : On XX/XX/XXXX, you agreed to pay the account for less than the balance and agreed to the amount of {$100.00} ... On XX/XX/XXXX, the settlement was completed, and the remaining balance was written off. \nDespite this acknowledgment of a settlement arrangement and completion, no letter was ever issued confirming the agreed terms, and my repeated requests were either ignored or dismissed. I completed all settlement payments by XX/XX/XXXX, and still received no documentation to reflect this. \n\nFrom XXXX XXXX ( XX/XX/XXXX ) : Your request for a copy of the letter confirming the settlement terms was reviewed. We do not locate a letter regarding a settlement offer dated XX/XX/XXXX. \nThis is particularly alarming because my payments were made based on that exact offer. Their denial of the agreements existence after accepting the payments reveals a serious procedural flaw or intentional deception. \n\nWhy This Is Deceptive and Legally Problematic The repeated refusal to provide written confirmation of a settlementwhile continuing to bill on a closed account, furnish negative credit data, and send conflicting settlement offersdemonstrates a pattern of deceptive and abusive conduct. \nThis prevented me from : Validating the terms of my agreement Disputing errors with supporting documentation Confirming completion of my obligations Protecting myself from ongoing derogatory credit reporting This conduct violates FCRA, FDCPA, and UDAAP standards by denying me the transparency and documentation I needed to resolve the account. Worse, TransUnion relied on the furnishers undocumented claims to continue verifying negative tradeline data. \nA valid settlement agreement must be documented. If the furnishers can not or will not produce such documentation, the credit reporting must be considered unverifiable and deleted. \n\n\n5. TransUnions Violations of FCRA TransUnion failed to meet its duty under FCRA 611 to : Conduct a reasonable reinvestigation Provide a description of the process Verify the data using competent evidence Delete unverifiable information if the furnisher can not confirm ownership and accuracy Instead, TransUnion relied on data furnishers who issued inconsistent, incomplete, and contradictory responses. \n\nAdditional Section : Why TransUnion 's Verification Was Inadequate and Legally Deficient Despite my submission of clear, documented contradictions and errors, TransUnion closed my disputes dated XX/XX/XXXX, and XX/XX/XXXX with claims that no changes were needed or that the items had been verified. This position is not only unsupported by the evidenceit also violates the Fair Credit Reporting Act ( FCRA 611 ) and industry standards under Metro 2 guidelines, which require credit reporting agencies to ensure the maximum possible accuracy of the data they report. \n\nTransUnions Reporting Confirms the Problem According to the investigation summaries provided by TransUnion : For XXXX XXXX XXXX  TransUnion shows : Account closed : XX/XX/XXXX Last payment received : XX/XX/XXXX Reporting status : Paid, closed ; was 6090 days past due Delinquency listed : 90 days past due in XX/XX/XXXX Remark : \" Settled for less than full balance '' For XXXX XXXX TransUnion shows : Account closed : XX/XX/XXXX Last payment received : XX/XX/XXXX Reporting status : Paid, closed ; was paid as agreed Delinquency listed : 90 days past due in XX/XX/XXXX Remark : \" Settled for less than full balance '' These summaries confirm that TransUnion knowingly accepted and reported post-closure payment activity as settlement payments without requiring proper validation or documentation of the settlement agreements. This is not just carelessit contradicts the FCRAs requirement that data must be verifiable and accurate. \nThe Legal Issues : 1. No Settlement Letter ExistsBoth furnishers refused to provide documentation proving I was under an official settlement arrangement. Without such documentation, TransUnion had no legal or factual basis to verify settled for less status or any associated payment updates. Per FCRA 611 ( a ) ( 1 ) ( A ), CRAs must conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate.