{"took":210,"timed_out":false,"_shards":{"total":5,"successful":5,"skipped":0,"failed":0},"hits":{"total":{"value":7,"relation":"eq"},"max_score":null,"hits":[{"_index":"complaint-public-v1","_id":"20753330","_score":19.707228,"_source":{"product":"Credit card","complaint_what_happened":"Product/Service : Credit Card Issue : Problem with a company 's investigation into an existing problem ( Account Security & Access ) Complaint Description : I am filing this complaint regarding Chase XXXX  systemic failure to provide accessible security controls for my credit card account, which has resulted in an unmitigated and ongoing fraud risk. \n\nXXXX. Logical Failure in Identity Verification ( XXXX  Mismatch ) While I obtained a XXXX credit card in XX/XX/XXXX, my formal tax identification ( ITIN ) was not issued until XXXX, and I did not establish a meaningful credit or public financial record before that time. Before XXXX, I had no significant financial or tax footprint in the XXXX that would generate public records. However, XXXX  identity verification process relies on security questions regarding home mortgages and auto loans from prior to XXXX. As I had no such financial activities during that period, it is physically impossible for me to answer these questions correctly. This creates a systemic verification failure that bars me from establishing an online account, leaving me without any means to monitor my transactions or manage my account security. This flaw may create a disparate impact on international or XXXX customers who are effectively denied the same security protections as domestic residents. \n\nXXXX. Denial of Critical Risk-Mitigation Tools Due to my inability to access online banking, I requested that Chase temporarily freeze my credit card as a preventative security measure since XXXX. This request was denied multiple times by customer service representatives, citing \" internal system limitations. '' Denying a customer the ability to freeze their own cardespecially when they are already locked out of online monitoringconstitutes a denial of a reasonable and standard security control. \n\nXXXX. XXXX XXXX XXXX XXXX XXXX ( XX/XX/XXXX ) On XX/XX/XXXX, I escalated this matter to a supervisor. I explicitly informed Chase that I am currently located internationally and can not visit a physical branch until after XX/XX/XXXX. Despite this, the only solution provided was a text link that required me to log in to an online account to freeze the card. Since my core complaint is the inability to create an online account, providing a solution that requires XXXX is not only dismissive but entirely non-functional. No alternative remote verification ( such as a secure document upload ) was offered. \n\nXXXX. XXXX XXXX and XXXX As a result of these failures, I am exposed to ongoing financial risk without any means of self-protection. XXXX  refusal to act on a manual security request, while knowing their automated systems are failing a verified customer, raises serious concerns regarding their ability to safeguard consumer accounts","date_sent_to_company":"2026-03-29T04:32:02.000Z","issue":"Other features, terms, or problems","sub_product":"General-purpose credit card or charge card","zip_code":"XXXXX","tags":null,"has_narrative":true,"complaint_id":"20753330","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"JPMORGAN CHASE & CO.","date_received":"2026-03-29T04:15:51.000Z","state":null,"company_public_response":null,"sub_issue":"Problem with customer service"},"highlight":{"complaint_what_happened":["Denial of Critical <em>Risk</em>-<em>Mitigation</em> Tools Due to my inability to access online banking, I requested that Chase temporarily freeze my credit card as a preventative security <em>measure</em> since XXXX. This request was denied multiple times by customer service representatives, citing \" internal system limitations. '' Denying a customer the ability to freeze their own cardespecially when they are already locked out of online monitoringconstitutes a denial of a reasonable and standard security control."]},"sort":[19.707228,"20753330"]},{"_index":"complaint-public-v1","_id":"6482545","_score":14.070135,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"Consumer Financial Protection Bureau\nP.O. Box 2900\nClinton, \nIA 52733-2900 TRUIST BANK  BREACH OF DUTY OF CARE\n \t \t \t \nDear Sir/Madam of the Consumer Financial Protection Bureau,  \n\nPlease take the time to read this information pack as it will explain the reason for my complaint to the Consumer Financial Protection Bureau. \n\nOn XXXX XXXX XXXX, I fell victim to a multilayered scam operation orchestrated\nby XXXX XXXX (the Scammer) and innocently lost XXXX  USD of my hard-earned life-savings.  I advised Truist Bank of this fact on XXXX XXXX XXXX and I havent received any satisfactory response so far.\n\nTruist Bank had a duty to exercise reasonable professionalism, care, pay due to regards to the interest of their customers and follow good industry practices (GIP) to keep customers accounts safe. This includes identifying vulnerable consumers who may be particularly susceptible to scams and looking out for payments which might indicate the consumer is at risk of financial harm.   \n \nSince XXXX XXXX, I have been attempting to resolve this matter with Truist Bank, but they have failed to settle this matter satisfactorily. I have been dealing with Truist Bank in good faith and am deeply disappointed in how they have handled this matter thus far.  \n   \nI find it baffling and reprehensible that my money has been so egregiously misused in a fashion that violates their principles, which call me to defend my rights. This is poorly thought out and vaguely defined nonsense. I doubt they care however since nonsense is what renders unscrupulous businesses financially successful. \nAccordingly, I respectfully insist that Truist Bank covers all overdrafts (560,000.00 USD) on the account. This is fair and reasonable given I was given no appropriate warning about the possibility of a scam. I have been a loyal customer of Truist Bank and have never had any difficulties of this kind before.\n\nFURTHER POINTS FOR CONSIDERATION \n\nThe examples of good and bad practices around investment fraud. Good practice included but was not limited to:\n\tA bank regularly assesses the risk to itself and its customers of losses from fraud, including investment fraud, in accordance with their established risk management framework. The risk assessment does not only cover situations where the bank could cover losses, but also where customers could lose and not be reimbursed by the bank. Resource allocation and mitigation measures are informed by this assessment.\n\tA bank contacts customers if it suspects a payment is being made to an investment fraudster.\n\tA bank has transaction monitoring rules designed to detect specific types of investment fraud. Investment fraud subject matter experts help set these rules.\n\tReal-time payment screening against a well-formulated watch list; transaction monitoring rules designed to detect specific types of investment fraud\n\tBanks actively contacting customers if suspect payments are identified\n\tBanks placing material on investment fraud on its website\n\tWork to detect and prevent investment fraud from being integrated with a banks vulnerable customers initiative\n\nTaking into account the law, regulatory rules and guidance, relevant codes of practice and what should consider having been good industry practice at the time, Truist Bank should reasonably and reasonably consider:\n\tHave been monitoring accountsand any payments made or receivedto counter various risks, including anti-money-laundering, countering the financing of terrorism, and preventing fraud and scams;\n\tHave had systems in place to look out for unusual transactions or other signs that might indicate its customers were at risk of fraud (amongst other things). This is particularly so given the increase in sophisticated fraud and scams in recent years, which banks are generally more familiar with than the average customer; and\n\tIn some circumstances, irrespective of the payment channel used, have taken additional steps, or made additional checks, before processed a payment, or in some cases declined to make a payment altogether, to help protect customers from the possibility of financial harm from fraud.\n\nDespite the regulatory and statutory requirements Truist Bank shall abide by as a licensed and regulated financial institution, instead of detecting patterns, drawing certain conclusions, and taking actions accordingly, Truist Bank may have insufficiently performed some hasty and haphazard review of the transaction(s) regarding the suspicious activities, but it seems that rather than being careful, methodical, and vigilant, they took no notice of what was happening.\n\nPlease be noted that I will not in any way quietly tolerate the consequences of Truist Bank actions (or more precisely, the lack thereof). It is perfectly obvious that they could have, and should have, utilized various risk-based examination procedures and techniques, all of which are within their purview and could have entirely prevented this disastrous outcome.\nAs previously advised, they should have known, suspected, or had reason to suspect that the transactions (or pattern of transactions):\n\tinvolve funds the ultimate purpose of which was to fuel an illegal enterprise;\n\tis intended to disguise funds the ultimate purpose of which was to fuel an illegal enterprise, in an attempt to avoid and thus violate regulations;\n\tis intentionally designed to defraud your customer;\n\tserves no legitimate or lawful purpose; and\n\tinvolve the use of your services to facilitate criminal activity.\n\nThere are so many other ways in which measures related to fraud prevention and mitigation could have been useful. Further factors that should have been taken into consideration include, but are not limited to, the following:\n\tThe timing, volume, frequency, and nature of the transactions in question;\n\tThe abnormality of such transactions against the background of your experience with me as a customer and other entities associated with the transactions (if any);\n\tThe suspicious nature of such transactions based on my overall risk profile including vulnerability and identification and research of high-risk services/products;\n\tSystemic filtering mechanisms, whether manual or automatic, for the identification of unusual activities; and\n\tPeriodic evaluation of the usefulness, appropriateness and effectiveness of anti-fraud programs, and other associated policies and procedures.\n\nRelevant industry practices at the time of the victimization:\nTruist Bank is obliged to take some action if it is sufficiently aware of a real possibility that a fraud may be being perpetuated. If you don't question its customers instructions or raise the possibility of a scam with the customer in these circumstances, it may be liable if the red flags indicate the customer is:\n\tparticularly vulnerable, or\n\tif the possibility of fraud was serious or real, not just suspected.\n\nThere are some recommendations to organizations for protecting customers from financial harm that might occur as a result of fraud or financial abuse; and gives guidance on how to recognize customers who might be at risk, how to assess the potential risks to the individual and how to take the necessary actions to prevent or minimize financial harm.\nThese recommendations are established as a general principle, the organization should deliver a service that:\n\n1)\tTakes a proactive approach to minimizing risks, impact and incidences of financial harm and it sets out systems and tools for the prevention and detection of fraud and financial abuse. As a general point, it says organizations should ensure that all systems are developed using technologies and methodologies that are effective in the prevention of fraud and financial abuse, through authorized and unauthorized payments, thereby minimizing the risk of financial harm to customers. As regards to the detection of fraud and financial abuse, it says the organization:\n\nA) should have measures in place across all payment channels and products to detect suspicious transactions or activities that might indicate fraud or financial abuse. It then lists the following examples of suspicious activity on customer accounts:\na. multiple cheque books;\nb. sudden increased spending;\nc. transfers to other accounts;\nd. multiple password attempts;\ne. logins from new devices, multiple geographical locations;\nf. sudden changes to the operation of the account; Unusual transactions are transactions whose amount, characteristics and frequency bear no relation to the economic activity of the customer, exceed normal market parameters or have no apparent legal justification.\ng. a withdrawal or payment for a large amount;\nh. a payment or series of payments to a new payee;\ni. financial activity that matches a known method of fraud or financial abuse.\n\nB) organizations should have a process in place to ensure that staff make contact with the customer to verify the financial activity, challenge its authenticity, explain the nature of the suspected or detected fraud and discuss an appropriate plan of action.\n\nMy true issue with the bank is their limited understanding of the kind of recall I was requesting to raise. The most common reason for a recall is where the account holder says the transaction was not authorised; a recall can also be claimed if the goods were not received or if the cardholder paid in another way (eg., with cash).\n\nWhilst I am not denying the demand for the reason code, I am emphasizing to the bank that my case falls under a different reason code. Despite providing the bank with the required explanations of my case, Truist Bank preferred to stick with the authorisation issue which has never been raised by me which already shows the banks lack of understanding of how to treat my case.\n\nTruist Bank could have done more at the time of the payment to warn me of the risks of scams\n\tTaking steps to educate their customers about scams.\n\tTaking steps to identify higher risk payments and customers who have a higher risk of becoming a victim of scams.\n\tProviding effective warnings to customers if the bank identifies a scam risk.\n\tTaking extra steps to protect customers who might be vulnerable to scams.\n\tTalking to customers about payments and even delaying or stopping payments where there are scam concerns.\n\tActing quickly when a scam is reported to it.\n\tTaking steps to stop fraudsters from opening bank accounts.\nBanks and other Payment Services Providers (PSPs) do have a duty to protect customers against the risk of financial loss due to fraud and/or to undertake due diligence on large transactions to guard against money laundering. In broad terms, the starting position at law is that a firm is expected to process payments and withdrawals that a customer authorises it to make, in accordance with the Payment Services Regulations and the terms and conditions of the customers account.\nBut, where the consumer made the payment as a consequence of the actions of a fraudster, it may sometimes be fair and reasonable for the bank to reimburse the consumer even though they authorised the payment.  \nI think Truist Bank shouldve had enough knowledge of this type of scam at the time. Truist Bank could have protected me from this; unlike me, the bank knows about the existence of such scams and how you prey on vulnerable victims like myself, taking advantage of lack of knowledge, awareness, and circumstance. Despite the irregularities in my spending and such untypical patterns, not a single contact was made me question what I was doing. The treatment from Truist Bank is compounded by trauma and anxiety and has left me in the awful situation I now find myself in.\nAlthough it was not Truist Bank that scammed me, they had many obligations to protect my Financial Interest - which they did not uphold if you take a quick look at the bank statements you will realise how the transactions were absolutely out of the usual pattern, there was suddenly increased spending, payments for considerably large amounts, series of payments to a new payee and of course financial activity that matched a known method of fraud or financial abuse.\nAll of the above points were not considered by Truist Bank when I was victimised, and no actions were taken to prevent that victimisation. Of course, I appreciate that they might want to act in good faith and uphold my requests to transfer these payments but the code sets out that organisations should have a process in place, to ensure that (i) staff make contact with the customer to verify the financial activity, (ii) challenge its authenticity, (iii) explain the nature of the suspected or detected fraud and (iv) discuss an appropriate plan of action. \n \nTo further simplify the situation with respect to the nature of the transactions, there are circumstances, irrespective of the payment channel used, where a bank should take additional steps, or make additional checks, before processing a payment, or in some cases decline to make a payment altogether, to help protect customers from the possibility of financial harm. This is particularly so in light of the environment created by the increase in sophisticated fraud and scams in recent years - which banks are generally more familiar with than the average customer.\n \nKindly take into account that this case against Truist Bank is not primarily about the scam that happened. My main issue with Truist Bank is its unwillingness to raise a recall under the relevant reason code. It is obvious that they did not take any of my reasonings into account and blatantly focused on the authorisation argument that does not match my case and the issue of whether the transactions were fraudulent according to what is written on the paper. \n\nAnti-Money Laundering Requirements for Financial Institutions and Other Designated Businesses \n\n3.1 What financial institutions and other businesses are subject to anti-money laundering requirements? Describe which professional activities are subject to such requirements and the obligations of the financial institutions and other businesses. The following are subject to the requirement to maintain risk-based AML Programs: \n\n\tBanks, including savings associations, trust companies, credit unions, branches and subsidiaries of foreign banks in the United States, and Edge corporations.\n\tBroker-dealers in securities.\n\tMutual funds. Futures Commission Merchants and Introducing Brokers in Commodities. Money Services Businesses 3.4 What are the requirements for recordkeeping or reporting large currency transactions? When must reports be filed and at what thresholds?\n\nCurrency Transaction Reporting\n\nFinancial institutions (defined as financial institutions under the BSA regulations) must file CTRs with FinCEN on all transactions in (physical) currency in excess of XXXX  (or the foreign equivalent) conducted by, though, or to the financial institution, by or on behalf of the same person, on the same day. 31C.F.R.  1010.310315.\nIt is prohibited to structure transactions to cause a financial institution not to file a CTR or to file an inaccurate CTR by breaking down transactions into smaller amounts at one or more financial institutions over one or more days. 31 C.F.R.  1010.314.\n\nCustomer Due Diligence\nPursuant to regulatory requirements, which became effective May 11, 2018, as part of their AML Programs, certain financial institutions (banks, broker-dealers, mutual funds, FCMs and IB-Cs) must implement formal risk-based CDD programs that include certain minimum elements, including customer identification and verification (under a Customer Identification Program), obtaining information about the nature and purpose of a customers account, ongoing monitoring of customer accounts, obtaining beneficial ownership information at a 25% threshold\nfor legal entity customers and identifying a control person for legal entity customers (with certain exceptions).\n\nThere also is a specific BSA requirement to maintain CDD programs for non-U.S. persons private banking accounts and foreign correspondent accounts. The same covered financial institutions as for CDD programs (banks, broker-dealers, mutual funds, FCMs and IB-Cs) must maintain a CDD program for non-U.S. private banking accounts established on behalf of, or for the benefit of, a non-U.S. person and foreign correspondent customers and an enhanced due diligence (EDD) program for those relationships posing a higher risk. These programs must be designed to detect and report suspicious activity with certain minimum standards. These requirements are based on Section 312 of the PATRIOT Act and are often referred to as Section 312 requirements. 31 C.F.R.  1010.610 (due diligence for foreign correspondent accounts), 1010.620 (due diligence for private banking for non-U.S. persons).\n3.9 What is the criteria for reporting suspicious activity?\n\nFinancial institutions and other businesses subject to the AML Program requirement (except Check Cashers, Operators of Credit Card Systems, and Dealers in Precious Metals, Precious Stones, or Jewels) are required to file SARs with FinCEN under the BSA (and for banks, under parallel requirements of their federal functional regulators). SARs are required where the filer knows, suspects, or has reason to suspect a transaction conducted or attempted by, at\nor through the financial institution: \n\n\tinvolves money laundering;\n\tis designed to evade any BSA regulation or requirement;\n\thas no business or apparent lawful purpose or is not the sort in which a particular customer would engage; or \n\tinvolves the use of the financial institution to facilitate criminal activity or involves any known or suspected violation of federal criminal law. \n\tSee, e.g., 31 C.F.R.  1023.320(c) (SAR requirements for broker-dealers). Generally, the reporting threshold is XXXX or more. For banks, if the suspect is unknown, it is XXXX or more. For MSBs, generally, it is XXXX or more.\n\nIn XXXX XXXX the office of the Senator XXXX XXXX  issued a report called: Facilitating Fraud: How Consumers Defrauded on XXXX are Left High and Dry by the Banks that Created It. These are some of the most important statements mentioned in the report:\nIn XXXX XXXX, Senator XXXX opened an investigation to determine the extent of fraudulent activity on XXXX, and to understand how the company and the banks that own and operate it make consumers whole when they are defrauded on the platform. Senators XXXX XXXX XXXX XXXX  wrote to XXXX seeking information about the frequency of scams and fraud and the companys policies on redressing consumers who have been defrauded. \nThe information provided by XXXX revealed that an estimated XXXX XXXX was lost by XXXX users through frauds and scams in 2021, but that the banks that participate in the network appear not to have provided sufficient recourse to their customers. In particular, XXXX response indicated that XXXX  facilitates fraudulent activity of many kinds That includes activity in which a users account is accessed by a bad actor and used to transfer a payment  often called unauthorized transactions  and activity in which a user is fraudulently induced into transferring a payment to a bad actor  often referred to by XXXX and XXXX-participant banks as authorized transactions.\nSenators XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX then sent letters to the seven big banks that own and operate XXXX parent company to determine the extent of the problems with illegal and fraudulent activity, and to determine how banks were helping consumers who lost money on the platform.\nAt nearly every turn, most of the big banks have stonewalled, refusing to provide the information requested by members of Congress. However, Senators XXXX XXXX XXXX finally obtained commitments from several of the banks CEOs that they would provide the information on XXXX to Congress during a Committee on Banking, Housing, and Urban Affairs hearing on XXXX XXXX XXXX\nOverall, the three banks that provided complete data sets  XXXX XXXX XXXX XXXX, and Truist  reported 35,848 cases of scams, involving over XXXX  million of payments in XXXX  and the first half of XXXX. In the vast majority of these cases, the banks did not repay the customers that reported being scammed. Overall these three banks reported repaying customers in only 3,473 cases (representing nearly 10% of scam claims) and repaid only XXXX XXXX  (representing 11.2% of payments).\nThe findings of this report reveal that fraud and theft on XXXX are widespread and growing, with consumers losing XXXX  each year. The banks that own and profit from the platform are failing to make their customers whole for both authorized and unauthorized fraudulent transactions, while refusing to release information publicly or to their customers that could help keep all consumers safe. Given this uncertain landscape and the banks abdication of responsibility, regulatory clarity is needed to further protect XXXX  users.\nThe CFPB has regulatory authority over peer-to-peer platforms including XXXX, and is reportedly considering issuing guidance to push banks to cover more fraudulently induced transactions, a move that would greatly improve consumer protections on peer-to-peer platforms like XXXX The agency should act to clarify and strengthen Regulation E and include fraud in the Regulations error resolution purview, increasing the responsibility of banks to keep XXXX safe and to ensure that consumers will be protected. The banks that created and profit off of XXXX should be pushed to protect their consumers from bad actors on their platform, and regulators should step in to ensure a fair and consistent process for everyone.\nFrom the report issued by the office of Senator XXXX XXXX, it is clear that the banks dont treat scam victims fairly, only 10% of scam victims get a compensation from the bank, while others just left suffering. Even more, banks keep getting their profit, while more and more people keep being scammed, hacked, simply saying, losing their hard-earned funds.\nAs it is mentioned in the report, such organizations as CFPB should issue a guidance in which it will be written how step-by step, financial institutions need to check each and every transaction that looks suspicious, especially those which are sent to a new payee (e.g., cryptocurrency platforms). In case if the financial institution doesnt follow these rules and their customer is scammed, it shouldnt be blamed only as a victims guilt. Financial institutions need to take their responsibility as well and provide their customer with a decent compensation.\n\nDesired outcome: Truist Bank has to put things into the right perspective for me by reversing the total amount of XXXX  USD paid to scammers as I have suffered a great loss because of this fraud, it had affected me personally, emotionally and financially. \n\n\nYours sincerely, \n\nXXXX XXXX","date_sent_to_company":"2023-01-24T12:46:36.000Z","issue":"Fraud or scam","sub_product":"International money transfer","zip_code":"20852","tags":null,"has_narrative":true,"complaint_id":"6482545","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"TRUIST FINANCIAL CORPORATION","date_received":"2023-01-24T12:41:22.000Z","state":"MD","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":["There are so many other ways in which <em>measures</em> related to fraud prevention and <em>mitigation</em> could have been useful."]