\n\n2. Account Status vs. Payment Dates ConflictBoth accounts were closed in late XXXX, yet TransUnion shows last payments received in XX/XX/XXXX. This proves that TransUnion accepted ongoing reporting activity on closed accounts, which is a major compliance issue. No explanation was provided as to how payments made 67 months post-closure could lawfully update a closed tradelineespecially without proof of a settlement contract. \nXXXX. Furnisher Contradictions Were IgnoredThe same furnishers that TransUnion relied on to verify these accounts issued multiple CFPB responses that contradict themselves on key points, including : Payment amounts and dates Whether a settlement was ever offered Whether third parties were involved Whether accounts were still being billed post-closure XXXX. TransUnion ignored these contradictions entirely and provided no statement of how they resolved these conflicts before declaring the tradelines verified. \nXXXX. TransUnions Dispute Results Do Not Satisfy FCRA XXXX ( a ) ( XXXX ) I was never provided with : A description of how the reinvestigation was conducted The name, address, and documentation relied on from the furnisher Any explanation of how contradictory or missing information was reconciled Legal Grounds for Immediate Removal Based on the documented record of contradictions, misrepresentations, and TransUnions failure to lawfully reinvestigate or validate the disputed information, the continued reporting of these XXXX XXXX and XXXX XXXX tradelines is a clear violation of the Fair Credit Reporting Act ( FCRA ). Since XXXX, I have consistently provided accurate and detailed documentationincluding payment confirmations, closure notices, and regulatory filingsthat directly refute the furnishers claims. \n\nDespite this, TransUnion has willfully ignored the facts and maintained inaccurate, misleading, and incomplete tradelines, acting in partnership with the furnishers to suppress necessary corrections that would reflect my true credit history. This conduct violates : FCRA 611 ( a ) for failure to conduct a reasonable reinvestigation, FCRA 611 ( a ) ( 5 ) for failure to delete or correct information that can not be verified, FCRA 607 ( b ) for failure to ensure maximum possible accuracy in consumer reports, And violates the principles of Metro 2 compliance and the CFPBs guidance on dispute resolution and data accuracy obligations. \n\nGiven the overwhelming evidence that : The furnishers statements are internally inconsistent, The accounts were closed months prior to the reported payment activity, And payments were initially denied, then later acknowledged by the furnishers TransUnion had no legal or factual basis to validate or continue reporting these accounts as accurate or verifiable. \n\nAccordingly, I demand the immediate and permanent deletion of both tradelines from my TransUnion credit file and request that the Consumer Financial Protection Bureau hold TransUnion accountable for its failure to protect consumers from inaccurate and unverifiable credit reporting in violation of federal law.","date_sent_to_company":"2025-07-06T20:58:45.000Z","issue":"Problem with a company's investigation into an existing problem","sub_product":"Credit reporting","zip_code":"483XX","tags":null,"has_narrative":true,"complaint_id":"14479151","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"TRANSUNION INTERMEDIATE HOLDINGS, INC.","date_received":"2025-07-06T20:24:03.000Z","state":"MI","company_public_response":null,"sub_issue":"Their investigation did not fix an error on your report"},"highlight":{"complaint_what_happened":["This repeated pattern of superficial responses and refusal to correct known <em>inaccuracies</em> violates my rights under the Fair Credit Reporting Act ( FCRA ). \n\nSupporting evidence previously submitted in full. This complaint includes only updated <em>investigation</em> results, creditor letters, and SEC ownership documents to avoid duplication."],"issue":["Problem with a company's <em>investigation</em> into an existing problem"],"sub_issue":["Their <em>investigation</em> did not fix an error on your report"]},"sort":[7.8161926,"14479151"]},{"_index":"complaint-public-v1","_id":"17471474","_score":5.686048,"_source":{"product":"Mortgage","complaint_what_happened":"Please see attached rebuttal to complaint XXXX, outlining all the violations.\n\nThank you for reviewing my complaint. I am submitting this rebuttal because Shellpoint 's response contains significant inaccuracies, omissions, and unresolved issues. Their response does not address the core problems, and the servicing errors remain ongoing. I respectfully request that CFPB re-open my complaint for further investigation.