},"sort":[14.070135,"6482545"]},{"_index":"complaint-public-v1","_id":"5916248","_score":13.211583,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"Dear Sir/Madam of the Consumer Financial Protection Bureau XXXX XXXX XX/XX/XXXX, I fell victim to a multilayered operation orchestrated by XXXX XXXX XXXX and a scammer called XXXX XXXX XXXX the Company ) and lost XXXX USD of my hard-earned funds. I advised Bank of the West of this fact on XX/XX/XXXX and I havent received any satisfactory response so far. Their sophisticated, manipulative, aggressive emotionally/psychologically driven sales tactics specifically tuned in to my personal circumstances was a deliberate and vicious financial crime on me as a vulnerable and unsuspecting individual. I also understand now that there is a multimillion-pound  industry out there with such Company operating to effectively steal people 's money using these tactics. Bank of the West had a duty to exercise reasonable professionalism, care, pay due to regards to the interest of their customers and follow good industry practices ( GIP ) to keep customers accounts safe. This includes identifying vulnerable consumers who may be particularly susceptible to scams and looking out for payments which might indicate the consumer is at risk of financial harm. Since XX/XX/XXXX, I have been attempting to resolve this matter with Bank of the West, but they have failed to settle this matter satisfactorily. I have been dealing with Bank of the West in good faith and am deeply disappointed in how they have handled this matter thus far. \nfind it baffling and reprehensible that my money has been so egregiously misused in a fashion that violates their principles, which call me to defend my rights. This is poorly thought out and vaguely defined nonsense. I doubt they care however since nonsense is what renders unscrupulous businesses financially successful. \nAccordingly, I respectfully insist that Bank of the West covers all overdrafts ( XXXX USD ) on the account. This is fair and reasonable given I was given no appropriate warning about the possibility of a scam. I have been a loyal customer of Bank of the West and have never had any difficulties of this kind before. \nFURTHER POINTS FOR CONSIDERATION Despite the regulatory and statutory requirements Bank of the West shall abide by as a licensed and regulated financial institution, instead of detecting patterns, drawing certain conclusions, and taking actions accordingly, Bank of the West may have insufficiently performed some hasty and haphazard review of the transaction ( s ) regarding the suspicious activities, but it seems that rather than being careful, methodical, and vigilant, they took no notice of what was happening. \nPlease be noted that I will not in any way quietly tolerate the consequences of Bank of the West actions ( or more precisely, the lack thereof ). It is perfectly obvious that they could have, and should have, utilized various risk-based examination procedures and techniques, all of which are within their purview and could have entirely prevented this disastrous outcome. \nAs previously advised, they should have known, suspected, or had reason to suspect that the transactions ( or pattern of transactions ) : involve funds the ultimate purpose of which was to fuel an illegal enterprise ; is intended to disguise funds the ultimate purpose of which was to fuel an illegal enterprise, in an attempt to avoid and thus violate regulations ; is intentionally designed to defraud your customer ; serves no legitimate or lawful purpose ; and involve the use of your services to facilitate criminal activity. \nThere are so many other ways in which measures related to fraud prevention and mitigation could have been useful. Further factors that should have been taken into consideration include, but are not limited to, the following : The timing, volume, frequency, and nature of the transactions in question ; The abnormality of such transactions against the background of your experience with me as a customer and other entities associated with the transactions ( if any ) ; The suspicious nature of such transactions based on my overall risk profile including vulnerability and identification and research of high-risk services/products ; Systemic filtering mechanisms, whether manual or automatic, for the identification of unusual activities ; and Periodic evaluation of the usefulness, appropriateness and effectiveness of anti-fraud programs, and other associated policies and procedures. \nThere are some recommendations to organizations for protecting customers from financial harm that might occur as a result of fraud or financial abuse ; and gives guidance on how to recognize customers who might be at risk, how to assess the potential risks to the individual and how to take the necessary actions to prevent or minimize financial harm. \nThese recommendations are established as a general principle, the organization should deliver a service that : 1 ) Takes a proactive approach to minimizing risks, impact and incidences of financial harm and it sets out systems and tools for the prevention and detection of fraud and financial abuse. As a general point, it says organizations should ensure that all systems are developed using technologies and methodologies that are effective in the prevention of fraud and financial abuse, through authorized and unauthorized payments, thereby minimizing the risk of financial harm to customers. As regards to the detection of fraud and financial abuse, it says the organization : A ) should have measures in place across all payment channels and products to detect suspicious transactions or activities that might indicate fraud or financial abuse. It then lists the following examples of suspicious activity on customer accounts : a. multiple cheque books; b. sudden increased spending ; c. transfers to other accounts ; d. multiple password attempts ; e. logins from new devices, multiple geographical locations ; f. sudden changes to the operation of the account ; Unusual transactions are transactions whose amount, characteristics and frequency bear no relation to the economic activity of the customer, exceed normal market parameters or have no apparent legal justification. \ng. a withdrawal or payment for a large amount ; h. a payment or series of payments to a new payee ; i. financial activity that matches a known method of fraud or financial abuse. \nB ) organizations should have a process in place to ensure that staff make contact with the customer to verify the financial activity, challenge its authenticity, explain the nature of the suspected or detected fraud and discuss an appropriate plan of action. \nBank of the West could have done more at the time of the payment to warn me of the risks of scams Taking steps to educate their customers about scams Taking steps to identify higher risk payments and customers who have a higher risk of becoming a victim of scams Providing effective warnings to customers if the bank identifies a scam risk Taking extra steps to protect customers who might be vulnerable to scams Talking to customers about payments and even delaying or stopping payments where there are scam concerns Acting quickly when a scam is reported to it Taking steps to stop fraudsters from opening bank accounts Banks and other Payment Services Providers ( PSPs ) do have a duty to protect customers against the risk of financial loss due to fraud and/or to undertake due diligence on large transactions to guard against money laundering. In broad terms, the starting position at law is that a firm is expected to process payments and withdrawals that a customer authorises it to make, in accordance with the Payment Services Regulations and the terms and conditions of the customers account.\n\nBut, where the consumer made the payment as a consequence of the actions of a fraudster, it may sometimes be fair and reasonable for the bank to reimburse the consumer even though they authorised the payment. \nBank of the West could have protected me from this ; unlike me, the bank knows about the existence of such scams and how you prey on vulnerable victims like myself, taking advantage of lack of knowledge, awareness, and circumstance. Despite the irregularities in my spending and such untypical patterns, not a single contact had made me question what I was doing. The treatment from Bank of the West is compounded by trauma and anxiety and has left me in the awful situation I now find myself in. \nAlthough it was not Bank of the West that scammed me, they had many obligations to protect my Financial Interest- which they did not uphold if you take a quick look at the bank statements you will realise how the transactions were absolutely out of the usual pattern, there was suddenly increased spending, multiple transfers on a single day, payments for considerably large amounts, series of payments to a new payee and of course financial activity that matched a known method of fraud or financial abuse. \nAll of the above points were not considered by Bank of the West when I was victimised, and no actions were taken to prevent that victimisation. Of course, I appreciate that they might want to act in good faith and uphold my requests to transfer these payments but the code sets out that organisations should have a process in place, to ensure that ( i ) staff make contact with the customer to verify the financial activity, ( ii ) challenge its authenticity, ( iii ) explain the nature of the suspected or detected fraud and ( iv ) discuss an appropriate plan of action. \nAnti-Money Laundering Requirements for Financial Institutions and Other Designated Businesses 3.1 What financial institutions and other businesses are subject to anti-money laundering requirements? Describe which professional activities are subject to such requirements and the obligations of the financial institutions and other businesses. The following are subject to the requirement to maintain risk-based AML Programs XXXX Banks, including savings associations, trust companies, credit unions, branches and subsidiaries of foreign banks in the United States XXXX and Edge corporations. \nBroker-dealers in securities. \nMutual funds. \nFutures Commission Merchants and Introducing Brokers in Commodities.\n\nMoney Services Businesses 3.4 What are the requirements for recordkeeping or reporting large currency transactions? When must reports be filed and at what thresholds? \nCurrency Transaction Reporting Financial institutions ( defined as financial institutions under the BSA regulations ) must file CTRs with FinCEN on all transactions in ( physical ) currency in excess of {$10000.00} ( or the foreign equivalent ) conducted by, though, or to the financial institution, by or on behalf of the same person, on the same day. 31C.F.R. 1010.310315.\n\nIt is prohibited to structure transactions to cause a financial institution not to file a CTR or to file an inaccurate CTR by breaking down transactions into smaller amounts at one or more financial institutions over one or more days. 31 C.F.R. 1010.314. \nCustomer Due Diligence Pursuant to regulatory requirements, which became effective XX/XX/XXXX, as part of their AML Programs, certain financial institutions ( banks, broker-dealers, mutual funds, FCMs and IB-Cs ) must implement formal risk-based CDD programs that include certain minimum elements, including customer identification and verification ( under a Customer Identification Program ), obtaining information about the nature and purpose of a customers account, ongoing monitoring of customer accounts, obtaining beneficial ownership information at a 25 % threshold for legal entity customers and identifying a control person for legal entity customers ( with certain exceptions ). \nThere also is a specific BSA requirement to maintain CDD programs for non-U.S. persons private banking accounts and foreign correspondent accounts. The same covered financial institutions as for CDD programs ( banks, broker-dealers, mutual funds, FCMs and IB-Cs ) must maintain a CDD program for non-U.S. private banking accounts established on behalf of, or for the benefit of, a non-U.S. person and foreign correspondent customers and an enhanced due diligence ( EDD ) program for those relationships posing a higher risk. These programs must be designed to detect and report suspicious activity with certain minimum standards. These requirements are based on Section 312 of the PATRIOT Act and are often referred to as Section 312 requirements. 31 C.F.R. 1010.610 ( due diligence for foreign correspondent accounts ), 1010.620 ( due diligence for private banking for non-U.S. persons ). \n3.9 What is the criteria for reporting suspicious activity?\n\nFinancial institutions and other businesses subject to the AML Program requirement ( except Check Cashers, Operators of Credit Card Systems, and Dealers in Precious Metals, Precious Stones, or Jewels ) are required to file SARs with FinCEN under the BSA ( and for banks, under parallel requirements of their federal functional regulators ). SARs are required where the filer knows, suspects, or has reason to suspect a transaction conducted or attempted by, at or through the financial institution : involves money laundering ; is designed to evade any BSA regulation or requirement ; has no business or apparent lawful purpose or is not the sort in which a particular customer would engage ; or involves the use of the financial institution to facilitate criminal activity or involves any known or suspected violation of federal criminal law.\n\nSee, e.g., 31 C.F.R. 1023.320 ( c ) ( SAR requirements for broker-dealers ). Generally, the reporting threshold is {$5000.00} or more. For banks, if the suspect is unknown, it is {$25000.00} or more. For MSBs, generally, it is {$2000.00} or more.\n\nIn summary, I respectfully request Consumer Financial Protection Bureau to review my points above, given your influence and obligations to provide : The duty of care they owe me as my bank.\n\nThe position I hold as loyal customer and their own intellectual knowledge, which has been overlooked in this case ; to be applied in a professional manner being justified as part of their banking services to their customers.\n\nThey should have noticed it in my transaction history that I have not done any transaction nor released such a large amount of money in foreign currency since I became their customer.\n\nDesired outcome : Bank of the West has to put things into the right perspective for me by reversing the total amount of XXXX USD paid to scammers as I have suffered a great loss because of this fraud, it had affected me personally, emotionally and financially. \nYours sincerely, XXXX XXXX XXXX","date_sent_to_company":"2022-08-25T15:26:35.000Z","issue":"Fraud or scam","sub_product":"International money transfer","zip_code":"91304","tags":null,"has_narrative":true,"complaint_id":"5916248","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"BANK OF THE WEST","date_received":"2022-08-25T15:06:21.000Z","state":"CA","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["There are so many other ways in which <em>measures</em> related to fraud prevention and <em>mitigation</em> could have been useful."]},"sort":[13.211583,"5916248"]},{"_index":"complaint-public-v1","_id":"7047994","_score":9.541836,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Consumer Financial Protection Bureau (CFPB) 1700 G Street NW Washington, D.C. 20552\n[WITHOUT PREJUDICE]\nURGENCY: HIGH\nIMPORTANCE: HIGH\nThis is to complain against Crypto.com. \nI wish to practice my right as a customer of CRYPTO.COM to use your organisation's service, seeking a formal, impartial investigation \nto amicably settle my dispute with CRYPTO.COM. \nIn order to clear up the myriad of letters and correspondences I have hitherto sent to CRYPTO.COM respecting my complaint, I believe it \nwill substantially strengthen both my case and your understanding, by taking a deeper look at the happenings of my case, and analysing \nthe relevant facts in an objective and comprehensive fashion.\nIt is crucial to note that I have been manipulated, socially-engineered and coerced to engage these fraudulent criminals. Much to my \nembarrassment, I recognise that I am the victim of an investment scam.\nMy complaint to the CFPB has arisen as I do not consider, by any stretch of the imagination, the conduct of CRYPTO.COM to be \ncommensurate with their legal role and responsibility to their customers. They sell a service to look after their customers, protect their \nmoney and are a financial institution that maintains a traditional relationship and way of working with its customers.\nDuring the complaints process with CRYPTO.COM, I found their communication ineffective, which further hides their conduct to \nmanagement and diminishes the service offering to their clients. They are struggling to adapt their business offering in the ever-changing \nworld of IT development. The internet is presenting a real problem which they choose to manage in a way which is not in line with rules \nand regulations of CFPB as well as their own internal policy and procedures sold to their clients. \nGeneral Obligation:\nCommencing on or around XXXX XXXX XXXX, I fell victim to two multi-layered scam operations run by WTN  which involved me making \ndeposits for a total amount of XXXX USD from my CRYPTO.COM account to fraudulent investment firms. \nWhen determining whats reasonable and fair, we should focus on the issue of liability; common queries include, but are not limited to, \nthe following (i) whether CRYPTO.COM did not take notice of any rule, law, or regulation, and/or possibly missed any material elements \nof the relevant bylaws or codes of conduct, that may have prevented them from protecting my financial safety; (ii) whether by virtue of \nCRYPTO.COMs custodianship over my funds or by its control over them, they owed a fiduciary duty to the me and if so, whether that \nduty was breached; (iii) whether CRYPTO.COM promoted the transaction(s) in question despite being aware of the nature of the \ntransaction(s) in question (iv) whether CRYPTO.COM was in compliance with its own policies and procedures; (v) whether \nCRYPTO.COM owed duties to myself, what the scope of those duties was, and whether CRYPTO.COM did not uphold those duties; (vi) \nwhether CRYPTO.COMs conduct was unfair; and (vii) whether CRYPTO.COM has within its power the ability to, and should, \ncompensate me for the harm that has befallen me.\nUpon identification of such unusual or suspicious activity, it is crucial that the relevant staff member adequately describe the factors \nmaking an activity or transaction suspicious, thoroughly depict the extent and nature of this activity and properly communicate to the \ncustomer that such activity meets the relevant criteria of fraud.\nIn providing its services to a customer, a financial institution is required by law to exercise the care and skill of a diligent, prudent banker. \nIn this case, this means that the payment service provider should not turn a blind eye to known facts pointing to a real possibility that \ntheir customer is being scammed. In other words, CRYPTO.COM must have had special knowledge of what was occurring or been alerted \nto a real possibility of fraud taking place. The financial institution must have known or reasonably ought to have known that I was dealing \nwith a scammer.\nGranted, there is room for diversity of view insofar as reasonableness is concerned. Indeed, there is a sense in which the standard of care \nof the reasonable person involves in its application a subjective element. \nHowever, it must be remembered that the correct test is always reasonable care in all circumstances, not average care. The fact that most \npeople behave in a certain way may be good evidence that the conduct is reasonable, but this is not necessarily the case. Although \nreasonableness is a very fluid concept, all of the evidence suggests that CRYPTO.COM did not foresee the fraud and disregarded even the \nmost obvious dangers in this respect. \nSituations do tend to repeat themselves and it is advisable to examine previous outcomes to see how the standard of the reasonable person \nshould be applied, and that lessons can be learnt from the errors of the past.\nCRYPTO.COMs Position:\nOn XXXX XXXX XXXX, CRYPTO.COM wrote in a letter ADDENDUM 2  DIGITAL ASSET WALLET 2. Crypto.com processes all \nDigital Asset Transfers according to the Instructions received from you and does not guarantee the identity of any recipient. You \nshould verify all transaction information prior to submitting Instructions for a Digital Asset Transfer to Crypto.com as the Digital \nAsset Transfer may not be canceled or reversed once processed by Crypto.com unless Crypto.com decides at its sole discretion that \nthe transaction should be canceled or reversed and is technically capable of such cancellation or reversal. You acknowledge that \nyou are responsible for ensuring the accuracy of any Instructions submitted to Crypto.com and that any errors may result in the \nirreversible loss of your Digital Asset...2- The general position is that customers are free to transact as they wish on their accounts \nwithout interference from their bank. It is the customers responsibility to make enquiries about the persons or businesses they are \ndealing with and to ensure they are genuine. There is no general obligation on banks to monitor customers accounts or to raise \nquestions regarding payments from their accounts in circumstances where the customer has made the transactions.\nRefuting CRYPTO.COMs arguments from a purely logical perspective:\nCRYPTO.COMs position is that the features of the situation at hand do not generate a genuine obligation to protect innocent and helpless \nvictims; they are essentially arguing that common-sense-based approaches are doomed to fail, leaving their exclusively technical account \nof the subject matter as the only meaningful choice. For reasons which are unclear, this extremely serious situation barely gets the attention \nit deserves even though ample evidence has been offered in support of this complaint.\nIn CRYPTO.COMs view, it is implied that we should not home in (and consequently rely) on unwritten laws, practicality, good judgement, \nreasonableness, sharpness, sensibleness, past outcomes, and insight, when taking appropriate precautions. To underscore, once again, such \nviews are at odds with common sense and are wildly irresponsible.\nImagine a view according to which the one and only thing that can make CRYPTO.COM morally obligated to do something is having it \nwritten down somewhere. Pursuant to this view, if CRYPTO.COMencounter the suffering of totally naive victims, they are only obligated \nto intervene in or remedy the situation, to the degree required by written material. This is unbecoming for a reputable establishment such \nas CRYPTO.COM. \nI have reviewed the material hereto sent by CRYPTO.COM carefully, and it unfortunately provides no response to my fundamental \nargument concerning the degree of care. Given its size, influence, and the resources at its disposal, this establishment clearly had a far \ngreater capacity than an individual such as myself had, to determine the level and likelihood of risk that a client such as myself is subjected \nto and had a duty to intervene as they now do to query in particular out-of-pattern transactions of this kind.\nIt is perfectly obvious that CRYPTO.COM, inadvertently, employs a subtle approach in addressing some of the key questions in a manner \nwhich neither provides me with adequate support nor protects anything other than its own interests.\nIt is CRYPTO.COM here, who has the burden of proof, to show that it has exercised the duty of care, that is to say, that CRYPTO.COM\nadhered to a standard of reasonable care in relation to the matter at issue given its extensive experience compared to mine. It is \nCRYPTO.COM that claims that the damages which I have suffered in connection to this matter have not been reasonably foreseeable, and \nthat my proposed degree of care is not, and has not been, commensurate with CRYPTO.COMs capacity, experience, expertise, or scope \nof services in any way. To reemphasize, CRYPTO.COMs indisputable overriding purpose is by no means to purely execute transactions \nin a blind and blank fashion, but rather to strike a balance between executing those transactions and capitalising on its undeniably vast \ncapabilities to protect consumers thereby enhancing market integrity.\nApropos of the fluidity of the concept of reasonableness, all CRYPTO.COM has done in this regard is set up a dichotomy of having or not \nhavingthe legal obligation under consideration, however, that does not go one-inch toward explaining why various regulatory authorities, \nhas maintained that financial institutions can, and should, protect consumers using their systems, advanced technologies, and rich \nexperience.\nCRYPTO.COM is obliged to take some action if it is sufficiently aware of a real possibility that a fraud may be being perpetuated. If you \ndon't question its customers instructions or raise the possibility of a scam with the customer in these circumstances, it may be liable if the \nred flags indicate the customer is:\n particularly vulnerable, or\n if the possibility of fraud was serious or real, not just suspected.\nThere are some recommendations to organisations for protecting customers from financial harm that might occur as a result of fraud or \nfinancial abuse; and gives guidance on how to recognise customers who might be at risk, how to assess the potential risks to the individual \nand how to take the necessary actions to prevent or minimise financial harm.\nThese recommendations are established as a general principle, the organisation should deliver a service that:\n1) Takes a proactive approach to minimising risks, impact and incidences of financial harm and it sets out systems and tools for\nthe prevention and detection of fraud and financial abuse. As a general point, it says organisations should ensure that all systems are \ndeveloped using technologies and methodologies that are effective in the prevention of fraud and financial abuse, through authorised \nand unauthorised payments, thereby minimising the risk of financial harm to customers. As regards to the detection of fraud and \nfinancial abuse, it says the organisation:\nA) should have measures in place across all payment channels and products to detect suspicious transactions or activities that \nmight indicate fraud or financial abuse. It then lists the following examples of suspicious activity on customer accounts:\na. multiple cheque books;\nb. sudden increased spending;\nc. transfers to other accounts;\nd. multiple password attempts;\ne. logins from new devices, multiple geographical locations;\nf. sudden changes to the operation of the account; Unusual transactions are transactions whose amount, \ncharacteristics and frequency bear no relation to the economic activity of the customer, exceed normal market \nparameters or have no apparent legal justification.\ng. a withdrawal or payment for a large amount;\nh. a payment or series of payments to a new payee;\ni. financial activity that matches a known method of fraud or financial abuse.\nB) organisations should have a process in place to ensure that staff make contact with the customer to verify the financial \nactivity, challenge its authenticity, explain the nature of the suspected or detected fraud and discuss an appropriate plan of action.\nCRYPTO.COM are yet to show, or otherwise provide me with, a compelling argument that their wide-ranging experience and wealth of \nspecialist knowledge in detecting transactional anomalies were not sufficient to avert the fraud at issue. By contrast, I have provided a\nmultitude of sound and powerful reasons by which requiring their involvement has not only been pressingly relevant but also eminently \nreasonable and well-justified.\nRather than empathising with and undertaking substantial efforts to convey their knowledge of the existence of such regulations abroad \nand thereafter use it to protect and proactively relieve the plight of consumers who have been cheated out of their money and whose role \nin society is properly fulfilled, positively contributing to local economic growth, development and sustainability  CRYPTO.COM adopts \na rather insouciant attitude toward my financial predicament portrayed herein.\nI am deeply convinced that the disastrous results that I have previously elaborated upon will continue to ensue if no responsibility is \nadopted by CRYPTO.COM in relation to this matter. I have also thoroughly detailed why they cannot simply dismiss this problem by \nstrictly adhering to legal technicalities which, after careful reflection, struck me as being nothing more than self-interest. Indeed, it seems \nto me utterly unfair to disregard fragile, sensitive, and vulnerable consumers who are afflicted by such allegedly malevolent acts, thereby \nkeeping an unjust status-quo that is corrupting our society at its core.\nConclusion:\nBased on my analysis, and as confirmed by various authorities concerned with such matters, there is abundant evidence that forwardthinking financial institutions ought to take reasonable steps to forestall fraud, or at least mitigate its risk by using an effective risk \nmanagement system, demonstrating their undisputed ability to responsibly and pre-emptively respond to questionable transactions in the \ndigital arena. The use of such systems, largely based on newly adopted technologies aimed at effectively navigating the evolving threat \nlandscape, is only one of a number of possible endeavours undertaken in this connection, alongside the application of past knowledge and \nexperience related to popular fraudulent practices.\nAstonishingly, I am pondering how it is that, despite being shown that CRYPTO.COMs business conduct was insufficient insofar as \nbackground checks are concerned, they keep refuting their indisputable role and responsibility in connection with the matter herein \ndiscussed. The points that I have hitherto made are too crucial to be taken lightly. CRYPTO.COMs non-observance of the fundamental \nprinciples of justice  that is, to completely overlook and not even remotely try to mitigate the suffering of vulnerable consumers is \ninexcusable given the size of the establishment and the vast resources at its disposal as the direct result of the patronage of clients like \nmyself. \nIf it was, indeed, solely my responsibility, we must then believe at least one of the following clauses: a) financial institutions have \nabsolutely no role whatsoever in preventing and detecting fraud, b) the fraud in question was not reasonably foreseeable, or c) the \ntransactions in question were not sufficiently alarming. It is extremely unfortunate that CRYPTO.COMpushes quite hard for me to believe \nall three of these thingsdespite evidence to the contrary.