\n\n1. SHELLPOINT 'S RESPONSE OMITS KEY FACTS AND FAILS TO ADDRESS DOCUMENTED ERRORS Several major issues remain unresolved : ( a ) Payments were rejected and returned after my loss mitigation application was acknowledged as complete.\n\nShellpoint 's letter dated XX/XX/XXXX states my application was complete and foreclosure protection was in place. After that date : Multiple weekly payments were rejected One payment was returned by check ( XX/XX/XXXX payment rejected XX/XX/XXXX ) Additional payments attempted through my bank were rejected These payment rejections are not addressed anywhere in Shellpoint 's response.\n\n( b ) Payment rejection pattern demonstrates bad faith Timeline of Shellpoint 's inconsistent conduct : XX/XX/XXXX - XX/XX/XXXX : Accepted my weekly {$170.00} payments XX/XX/XXXX : Rejected payments and referred loan to foreclosure attorney XX/XX/XXXX : Resumed accepting payments XX/XX/XXXX : Rejected payments again ( starting with XX/XX/XXXX payment, rejected XX/XX/XXXX ) This pattern prevents me from curing any actual delinquency and demonstrates Shellpoint 's bad faith in servicing my account.\n\n2. XXXX ADMITS ( AND SHELLPOINT INHERITED ) SYSTEMATIC ACCOUNTING ERRORS FROM XXXX Shellpoint 's XX/XX/XXXX response specifically acknowledges errors made by the prior servicer ( XXXX  ) : \" Errors were found in the construction of your XXXX-approved loan modification during XX/XX/XXXX to XX/XX/XXXX '' \" Payments received between XX/XX/XXXX, and XX/XX/XXXX, XXXXprior to the modification being bookedwere not applied according to the modification terms, contributing to further delinquency '' While these errors occurred under XXXXXXXX XXXX servicing ( before Shellpoint took over in XX/XX/XXXX ), Shellpoint : Inherited an account with known errors Took responsibility for these errors in their CFPB response Has NOT corrected the errors Is attempting to foreclose based on a delinquency created by these admitted errors Within 8 months of taking over servicing ( XX/XX/XXXX - XX/XX/XXXX ), Shellpoint filed a Notice of Default without : Correcting the inherited accounting errors Providing accurate accounting of my payments Giving me fair opportunity to cure any actual shortfall Properly crediting my payments made under Shellpoint 's servicing CRITICAL : The alleged delinquency that Shellpoint is foreclosing on was created by XXXXXXXX XXXX admitted errors , which Shellpoint has failed to correct.\n\n3. SHELLPOINT INCONSISTENTLY APPLIED THE XXXX MODIFICATION PARTIAL IMPLEMENTATION IS EVIDENCE THE MODIFICATION WAS ACTIVE Although Shellpoint claims the modification was not implemented, their own records and my current loan terms show : My current interest rate ( 4.125 % ) is the same rate contained in the XXXX modification My current monthly payment amount ( {$660.00} ) matches the XXXX modification payment exactly This indicates Shellpoint did implement parts of the modification, contradicting their written statement. Partial implementation is a recognized form of contract acceptance and raises serious concerns about the accuracy of their foreclosure basis.\n\nMoreover, I have been making payments in good faith reliance on the modification agreement since XX/XX/XXXX. \n4. PRINCIPAL BALANCE FIGURES ARE INCONSISTENT AND UNEXPLAINED Shellpoint 's letter lists contradictory principal balance figures : Loan history principal : {$110000.00} My loan history downloaded from Shellpoint 's system shows : {$110000.00} ( as of XX/XX/XXXX ) My XXXX modification agreement states : {$110000.00} Shellpoint 's XXXX proposed modification lists : {$120000.00} These figures contradict each other by more than {$10000.00} with no explanation.\n\nShellpoint provided no breakdown of : Which fees were capitalized Why the balance increased by $ XXXX despite payments made What calculations were used Whether misapplied payments from XXXX were corrected How the 13-year draw period error affected the balance This is directly responsive to my RESPA Notice of Error, yet they did not provide the required explanation under 12 U.S.C. 2605 ( e ).\n\n5. SHELLPOINT CONFIRMS THE DRAW PERIOD WAS INCORRECTLY RECORDED Their letter states their system incorrectly showed the draw period ending XX/XX/XXXX, when it actually ended XX/XX/XXXX ( per my original HELOC terms : 60-month draw period from XX/XX/XXXX ). \nShellpoint claims they corrected the draw period end date to XX/XX/XXXX after I brought it to their attention. This is STILL WRONG. My original HELOC agreement shows a 60-month ( 5-year ) draw period starting XX/XX/XXXX. Correct draw period end date : XX/XX/XXXX ( not XXXX, not XXXX ). \nThis means : The loan was serviced with fundamentally incorrect information Payments may have been applied as \" draw period '' ( interest-only ) when they should have been applied to principal Possible over-accrual of interest occurred The XXXX modification calculations may have been based on incorrect principal balance Their accounting is demonstrably unreliable Even Shellpoint 's `` correction '' to XX/XX/XXXX is still wrong by 5 years This directly impacts the accuracy of the principal balance, arrears calculation, and modification terms, yet Shellpoint provided no explanation of : How this error affected payment application Whether they recalculated the balance What my principal balance should actually be with correct payment application Whether the modification balance of {$110000.00} was calculated using the wrong draw period assumption 6. SHELLPOINT DID NOT RESPOND TO MULTIPLE REQUIRED RESPA/RFI ITEMS My Notice of Error and Request for Information requested : Full itemization of arrears with dates and amounts Payment-by-payment transaction history showing application to principal, interest, fees Itemization of capitalized amounts Explanation for conflicting principal balances Documentation related to rejected payments All internal servicing notes regarding the XXXX modification Complete accounting from XX/XX/XXXX to present Explanation of how bankruptcy trustee payments were applied Shellpoint did not provide or address these items. Regulation X ( 12 C.F.R. 1024.35 ) requires a substantive response to a Notice of Error. Their response is incomplete and does not satisfy their legal obligations under RESPA.\n\n7. SHELLPOINT 'S DENIAL OF DUAL TRACKING IS CONTRADICTED BY THE PAYMENT REJECTIONS AND TIMELINE Shellpoint claims foreclosure proceedings were paused during loss mitigation review. However, the timeline contradicts this : XX/XX/XXXX : Loan servicing transferred to Shellpoint XX/XX/XXXX : Shellpoint refers loan to foreclosure attorney ( per their letter ) XX/XX/XXXX : Notice of Default recorded XX/XX/XXXX : Shellpoint acknowledges my loss mitigation application is complete After XX/XX/XXXX : Shellpoint rejects multiple payments XX/XX/XXXX : Shellpoint sends CFPB response claiming delinquency Rejecting payments while a loss mitigation application is under review : ( 1 ) Prevents the borrower from curing any delinquency ( 2 ) Causes the alleged arrears to grow ( 3 ) Constitutes advancement of foreclosure proceedings ( 4 ) Violates the dual tracking prohibition under California Civil Code 2923.6 and Regulation X 8. SHELLPOINT FABRICATED A LOSS MITIGATION APPLICATION- I MADE NO SUCH APPLICATION Shellpoint 's XX/XX/XXXX letter states I submitted a complete loss mitigation application as of XX/XX/XXXX. \nTHIS IS CATEGORICALLY FALSE. \nIn XX/XX/XXXX, my ONLY contact with Shellpoint was : - Making my regular weekly {$170.00} bill pay payments - Payments made through my bank 's automated bill pay system - No other communication of any kind I did NOT in XX/XX/XXXX : - Submit any loss mitigation application ( online, mail, fax, or in person ) - Call Shellpoint to request loss mitigation - Email Shellpoint about loss mitigation - Send any documents to Shellpoint- Authorize anyone to apply on my behalf - Log into any Shellpoint online portal - Sign any application forms I have bank records proving my only activity was routine bill pay payments. Shellpoint fabricated this application. Why would Shellpoint do this?\n\n1. To create appearance of regulatory compliance : By claiming to 'evaluate ' me for loss mitigation, they appear to comply with regulations requiring servicers to consider alternatives to foreclosure.\n\n2. To justify quick denial : They could 'evaluate ' the fake application and deny it ( XX/XX/XXXX ), claiming they considered alternatives.\n\n3. To justify payment rejections : While 'evaluating ' the fake application, they rejected my payments ( starting XX/XX/XXXX ), increasing alleged arrears.\n\n4. To avoid honoring my XX/XX/XXXX modification : By treating me as a new applicant rather than someone with an existing modification.