\nIn summary, I respectively ask your organisation to consider my points, given your personal and companywide obligation to provide a fair \nand reasonable investigation into the complaint.\nI look forward to your input and would gladly cooperate to reach a fair and reasonable outcome.\nThank you.\nXXXX XXXX","date_sent_to_company":"2023-05-30T19:56:10.000Z","issue":"Fraud or scam","sub_product":"Mobile or digital wallet","zip_code":"030XX","tags":"Older American, Servicemember","has_narrative":true,"complaint_id":"7047994","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Foris DAX, Inc.","date_received":"2023-05-30T19:44:41.000Z","state":"NH","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["Conclusion:\nBased on my analysis, and as confirmed by various authorities concerned with such matters, there is abundant evidence that forwardthinking financial institutions ought to take reasonable steps to forestall fraud, or at least <em>mitigate</em> its <em>risk</em> by using an effective <em>risk</em> \nmanagement system, demonstrating their undisputed ability to responsibly and pre-emptively respond to questionable transactions in the \ndigital arena."]},"sort":[9.541836,"7047994"]},{"_index":"complaint-public-v1","_id":"13642578","_score":7.2779903,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"Introduction & Summary of Complaint I, XXXX XXXX, hereby submit this second formal complaint against Experian and Equifax for their willful and unlawful handling of a fraudulent XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX account on my credit reports. This account was previously deleted from all of my credit files ( as of XX/XX/year> ) after being confirmed inaccurate and unauthorized, yet it has been reinserted without any notice to me a blatant violation of the Fair Credit Reporting Act ( FCRA ) 611 ( a ) ( 5 ) ( B ) ( ii ). The reinsertion of this deleted account is fraudulent, deceptive, and has caused me severe emotional and financial harm. I write to demand immediate relief and to hold Experian and Equifax accountable for this egregious breach of my consumer rights. \n\nSummary of Issues : Illegal Reinsertion without Notice : A XXXX  account not belonging to me was deleted after dispute, but Experian and Equifax reinserted it into my credit reports without providing the required written notice within 5 business days, violating federal law.\n\nUnauthorized/Stolen Account : The XXXX account in question is the result of unauthorized use of my identity effectively a stolen account that I never opened, authorized, or benefited from. It should never have been reported under my name. \nPattern of Misconduct : Experian and Equifax have demonstrated a pattern of deceptive trade practices and systemic misconduct, ignoring my prior CFPB complaint ( filed XX/XX/year> ) and continuing to report false information. This knowing failure to correct their practices shows a willful violation of the FCRA and other consumer protection laws. \nConsumer Harm : I am suffering significant emotional distress ( anxiety, sleeplessness, and humiliation ) and financial injury ( damage to my credit scores, denial of credit opportunities, and higher costs ) due to their negligence and willful non-compliance. I have been forced to expend time and resources to address a fictitious debt, which is ruining my financial reputation through no fault of my own. \n\nI urge the CFPB to take this complaint with utmost seriousness. Below, I provide detailed facts, legal violations, and the relief sought. My goal is the permanent deletion of this bogus account and accountability for those responsible, so that no other consumer endures this debt slavery being trapped by a false debt on their credit report. \n\nBackground : Deleted Account Illegally Reinserted XXXX  Account Details : The account at issue is a XXXX XXXX XXXX XXXX XXXX XXXX XXXX account that was fraudulently opened or attributed to me without my authorization. After discovering it on my credit reports, I disputed the account with all credit bureaus. As a result, by XX/XX/year>, the account was deleted from my Experian and Equifax reports ( indicating it was unverified/inaccurate ). I have official dispute results confirming that the XXXX tradeline was removed due to lack of verification or accuracy. \n\nReinsertion without Notice : Shockingly, in XX/XX/year>, I found that this XXXX account had been reinserted into my Experian and Equifax credit files without any advance notice or explanation. I never received the written notice that is required within XXXX business days of reinsertion under the FCRA. In fact, I received no communication whatsoever from Experian or Equifax informing me that they were adding this previously-deleted item back onto my reports. This clandestine reinsertion is illegal. FCRA 611 ( a ) ( 5 ) ( B ) ( 15 U.S.C. 1681i ( a ) ( 5 ) ( B ) ) lays out strict conditions for reinserting deleted information : Certification Requirement : A deleted item may not be reinserted unless the furnisher certifies the information is complete and accurate.\n\nConsumer Notice Requirement : If a deleted item is reinserted, the credit bureau shall notify the consumer in writing within XXXX business days of the reinsertion, including details of the furnisher and the consumers rights. \n\nExperian and Equifax appear to have violated both provisions. They either reinserted the account without obtaining a valid certification of accuracy, or accepted a dubious certification despite the account being previously deemed unverifiable. In either case, they failed to notify me in writing of the reinsertion within the 5-day window ( or at all ). This is a direct violation of federal law. By law, the absence of timely notice alone renders the reinsertion unlawful. The violation is clear-cut and inexcusable.\n\nNo New Information or Valid Basis : There was no legitimate new information that could suddenly make this account verified. The account remains fraudulent and inaccurate. Its prior deletion establishes that XXXX could not verify it as my debt. Any purported certification by XXXX to re-report this account is highly suspect and likely false. Therefore, the reinsertion is not only procedurally improper, but also a substantive act of fraud re-reporting information known to be unverifiable and false. I have strong reason to believe this reinsertion was done in bad faith, possibly as part of a collusive arrangement between XXXX and the credit bureaus to push a bogus debt onto my reports. ( Notably, XXXX stands to benefit from having the account reappear, as it pressures me to pay or settle a debt I do not owe. Experian and Equifaxs willingness to violate the law in this manner raises the question of whether they are receiving fees or other incentives for such illicit reinsertions an unlawful collusion and abuse of the credit reporting system. ) Lack of Notice to Complainant : To reiterate, I was completely blindsided by the reappearance of this account. I only discovered the reinsertion by monitoring my credit no notice came from Experian or Equifax. This lack of notice deprived me of the opportunity to immediately dispute or block the reinserted entry, which is exactly the kind of harm the FCRAs notice requirement is meant to prevent. The bureaus secretive action demonstrates a willful disregard for my rights and basic fairness. \n\nUnauthorized Account & Identity Theft The XXXX account is fraudulent it does not belong to me. It appears to be an account opened or used by someone else ( or created due to identity theft ), which was then incorrectly attributed to me on my credit file. I have never had any business relationship with XXXX XXXX XXXX XXXX. This account is the result of identity theft or mistaken identity, and it was already acknowledged as such when it was deleted after my initial dispute. \n\nAccount Was Stolen/Inaccurate : For clarity, this account is essentially a stolen account either opened using my personal information without my permission, or erroneously reported under my name when it pertains to another individual. It is an inaccurate trade line that should never have been reported on my credit in the first place. By reinserting this account, Experian and Equifax are effectively reporting bogus debt information against an innocent consumer ( myself ). This is beyond negligent ; it is a knowing dissemination of false information. \n\nXXXX. FCRA 623 Violations by Furnisher ( XXXX ) : While this complaint is directed at the credit bureaus, it must be noted that XXXX, as the furnisher, XXXX have violated its own legal duties. If XXXX certified the account as accurate despite it being fraudulent, XXXX violated FCRA 623 ( a ) ( 1 ) ( A ) ( 15 U.S.C. 1681s-2 ( a ) ( 1 ) ( A ) ), which prohibits furnishing information known ( or that should be known ) to be inaccurate. XXXX also failed to conduct a good-faith reinvestigation upon my disputes and apparently re-furnished the disputed information without any new proof of validity a potential violation of FCRA 623 ( b ) duties to investigate and correct. These actions by XXXX amount to furnishing false credit information and could not have been done in good faith. I am including this point because Experian and Equifaxs reinsertion of the account suggests they relied on XXXX word ; if so, all parties are complicit in re-reporting false data. Experian and Equifax had an obligation under FCRA 611 to ensure the furnishers certification was legitimate before reinstating the item they apparently failed in this obligation.\n\n4. Unfair and Deceptive Acts and Practices ( UDAP ) : The conduct of Experian and Equifax constitutes unfair or deceptive trade practices in violation of Section 5 of the Federal Trade Commission Act ( 15 U.S.C. 45 ) and state consumer protection laws. Reinserting a previously deleted, disputed debt without notice is inherently deceptive, as it misleads the consumer and any third-party viewing the report about the legitimacy of the debt. It is also unfair, as it causes substantial injury ( credit damage and emotional distress ) that the consumer can not reasonably avoid, with no countervailing benefit. These credit bureaus are systemically betraying consumer trust and public policy by flouting dispute resolutions and secretly re-aging debts. In fact, the CFPB has recently taken enforcement action underscoring how both Equifax and Experian have engaged in systemic violations related to dispute handling and reinsertion : Equifax was found to have allowed previously deleted inaccuracies to be reinserted into credit reports, leading to a {$15.00} million penalty in XXXX  and Experian was sued in 2025 for failing to properly investigate disputes and reinserting errors on credit reports. This shows that what I am experiencing is not an isolated mistake but part of a pattern of willful misconduct by these bureaus. Experian and Equifaxs actions in my case mirror the very abuses identified by regulators ( e.g. sham investigations and unlawful reinsertion ), proving their knowing non-compliance despite being on notice. It is deeply deceptive and unethical for Experian and Equifax to present themselves as purveyors of accurate credit data while deliberately reintroducing information they know to be false. Such behavior also violates the spirit of the Consumer Financial Protection Act ( under which the CFPB can deem practices unfair or abusive ). \nXXXX. Debt Slavery and Potential Extortionate Conduct : By continuously reporting a false debt that I do not owe, Experian and Equifax have effectively shackled me to a debt that is entirely fabricated. This situation feels like a form of * * debt bondage or debt slavery, wherein I, the consumer, am being forced to suffer indefinite credit harm unless I somehow pay or resolve a debt that isnt mine. This term is not used lightly the practice of coercing payment by damaging someones credit is akin to using extortion. In fact, using credit reporting as a weapon to pressure consumers into paying illegitimate debts can be seen as an extortionate means of debt collection. Under 18 U.S.C. 894, it is a federal crime to use extortionate means ( including coercion or implicit threats ) to collect a debt, punishable by up to 20 years in prison. While Experian and Equifax are not traditional debt collectors, their willful perpetuation of false credit data serves to coerce me into paying or dealing with the fraudulent XXXX account to regain my financial freedom. They are facilitating XXXX attempted collection through extortionate damage to my reputation. I want to put Experian and Equifax on notice that this behavior is not just a civil violation it veers into potentially criminal territory. By knowingly participating in the continued reporting of a bogus debt ( after being informed of its false nature through disputes and a prior CFPB complaint ), they are participat [ ing ] in the use ofextortionate means to collect an extension of credit. If they do not cease, I will be urging regulators and law enforcement to investigate these actions under relevant criminal statutes. No consumer should be held financial hostage by false information in this manner.\n\nIn summary, Experian and Equifax have violated the FCRA, the FTC Act, and possibly criminal laws through their handling of my case. Their actions are knowing, willful, and part of a broader pattern of ignoring consumer rights. \n\nPrior CFPB Complaint & Willful Non-Compliance This is my second CFPB complaint on this matter. I previously submitted a CFPB complaint on XX/XX/year>, detailing the issues with this XXXX account and the improper conduct of Experian and Equifax. That prior complaint put both bureaus on explicit notice of the accounts fraudulent nature and their legal obligations. Equifax and Experian were thus fully aware as of early XX/XX/year> that : ( a ) the XXXX account did not belong to me, had been deleted for lack of verifiability, and ( b ) any reinsertion would be unlawful without following FCRA protocols. Despite this, they have failed to take corrective action and allowed the situation to deteriorate further. The fact that the account remains ( or was reinserted ) after my XX/XX/XXXX complaint demonstrates a knowing and willful violation. They are not making a mistake in good faith they are consciously flouting the law. This willfulness entitles me to enhanced remedies under the FCRA ( such as punitive damages ). It also indicates that internal compliance and back-office teams at these bureaus are either negligently incompetent or intentionally abusing the system. In either case, accountability is required. \n\nI urge the CFPB to review my prior complaint ( including any responses, or lack thereof, from Experian/Equifax ) as context. The bureaus disregard of a regulator-facilitated complaint process highlights their brazen attitude. If a CFPB complaint could not compel them to simply obey the law and remove a known false account, it evidences a systemic problem and a willful contempt for consumer protection laws on the part of these companies. It is also evidence that stronger action such as supervisory or enforcement intervention may be needed by CFPB in addition to resolving my individual issue.