\n\nTIMELINE OF FABRICATED APPLICATION SCHEME : - XX/XX/XXXX : Shellpoint determines application complete - XX/XX/XXXX : Shellpoint sends letter acknowledging application and telling me to continue to make your monthly payments - XX/XX/XXXX : I make my regular weekly {$170.00} payment ( following their XX/XX/XXXX instruction ) - XX/XX/XXXX : Shellpoint REJECTS my XX/XX/XXXX payment. Shellpoint also cuts me a check for my XX/XX/XXXX payment ( 5 days after telling me to make payments ). \n- XX/XX/XXXX : Shellpoint denies fabricated application ( only 14 days later ) - XX/XX/XXXX : Shellpoint tells CFPB they're in compliance with regulations This is fraud. Shellpoint : 1. Fabricated an application I never submitted 2. Used it to create false paper trail 3. Rejected my payments immediately after acknowledging the fake application 4. Quickly denied the application they fabricated 5. Used this charade to advance foreclosure while claiming regulatory compliance I request CFPB investigate : 1. What application Shellpoint claims to have received XX/XX/XXXX 2. What documents they claim I submitted 3. How I allegedly submitted this application 4. Whether Shellpoint has any record of actual communication from me in XX/XX/XXXX 5. Whether Shellpoint has engaged in this practice with other borrowers Shellpoint can not foreclose based on fabricated applications and manufactured denials.\n\n9. SHELLPOINT VIOLATED ITS OWN WRITTEN INSTRUCTION TO MAKE PAYMENTS Timeline of Shellpoint 's contradictory conduct : XX/XX/XXXX : Shellpoint sends letter stating : - My alleged application grants me protection from foreclosure - I should continue to make monthly payments according to your loan agreement XX/XX/XXXX : Following Shellpoint 's written instruction, I made my regular weekly {$170.00} payment via bill pay ( as I had been doing for years ). \nXX/XX/XXXX : Shellpoint REJECTED/RETURNED my XX/XX/XXXX payment.\n\nThis means : 1. Shellpoint instructed me in writing to make payments ( XX/XX/XXXX ) 2. I made a payment in direct reliance on that instruction ( XX/XX/XXXX ) 3. Shellpoint rejected the payment I made following their instruction ( XX/XX/XXXX ) 4. This occurred during the alleged 'evaluation period ' when foreclosure protection supposedly applied Shellpoint can not : - Tell me to make payments in writing - Reject payments I make following those instructions - Use rejected payments to justify foreclosure - Claim I'm not paying when they won't accept payments The 5-day gap between payment submission ( XX/XX/XXXX ) and rejection ( XX/XX/XXXX ) proves this was a deliberate, affirmative decision by Shellpoint to reject my payment during the evaluation period.\n\nThis demonstrates : - The evaluation was a sham with predetermined denial - Payment rejection was part of scheme to increase arrears- Shellpoint 's bad faith in servicing my account This XX/XX/XXXX payment was part of my consistent pattern of weekly payments I had been making for years. I was continuing my established payment schedule in compliance with both my XX/XX/XXXX modification and Shellpoint 's XX/XX/XXXX written instruction.\n\nShellpoint 's rejection of this payment - made in direct response to their written directive - is evidence of bad faith, breach of their own instructions, and advancement of foreclosure during a supposed evaluation period.\n\n10. SHELLPOINT FAILED TO ADDRESS CRITICAL PAYMENT INFORMATION My complaint specifically detailed the payments I made, which Shellpoint completely ignored : I MAKE WEEKLY PAYMENTS I make payments of {$170.00} per week ( not monthly ), which equals MORE than the required {$660.00} monthly payment.\n\nLooking at Shellpoint 's loan history statement : - Multiple {$170.00} entries per month clearly show weekly payment pattern - I was CONSISTENTLY OVERPAYING the required amount - Yet principal balance remained flat at around {$110000.00} for 20+ months This proves Shellpoint could not properly handle weekly payments and failed to : 1. Apply the extra to principal 2. Properly credit weekly payments as they were received 3. Notify me if weekly payments caused processing issues I was paying EXTRA to reduce my debt faster. Shellpoint 's system failure in handling weekly payments should not result in foreclosure.\n\nTOTAL PAYMENTS MADE SINCE MODIFICATION ( XX/XX/XXXX - XX/XX/XXXX ) : My post-modification principal balance was {$110000.00}, which included all arrears, fees, and advances up to that date I paid {$16000.00} of the required down payments of {$15000.00} ( {$930.00} over required ) I paid payments totaling {$10000.00} between XXXX and when Shellpoint improperly stopped accepting payments.\n\nThe bankruptcy trustee made additional payments totaling {$7600.00} ( XXXX ) I resumed weekly payments on XX/XX/XXXX and paid {$4600.00} up until Shellpoint improperly stopped accepting payments.