\n\nImpact on Complainant ( Damages ) Experian and Equifaxs actions have caused me substantial harm, both emotionally and financially : Emotional Distress : I have suffered anxiety, stress, and loss of peace of mind knowing that a blatantly false account is tarnishing my credit. I constantly worry about who sees this misinformation be it lenders, employers, or landlords and what they might think. The situation has caused me sleepless nights and feelings of powerlessness. It is deeply traumatic to be effectively accused of owing a debt that was a result of identity theft. The reinsertion incident done secretly has further eroded my trust in the credit reporting system. I feel harassed and abused by the very agencies that are supposed to maintain fair and accurate credit files. This emotional toll is real and significant. \nDamage to Credit Standing : The false XXXX account has negatively impacted my credit score and credit profile. It is likely being reported with derogatory information ( e.g. a fraudulent balance, late payments or charge-off status that are not mine ), which lowers my credit score unjustly. As a result, I have been denied credit or offered credit at much higher interest rates than I deserve. For example, after this account reappeared, I noticed a drop in my credit score and have received credit card denials that cite serious delinquency or accounts in collection which align with the bogus XXXX entry. This means I am effectively being financially penalized for a crime committed against me. It is an outrageous situation. \nInterference in Life Opportunities : Because of this inaccurate credit information, my access to housing and employment may also be hindered. Many landlords and employers check credit reports. I now live in fear that an apartment application or even a job offer could be jeopardized by Experian and Equifax reporting me as delinquent on a fraudulent debt. This is causing immense additional stress and potentially limiting my economic opportunities. Such ripple effects are exactly why FCRA exists and why its violation is so serious. \nFinancial Costs and Time Loss : I have spent countless hours disputing, monitoring, and attempting to resolve this issue time that I should have been spending on my job and family. Ive incurred costs for mailing dispute letters, possibly credit monitoring services, and other expenses trying to protect myself. I am also preparing to file police reports or additional identity theft affidavits, which is an onerous process. All these burdens exist solely because Experian and Equifax failed to do their jobs correctly. They should compensate me for these losses. Moreover, I intend to seek statutory damages for each willful FCRA violation ( up to {$1000.00} each ) and any actual damages in a court of law if this is not promptly resolved, as allowed by FCRA 616, 617 ( 15 U.S.C. 1681n, 1681o ). The FCRA provides for even punitive damages for willful violations, which I will pursue given the egregious and knowing nature of this misconduct. \n\nIn summary, the negligence and willful misconduct of Experian and Equifax have caused me intense emotional suffering and put me at risk of tangible financial harm. They must be held accountable for these damages. I ask the CFPB to consider these impacts and use its full authority to obtain relief and deterrence. \n\nRelief Demanded Given the above facts and violations, I am seeking the following immediate relief and remedies to resolve my complaint : Permanent Deletion of the XXXX XXXXccount : Immediately and permanently delete the XXXX  account from all of my credit reports at Experian, Equifax, and TransUnion ( if it appears there ). This deletion should occur without possibility of reinsertion. The account is fraudulent, unverified, and unverifiable it must be removed for good. \nWritten Confirmation of Deletion and Cessation : Provide me with written confirmation ( from a high-level representative of Experian and Equifax ) that the XXXX XXXXcount has been deleted and will not be reported again under my file. This documentation should be provided within five ( 5 ) business days of your receipt of this complaint and should be on official letterhead, signed by a person with authority. It must state that Experian and Equifax will cease all reporting and use of this account data in any consumer report or credit score relating to me. In essence, I want proof that this account is gone and will stay gone permanently. \nDocumentation of Any Reinsertion Actions : I demand full documentation and disclosure of how this account was reinserted. This includes : any certification of accuracy XXXX provided, the date and method of reinsertion, the internal records showing the decision process for reinsertion, and identification of the employees or agents involved in approving the reinsertion at Experian and Equifax. I have a right to this information, especially given that the FCRA entitles me to know the furnishers details and that a reinsertion occurred ( which I was never told ). I want to see how such a mistake was allowed to happen despite the law and a prior dispute. \nIdentity Theft Block Implementation : Upon receipt of my FTC Identity Theft Report and request, Experian and Equifax must immediately block the reporting of the XXXX XXXXccount ( as well as any inquiries or derivative information related to it ) in my credit file, pursuant to 15 U.S.C. 1681c-2. This block must be put in place within 4 business days of my providing the required documentation, and I should receive confirmation of the block. After blocking, the bureaus must not reinsert or un-block the item unless permitted by the narrow exceptions in the law ( which do not apply here, as this is a clear case of identity theft, not an error or frivolous claim ). \nCease & Desist Order to XXXX XXXX XXXX request that CFPB forward a cease-and-desist notice to XXXX XXXX XXXX XXXX through this complaint process as well. XXXX must be instructed to cease all furnishing of this account data to any credit reporting agency. They should also cease any collection activities on this account, including harassing calls or communications ( I have received collection calls regarding this account in the past, which is outrageous since its not mine ). XXXX should be on notice that they face legal liability if they continue to pursue a victim of identity theft for this debt. While XXXX is not the primary subject of this complaint, their cooperation is necessary for a complete resolution. They should investigate their own records, recognize this account as fraudulent, close it, and not sell or transfer it ( if they havent already ). \nUpdated Credit Reports : After deletion and blocking, I demand updated copies of my Experian and Equifax credit reports ( at no charge to me ) to verify that the XXXX account has been removed. Additionally, my credit scores should be recalculated without the influence of this derogatory item, and I should be provided some assurance that any lingering negative impact ( such as low score or risk flags caused by the account ) has been fully mitigated. \nGoodwill Measures for Damage Done : While the immediate deletion is top priority, I also ask that Experian and Equifax take steps to mitigate the damage Ive suffered. For instance, they should assist me in notifying any recent creditors who pulled my report that the derogatory information was erroneous ( so I can perhaps get credit reconsidered ). They should also consider offering me a period of complimentary credit monitoring or other services to help regain my confidence, given how their failures have increased my risk. At minimum, I expect an apology and acknowledgment of error from both companies. \n\nAll the above actions are necessary to make me whole and prevent further harm. I expect these remedies to be carried out immediately upon receipt of this complaint. I will not accept half-measures ( such as a temporary deletion or a vague promise ). I want concrete, verifiable action and documentation. \n\nAccountability and Further Actions It is not enough to simply delete the account now that the damage is done ; Experian and Equifax must also be held accountable so that they do not repeat such conduct. I am therefore requesting that beyond the individual relief, the CFPB consider the following measures and that Experian and Equifax acknowledge these steps : Internal Disciplinary Action : Experian and Equifax should investigate the actions of their employees and automated systems that led to this unlawful reinsertion. The back-office compliance and dispute teams responsible must be retrained, disciplined, or removed if they willfully violated protocols. I demand that the companies report what internal corrective action they are taking ( e.g., if a particular department failed to send the notice, what is being done about it? ). Individual accountability is important those who knowingly broke the law should face professional consequences. \nCompliance Review and Certification : I call on Experian and Equifax to conduct a thorough compliance review of their reinvestigation and reinsertion procedures, and to certify to the CFPB ( and to me in writing ) that they have implemented measures to prevent such unlawful reinsertion in the future. This might include improved system checks to enforce the FCRA 5-day notice rule and stronger verification requirements before any deleted data can be re-reported. Given the CFPBs findings of widespread issues at these bureaus, a proactive compliance step is warranted.\n\nRegulatory Enforcement : I respectfully urge the CFPB to use its supervisory and enforcement authority in this case. These violations go beyond my individual incident ; they reflect broader problems. If not already under an enforcement action, Experians and Equifaxs behavior here might merit inclusion in any ongoing CFPB oversight of credit reporting agencies. The CFPB should ensure they pay penalties if appropriate, just as Equifax was fined for similar issues earlier in 2025. A strong regulatory response will incentivize compliance and show the industry that reinsertions without notice and related abuses will not be tolerated. \nCivil Litigation : If Experian and Equifax do not fully remedy this situation, I am prepared to pursue a civil lawsuit for FCRA and related violations. I will seek all available damages statutory, actual, and punitive for their willful noncompliance. As noted, willful FCRA violations can result in significant financial penalties and even punitive damages. I am also aware that each failure to comply ( each improper reinsertion and each lack of notice ) can be a separate violation, potentially multiplying the statutory damages. I would prefer to avoid litigation, but I will not hesitate if my rights continue to be ignored.\n\nCriminal Referral : Given the hints of collusion and willful data manipulation in this case, I also put Experian and Equifax on notice that I may seek a referral to the FTC, state Attorneys General, or even the Department of Justice for investigation into potential criminal law violations. As discussed, using false credit reporting to extort payment can violate federal criminal law ( 18 U.S.C. 894 ). Additionally, if any individual at the bureaus altered or suppressed the required consumer notice or tampered with my dispute, that could be considered mail or wire fraud. Knowingly providing false information to a federal regulator ( if they respond to CFPB with false claims ) can also be a crime. I urge the companies to consider their personal and corporate exposure here. This is not a standard, low-level error its a willful act that carries legal risk.\n\nPersonal Accountability of Management : I demand that upper management at Experian and Equifax acknowledge this complaint and take responsibility. Often these kinds of problems stem from corporate policies that prioritize profit or appeasing furnishers over consumers rights. I want to see a statement from a senior compliance officer or executive that they have reviewed my case and are ensuring compliance going forward. If this does not happen, it further evidences a culture of compliance failure, which I will report to the CFPB and appropriate authorities.\n\nLegislative and Public Policy Note It is worth noting that public policy is moving in a direction to further protect consumers from exactly the kind of harm Ive experienced. For example, in XX/XX/year> the state of Washington enacted XXXX XXXX XXXX, a law that prohibits collection agencies from reporting medical debt to credit bureaus, effectively ensuring that certain sensitive and often disputable debts ( like medical bills ) do not haunt consumers credit reports. This law was passed to protect consumers from unfair credit reporting practices that can ruin lives. The spirit of such legislation is to recognize that some debts or accounts should not be on credit reports at all due to their potential for error or harm. Similarly, federal regulators ( CFPB ) have been working on rules to curb credit reporting of medical debt and other abusive reporting practices. \n\nWhile my case is about a financial account, not medical, the principle is the same unauthorized or erroneous accounts must not be reported. XXXX XXXX and related initiatives show a growing consensus that consumers need stronger protections against improper credit reporting of any debt that is not valid or fair. By continuing to report a clearly unauthorized account, Experian and Equifax are acting contrary to this public policy trend and against the principles of fairness. In fact, their actions would be condemnable under any stricter regime contemplated by lawmakers. I cite this to urge the CFPB to act decisively consumers like me should not have to fight these battles when the law and emerging policies are on our side.","date_sent_to_company":"2025-05-21T18:01:23.000Z","issue":"Improper use of your report","sub_product":"Credit reporting","zip_code":"33993","tags":null,"has_narrative":true,"complaint_id":"13642578","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"EQUIFAX, INC.","date_received":"2025-05-21T16:37:02.000Z","state":"FL","company_public_response":null,"sub_issue":"Reporting company used your report improperly"},"highlight":{"complaint_what_happened":["Additionally, my credit scores should be recalculated without the influence of this derogatory item, and I should be provided some assurance that any lingering negative impact ( such as low score or <em>risk</em> flags caused by the account ) has been fully <em>mitigated</em>. \nGoodwill <em>Measures</em> for Damage Done : While the immediate deletion is top priority, I also ask that Experian and Equifax take steps to <em>mitigate</em> the damage Ive suffered."]},"sort":[7.2779903,"13642578"]},{"_index":"complaint-public-v1","_id":"13642769","_score":7.267872,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"Introduction & Summary of Complaint I, XXXX XXXX, hereby submit this second formal complaint against Experian and Equifax for their willful and unlawful handling of a fraudulent XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX account on my credit reports. This account was previously deleted from all of my credit files ( as of XX/XX/year> ) after being confirmed inaccurate and unauthorized, yet it has been reinserted without any notice to me a blatant violation of the Fair Credit Reporting Act ( FCRA ) 611 ( a ) ( 5 ) ( B ) ( ii ). The reinsertion of this deleted account is fraudulent, deceptive, and has caused me severe emotional and financial harm. I write to demand immediate relief and to hold Experian and Equifax accountable for this egregious breach of my consumer rights. \n\nSummary of Issues : Illegal Reinsertion without Notice : A XXXX  account not belonging to me was deleted after dispute, but Experian and Equifax reinserted it into my credit reports without providing the required written notice within 5 business days, violating federal law.\n\nUnauthorized/Stolen Account : The XXXX account in question is the result of unauthorized use of my identity effectively a stolen account that I never opened, authorized, or benefited from. It should never have been reported under my name. \nPattern of Misconduct : Experian and Equifax have demonstrated a pattern of deceptive trade practices and systemic misconduct, ignoring my prior CFPB complaint ( filed XX/XX/year> ) and continuing to report false information. This knowing failure to correct their practices shows a willful violation of the FCRA and other consumer protection laws. \nConsumer Harm : I am suffering significant emotional distress ( anxiety, sleeplessness, and humiliation ) and financial injury ( damage to my credit scores, denial of credit opportunities, and higher costs ) due to their negligence and willful non-compliance. I have been forced to expend time and resources to address a fictitious debt, which is ruining my financial reputation through no fault of my own. \n\nI urge the CFPB to take this complaint with utmost seriousness. Below, I provide detailed facts, legal violations, and the relief sought. My goal is the permanent deletion of this bogus account and accountability for those responsible, so that no other consumer endures this debt slavery being trapped by a false debt on their credit report. \n\nBackground : Deleted Account Illegally Reinserted XXXX  Account Details : The account at issue is a XXXX XXXX XXXX XXXX XXXX XXXX XXXX account that was fraudulently opened or attributed to me without my authorization. After discovering it on my credit reports, I disputed the account with all credit bureaus. As a result, by XX/XX/year>, the account was deleted from my Experian and Equifax reports ( indicating it was unverified/inaccurate ). I have official dispute results confirming that the XXXX tradeline was removed due to lack of verification or accuracy. \n\nReinsertion without Notice : Shockingly, in XX/XX/year>, I found that this XXXX account had been reinserted into my Experian and Equifax credit files without any advance notice or explanation. I never received the written notice that is required within XXXX business days of reinsertion under the FCRA. In fact, I received no communication whatsoever from Experian or Equifax informing me that they were adding this previously-deleted item back onto my reports. This clandestine reinsertion is illegal. FCRA 611 ( a ) ( 5 ) ( B ) ( 15 U.S.C. 1681i ( a ) ( 5 ) ( B ) ) lays out strict conditions for reinserting deleted information : Certification Requirement : A deleted item may not be reinserted unless the furnisher certifies the information is complete and accurate.\n\nConsumer Notice Requirement : If a deleted item is reinserted, the credit bureau shall notify the consumer in writing within XXXX business days of the reinsertion, including details of the furnisher and the consumers rights. \n\nExperian and Equifax appear to have violated both provisions. They either reinserted the account without obtaining a valid certification of accuracy, or accepted a dubious certification despite the account being previously deemed unverifiable. In either case, they failed to notify me in writing of the reinsertion within the 5-day window ( or at all ). This is a direct violation of federal law. By law, the absence of timely notice alone renders the reinsertion unlawful. The violation is clear-cut and inexcusable.\n\nNo New Information or Valid Basis : There was no legitimate new information that could suddenly make this account verified. The account remains fraudulent and inaccurate. Its prior deletion establishes that XXXX could not verify it as my debt. Any purported certification by XXXX to re-report this account is highly suspect and likely false. Therefore, the reinsertion is not only procedurally improper, but also a substantive act of fraud re-reporting information known to be unverifiable and false. I have strong reason to believe this reinsertion was done in bad faith, possibly as part of a collusive arrangement between XXXX and the credit bureaus to push a bogus debt onto my reports. ( Notably, XXXX stands to benefit from having the account reappear, as it pressures me to pay or settle a debt I do not owe. Experian and Equifaxs willingness to violate the law in this manner raises the question of whether they are receiving fees or other incentives for such illicit reinsertions an unlawful collusion and abuse of the credit reporting system. ) Lack of Notice to Complainant : To reiterate, I was completely blindsided by the reappearance of this account. I only discovered the reinsertion by monitoring my credit no notice came from Experian or Equifax. This lack of notice deprived me of the opportunity to immediately dispute or block the reinserted entry, which is exactly the kind of harm the FCRAs notice requirement is meant to prevent. The bureaus secretive action demonstrates a willful disregard for my rights and basic fairness. \n\nUnauthorized Account & Identity Theft The XXXX account is fraudulent it does not belong to me. It appears to be an account opened or used by someone else ( or created due to identity theft ), which was then incorrectly attributed to me on my credit file. I have never had any business relationship with XXXX XXXX XXXX XXXX. This account is the result of identity theft or mistaken identity, and it was already acknowledged as such when it was deleted after my initial dispute. \n\nAccount Was Stolen/Inaccurate : For clarity, this account is essentially a stolen account either opened using my personal information without my permission, or erroneously reported under my name when it pertains to another individual. It is an inaccurate trade line that should never have been reported on my credit in the first place. By reinserting this account, Experian and Equifax are effectively reporting bogus debt information against an innocent consumer ( myself ). This is beyond negligent ; it is a knowing dissemination of false information. \n\nXXXX. FCRA 623 Violations by Furnisher ( XXXX ) : While this complaint is directed at the credit bureaus, it must be noted that XXXX, as the furnisher, XXXX have violated its own legal duties. If XXXX certified the account as accurate despite it being fraudulent, XXXX violated FCRA 623 ( a ) ( 1 ) ( A ) ( 15 U.S.C. 1681s-2 ( a ) ( 1 ) ( A ) ), which prohibits furnishing information known ( or that should be known ) to be inaccurate. XXXX also failed to conduct a good-faith reinvestigation upon my disputes and apparently re-furnished the disputed information without any new proof of validity a potential violation of FCRA 623 ( b ) duties to investigate and correct. These actions by XXXX amount to furnishing false credit information and could not have been done in good faith. I am including this point because Experian and Equifaxs reinsertion of the account suggests they relied on XXXX word ; if so, all parties are complicit in re-reporting false data. Experian and Equifax had an obligation under FCRA 611 to ensure the furnishers certification was legitimate before reinstating the item they apparently failed in this obligation.\n\n4. Unfair and Deceptive Acts and Practices ( UDAP ) : The conduct of Experian and Equifax constitutes unfair or deceptive trade practices in violation of Section 5 of the Federal Trade Commission Act ( 15 U.S.C. 45 ) and state consumer protection laws. Reinserting a previously deleted, disputed debt without notice is inherently deceptive, as it misleads the consumer and any third-party viewing the report about the legitimacy of the debt. It is also unfair, as it causes substantial injury ( credit damage and emotional distress ) that the consumer can not reasonably avoid, with no countervailing benefit. These credit bureaus are systemically betraying consumer trust and public policy by flouting dispute resolutions and secretly re-aging debts. In fact, the CFPB has recently taken enforcement action underscoring how both Equifax and Experian have engaged in systemic violations related to dispute handling and reinsertion : Equifax was found to have allowed previously deleted inaccuracies to be reinserted into credit reports, leading to a {$15.00} million penalty in XXXX  and Experian was sued in 2025 for failing to properly investigate disputes and reinserting errors on credit reports. This shows that what I am experiencing is not an isolated mistake but part of a pattern of willful misconduct by these bureaus. Experian and Equifaxs actions in my case mirror the very abuses identified by regulators ( e.g. sham investigations and unlawful reinsertion ), proving their knowing non-compliance despite being on notice. It is deeply deceptive and unethical for Experian and Equifax to present themselves as purveyors of accurate credit data while deliberately reintroducing information they know to be false. Such behavior also violates the spirit of the Consumer Financial Protection Act ( under which the CFPB can deem practices unfair or abusive ). \nXXXX. Debt Slavery and Potential Extortionate Conduct : By continuously reporting a false debt that I do not owe, Experian and Equifax have effectively shackled me to a debt that is entirely fabricated. This situation feels like a form of * * debt bondage or debt slavery, wherein I, the consumer, am being forced to suffer indefinite credit harm unless I somehow pay or resolve a debt that isnt mine. This term is not used lightly the practice of coercing payment by damaging someones credit is akin to using extortion. In fact, using credit reporting as a weapon to pressure consumers into paying illegitimate debts can be seen as an extortionate means of debt collection. Under 18 U.S.C. 894, it is a federal crime to use extortionate means ( including coercion or implicit threats ) to collect a debt, punishable by up to 20 years in prison. While Experian and Equifax are not traditional debt collectors, their willful perpetuation of false credit data serves to coerce me into paying or dealing with the fraudulent XXXX account to regain my financial freedom. They are facilitating XXXX attempted collection through extortionate damage to my reputation. I want to put Experian and Equifax on notice that this behavior is not just a civil violation it veers into potentially criminal territory. By knowingly participating in the continued reporting of a bogus debt ( after being informed of its false nature through disputes and a prior CFPB complaint ), they are participat [ ing ] in the use ofextortionate means to collect an extension of credit. If they do not cease, I will be urging regulators and law enforcement to investigate these actions under relevant criminal statutes. No consumer should be held financial hostage by false information in this manner.\n\nIn summary, Experian and Equifax have violated the FCRA, the FTC Act, and possibly criminal laws through their handling of my case. Their actions are knowing, willful, and part of a broader pattern of ignoring consumer rights. \n\nPrior CFPB Complaint & Willful Non-Compliance This is my second CFPB complaint on this matter. I previously submitted a CFPB complaint on XX/XX/year>, detailing the issues with this XXXX account and the improper conduct of Experian and Equifax. That prior complaint put both bureaus on explicit notice of the accounts fraudulent nature and their legal obligations. Equifax and Experian were thus fully aware as of early XX/XX/year> that : ( a ) the XXXX account did not belong to me, had been deleted for lack of verifiability, and ( b ) any reinsertion would be unlawful without following FCRA protocols. Despite this, they have failed to take corrective action and allowed the situation to deteriorate further. The fact that the account remains ( or was reinserted ) after my XX/XX/XXXX complaint demonstrates a knowing and willful violation. They are not making a mistake in good faith they are consciously flouting the law. This willfulness entitles me to enhanced remedies under the FCRA ( such as punitive damages ). It also indicates that internal compliance and back-office teams at these bureaus are either negligently incompetent or intentionally abusing the system. In either case, accountability is required. \n\nI urge the CFPB to review my prior complaint ( including any responses, or lack thereof, from Experian/Equifax ) as context. The bureaus disregard of a regulator-facilitated complaint process highlights their brazen attitude. If a CFPB complaint could not compel them to simply obey the law and remove a known false account, it evidences a systemic problem and a willful contempt for consumer protection laws on the part of these companies. It is also evidence that stronger action such as supervisory or enforcement intervention may be needed by CFPB in addition to resolving my individual issue.