\n\nTOTAL PAYMENTS : {$39000.00} According to modification, these are the facts, REQUIRED PAYMENTS : Down payment : {$15000.00} Monthly payments ( 42 months {$660.00} ) : {$28000.00} TOTAL REQUIRED : {$43000.00} ACTUAL SHORTFALL, including months of rejected payments ( if all payments properly applied ) : Approximately {$4400.00} This represents approximately 6-7 months of payments - a manageable amount that I should have been given clear opportunity to cure.\n\nInstead, Shellpoint : Claims I am delinquent from XX/XX/XXXX Has not explained where my {$39000.00} in payments went Refuses to provide an accurate accounting Rejects my attempts to continue making payments I have paid {$39000.00} in good faith to perform under the modification. Shellpoint 's failure to properly apply these payments created the alleged delinquency.\n\n11. ADDITIONAL VIOLATIONS NOT ADDRESSED IN SHELLPOINT 'S RESPONSE ( a ) Harassment from Third-Party Solicitors Since the Notice of Default was filed on XX/XX/XXXX, multiple third-party solicitors have been calling my adult children regarding this debt. These unsolicited calls have caused additional stress and embarrassment to my family. While Shellpoint may not be directly making these calls, the filing of the NOD made my personal financial situation public record, leading to this harassment.\n\n( b ) Documented Emotional Distress and Harassment The stress from Shellpoint 's conduct has caused severe documented harm : Emergency room visit for XXXX XXXX ( thought I was having a XXXX XXXX ) Ongoing physical symptoms including chest pains and ulcer-like symptoms Constant phone calls, mail, and door knocking Public humiliation from foreclosure notice posted on XXXX Harassment of my children Shellpoint 's response shows no acknowledgment of the harm their admitted errors have caused.\n\n( c ) California Homeowner Bill of Rights Violations If Shellpoint questions whether California HBOR applies to HELOCs, California Civil Code 2924.12 ( d ) states protections apply to \" any entity that seeks to foreclose on a mortgage or deed of trust '' on residential property. My HELOC is secured by my primary residence and therefore protected.\n\nShellpoint has violated : Accurate information requirements Good faith servicing obligations Dual tracking prohibitions 12. SHELLPOINT 'S PROPOSED \" RESOLUTION '' IS INADEQUATE AND UNACCEPTABLE Shellpoint 's XX/XX/XXXX letter states they \" waived legal and foreclosure-related fees totaling {$2500.00} '' with only a {$25.00} NSF fee remaining.\n\nThis is inadequate because : It does not correct the underlying accounting errors they admitted It does not explain where my {$39000.00} in payments were applied It does not credit my {$930.00} down payment overpayment It does not provide the accurate principal balance It does not rescind the wrongfully-filed Notice of Default It does not address their payment rejection pattern It does not resolve the 13-year draw period error 's impact Waiving fees they should never have charged in the first place does not resolve systematic accounting fraud and breach of contract.\n\n13. SHELLPOINT 'S XX/XX/XXXX DENIAL LETTER PROVES THEY ARE NOT HONORING MY EXISTING MODIFICATION On XX/XX/XXXX, Shellpoint sent me a letter denying me for various loss mitigation programs, stating my housing debt-to-income ratio is out of the acceptable range.\n\nThis denial reveals the core problem : 1. I already have a valid, fully executed loan modification dated XX/XX/XXXX, with monthly payments of {$660.00} on a principal balance of {$110000.00}, acknowledged by the bankruptcy court.\n\n2. I do not need new loss mitigation - I need Shellpoint to honor the existing modification agreement they inherited from XXXX. \n3. Shellpoint evaluated me as if I have no modification, determined I don't qualify for new programs, and is now proceeding with foreclosure.\n\n4. This constitutes breach of contract. Shellpoint can not : - Refuse to honor a valid modification agreement - Require me to re-qualify for a modification I already have - Foreclose because I don't meet criteria for NEW loss mitigation Shellpoint 's position is clear : They do not recognize my XX/XX/XXXX modification as valid and binding. This is precisely why they have been misapplying my payments and rejecting my weekly payments that exceed the required $ XXXXmonth. \nI am not seeking new loss mitigation. I am demanding Shellpoint honor the existing modification agreement I have with my lender.\n\n14. THE ISSUES REMAIN UNRESOLVED AND REQUIRE FURTHER INVESTIGATION At this time : My account history is still incorrect My XXXX modification has not been correctly applied My payments totaling {$39000.00} have not been properly credited My principal balance remains inconsistent and unexplained My arrears remain unverified and unexplained My rejected payments remain unexplained My draw period was misrepresented for thirteen years with no accounting correction Foreclosure proceedings continue despite unresolved servicing errors I am unable to make payments due to Shellpoint 's rejections CONCLUSION Shellpoint has admitted in writing to : Years of accounting errors ( XX/XX/XXXX - XX/XX/XXXX ) Misapplication of modification payments 13-year draw period configuration error ( XXXX, and even their \" correction '' to XXXX is still wrong by 5 years ) Servicing errors requiring \" corrections '' Despite these admissions, they have not corrected my account and continue to pursue foreclosure based on a delinquency THEY CREATED through their own errors.\n\nI have paid {$39000.00} in good faith to perform under my modification agreement, making WEEKLY payments exceeding the required $ XXXX/month. I should not lose my home because Shellpoint failed to properly account for my payments.\n\nAdditionally, Shellpoint fabricated a loss mitigation application I never submitted, then rejected my payments while claiming to \" evaluate '' me, then denied the fabricated application - all while refusing to honor my valid XX/XX/XXXX modification agreement.\n\nThe issues raised in my original complaint remain completely unresolved. Shellpoint 's response does not satisfy their obligations under RESPA and does not provide the accurate accounting I am legally entitled to receive.\n\nI respectfully request CFPB 's continued oversight of this matter, as Shellpoint 's conduct has caused severe financial and emotional hardship for me and my family.\n\nThank you for your attention to this serious matter.","date_sent_to_company":"2025-11-24T21:19:28.000Z","issue":"Struggling to pay mortgage","sub_product":"Home equity loan or line of credit (HELOC)","zip_code":"90746","tags":null,"has_narrative":true,"complaint_id":"17471474","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Shellpoint Partners, LLC","date_received":"2025-11-24T21:01:44.000Z","state":"CA","company_public_response":"Company believes it acted appropriately as authorized by contract or law","sub_issue":"An existing modification, forbearance plan, short sale, or other loss mitigation relief"},"highlight":{"complaint_what_happened":["I am submitting this rebuttal because Shellpoint 's response contains significant <em>inaccuracies</em>, omissions, and unresolved issues. Their response does not address the core problems, and the servicing errors remain ongoing. I respectfully request that CFPB re-open my complaint for further <em>investigation</em>.\n\n1."]},"sort":[5.686048,"17471474"]},{"_index":"complaint-public-v1","_id":"6583808","_score":4.0653353,"_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":["XXXX  should have reduced my interest to 0% and just offer to pay me a XXXX statutory damage amount while not <em>admitting</em> or <em>denying</em> 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."]},"sort":[4.0653353,"6583808"]},{"_index":"complaint-public-v1","_id":"6583809","_score":4.060375,"_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":["XXXX  should have reduced my interest to 0% and just offer to pay me a XXXX statutory damage amount while not <em>admitting</em> or <em>denying</em> 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."]},"sort":[4.060375,"6583809"]}]},"aggregations":{"has_narrative":{"meta":{},"doc_count":8,"has_narrative":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":1,"key_as_string":"true","doc_count":8}]}},"product":{"doc_count":8,"product":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Credit reporting, credit repair services, or other personal consumer reports","doc_count":2,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Credit reporting","doc_count":2}]}},{"key":"Debt collection","doc_count":2,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Credit card debt","doc_count":1},{"key":"Federal student loan debt","doc_count":1}]}},{"key":"Credit card or prepaid 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