\n\nImpact on Complainant ( Damages ) Experian and Equifaxs actions have caused me substantial harm, both emotionally and financially : Emotional Distress : I have suffered anxiety, stress, and loss of peace of mind knowing that a blatantly false account is tarnishing my credit. I constantly worry about who sees this misinformation be it lenders, employers, or landlords and what they might think. The situation has caused me sleepless nights and feelings of powerlessness. It is deeply traumatic to be effectively accused of owing a debt that was a result of identity theft. The reinsertion incident done secretly has further eroded my trust in the credit reporting system. I feel harassed and abused by the very agencies that are supposed to maintain fair and accurate credit files. This emotional toll is real and significant. \nDamage to Credit Standing : The false XXXX account has negatively impacted my credit score and credit profile. It is likely being reported with derogatory information ( e.g. a fraudulent balance, late payments or charge-off status that are not mine ), which lowers my credit score unjustly. As a result, I have been denied credit or offered credit at much higher interest rates than I deserve. For example, after this account reappeared, I noticed a drop in my credit score and have received credit card denials that cite serious delinquency or accounts in collection which align with the bogus XXXX entry. This means I am effectively being financially penalized for a crime committed against me. It is an outrageous situation. \nInterference in Life Opportunities : Because of this inaccurate credit information, my access to housing and employment may also be hindered. Many landlords and employers check credit reports. I now live in fear that an apartment application or even a job offer could be jeopardized by Experian and Equifax reporting me as delinquent on a fraudulent debt. This is causing immense additional stress and potentially limiting my economic opportunities. Such ripple effects are exactly why FCRA exists and why its violation is so serious. \nFinancial Costs and Time Loss : I have spent countless hours disputing, monitoring, and attempting to resolve this issue time that I should have been spending on my job and family. Ive incurred costs for mailing dispute letters, possibly credit monitoring services, and other expenses trying to protect myself. I am also preparing to file police reports or additional identity theft affidavits, which is an onerous process. All these burdens exist solely because Experian and Equifax failed to do their jobs correctly. They should compensate me for these losses. Moreover, I intend to seek statutory damages for each willful FCRA violation ( up to {$1000.00} each ) and any actual damages in a court of law if this is not promptly resolved, as allowed by FCRA 616, 617 ( 15 U.S.C. 1681n, 1681o ). The FCRA provides for even punitive damages for willful violations, which I will pursue given the egregious and knowing nature of this misconduct. \n\nIn summary, the negligence and willful misconduct of Experian and Equifax have caused me intense emotional suffering and put me at risk of tangible financial harm. They must be held accountable for these damages. I ask the CFPB to consider these impacts and use its full authority to obtain relief and deterrence. \n\nRelief Demanded Given the above facts and violations, I am seeking the following immediate relief and remedies to resolve my complaint : Permanent Deletion of the XXXX XXXXccount : Immediately and permanently delete the XXXX  account from all of my credit reports at Experian, Equifax, and TransUnion ( if it appears there ). This deletion should occur without possibility of reinsertion. The account is fraudulent, unverified, and unverifiable it must be removed for good. \nWritten Confirmation of Deletion and Cessation : Provide me with written confirmation ( from a high-level representative of Experian and Equifax ) that the XXXX XXXXcount has been deleted and will not be reported again under my file. This documentation should be provided within five ( 5 ) business days of your receipt of this complaint and should be on official letterhead, signed by a person with authority. It must state that Experian and Equifax will cease all reporting and use of this account data in any consumer report or credit score relating to me. In essence, I want proof that this account is gone and will stay gone permanently. \nDocumentation of Any Reinsertion Actions : I demand full documentation and disclosure of how this account was reinserted. This includes : any certification of accuracy XXXX provided, the date and method of reinsertion, the internal records showing the decision process for reinsertion, and identification of the employees or agents involved in approving the reinsertion at Experian and Equifax. I have a right to this information, especially given that the FCRA entitles me to know the furnishers details and that a reinsertion occurred ( which I was never told ). I want to see how such a mistake was allowed to happen despite the law and a prior dispute. \nIdentity Theft Block Implementation : Upon receipt of my FTC Identity Theft Report and request, Experian and Equifax must immediately block the reporting of the XXXX XXXXccount ( as well as any inquiries or derivative information related to it ) in my credit file, pursuant to 15 U.S.C. 1681c-2. This block must be put in place within 4 business days of my providing the required documentation, and I should receive confirmation of the block. After blocking, the bureaus must not reinsert or un-block the item unless permitted by the narrow exceptions in the law ( which do not apply here, as this is a clear case of identity theft, not an error or frivolous claim ). \nCease & Desist Order to XXXX XXXX XXXX request that CFPB forward a cease-and-desist notice to XXXX XXXX XXXX XXXX through this complaint process as well. XXXX must be instructed to cease all furnishing of this account data to any credit reporting agency. They should also cease any collection activities on this account, including harassing calls or communications ( I have received collection calls regarding this account in the past, which is outrageous since its not mine ). XXXX should be on notice that they face legal liability if they continue to pursue a victim of identity theft for this debt. While XXXX is not the primary subject of this complaint, their cooperation is necessary for a complete resolution. They should investigate their own records, recognize this account as fraudulent, close it, and not sell or transfer it ( if they havent already ). \nUpdated Credit Reports : After deletion and blocking, I demand updated copies of my Experian and Equifax credit reports ( at no charge to me ) to verify that the XXXX account has been removed. Additionally, my credit scores should be recalculated without the influence of this derogatory item, and I should be provided some assurance that any lingering negative impact ( such as low score or risk flags caused by the account ) has been fully mitigated. \nGoodwill Measures for Damage Done : While the immediate deletion is top priority, I also ask that Experian and Equifax take steps to mitigate the damage Ive suffered. For instance, they should assist me in notifying any recent creditors who pulled my report that the derogatory information was erroneous ( so I can perhaps get credit reconsidered ). They should also consider offering me a period of complimentary credit monitoring or other services to help regain my confidence, given how their failures have increased my risk. At minimum, I expect an apology and acknowledgment of error from both companies. \n\nAll the above actions are necessary to make me whole and prevent further harm. I expect these remedies to be carried out immediately upon receipt of this complaint. I will not accept half-measures ( such as a temporary deletion or a vague promise ). I want concrete, verifiable action and documentation. \n\nAccountability and Further Actions It is not enough to simply delete the account now that the damage is done ; Experian and Equifax must also be held accountable so that they do not repeat such conduct. I am therefore requesting that beyond the individual relief, the CFPB consider the following measures and that Experian and Equifax acknowledge these steps : Internal Disciplinary Action : Experian and Equifax should investigate the actions of their employees and automated systems that led to this unlawful reinsertion. The back-office compliance and dispute teams responsible must be retrained, disciplined, or removed if they willfully violated protocols. I demand that the companies report what internal corrective action they are taking ( e.g., if a particular department failed to send the notice, what is being done about it? ). Individual accountability is important those who knowingly broke the law should face professional consequences. \nCompliance Review and Certification : I call on Experian and Equifax to conduct a thorough compliance review of their reinvestigation and reinsertion procedures, and to certify to the CFPB ( and to me in writing ) that they have implemented measures to prevent such unlawful reinsertion in the future. This might include improved system checks to enforce the FCRA 5-day notice rule and stronger verification requirements before any deleted data can be re-reported. Given the CFPBs findings of widespread issues at these bureaus, a proactive compliance step is warranted.\n\nRegulatory Enforcement : I respectfully urge the CFPB to use its supervisory and enforcement authority in this case. These violations go beyond my individual incident ; they reflect broader problems. If not already under an enforcement action, Experians and Equifaxs behavior here might merit inclusion in any ongoing CFPB oversight of credit reporting agencies. The CFPB should ensure they pay penalties if appropriate, just as Equifax was fined for similar issues earlier in 2025. A strong regulatory response will incentivize compliance and show the industry that reinsertions without notice and related abuses will not be tolerated. \nCivil Litigation : If Experian and Equifax do not fully remedy this situation, I am prepared to pursue a civil lawsuit for FCRA and related violations. I will seek all available damages statutory, actual, and punitive for their willful noncompliance. As noted, willful FCRA violations can result in significant financial penalties and even punitive damages. I am also aware that each failure to comply ( each improper reinsertion and each lack of notice ) can be a separate violation, potentially multiplying the statutory damages. I would prefer to avoid litigation, but I will not hesitate if my rights continue to be ignored.\n\nCriminal Referral : Given the hints of collusion and willful data manipulation in this case, I also put Experian and Equifax on notice that I may seek a referral to the FTC, state Attorneys General, or even the Department of Justice for investigation into potential criminal law violations. As discussed, using false credit reporting to extort payment can violate federal criminal law ( 18 U.S.C. 894 ). Additionally, if any individual at the bureaus altered or suppressed the required consumer notice or tampered with my dispute, that could be considered mail or wire fraud. Knowingly providing false information to a federal regulator ( if they respond to CFPB with false claims ) can also be a crime. I urge the companies to consider their personal and corporate exposure here. This is not a standard, low-level error its a willful act that carries legal risk.\n\nPersonal Accountability of Management : I demand that upper management at Experian and Equifax acknowledge this complaint and take responsibility. Often these kinds of problems stem from corporate policies that prioritize profit or appeasing furnishers over consumers rights. I want to see a statement from a senior compliance officer or executive that they have reviewed my case and are ensuring compliance going forward. If this does not happen, it further evidences a culture of compliance failure, which I will report to the CFPB and appropriate authorities.\n\nLegislative and Public Policy Note It is worth noting that public policy is moving in a direction to further protect consumers from exactly the kind of harm Ive experienced. For example, in XX/XX/year> the state of Washington enacted XXXX XXXX XXXX, a law that prohibits collection agencies from reporting medical debt to credit bureaus, effectively ensuring that certain sensitive and often disputable debts ( like medical bills ) do not haunt consumers credit reports. This law was passed to protect consumers from unfair credit reporting practices that can ruin lives. The spirit of such legislation is to recognize that some debts or accounts should not be on credit reports at all due to their potential for error or harm. Similarly, federal regulators ( CFPB ) have been working on rules to curb credit reporting of medical debt and other abusive reporting practices. \n\nWhile my case is about a financial account, not medical, the principle is the same unauthorized or erroneous accounts must not be reported. XXXX XXXX and related initiatives show a growing consensus that consumers need stronger protections against improper credit reporting of any debt that is not valid or fair. By continuing to report a clearly unauthorized account, Experian and Equifax are acting contrary to this public policy trend and against the principles of fairness. In fact, their actions would be condemnable under any stricter regime contemplated by lawmakers. I cite this to urge the CFPB to act decisively consumers like me should not have to fight these battles when the law and emerging policies are on our side.","date_sent_to_company":"2025-05-21T18:00:15.000Z","issue":"Improper use of your report","sub_product":"Credit reporting","zip_code":"33993","tags":null,"has_narrative":true,"complaint_id":"13642769","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Experian Information Solutions Inc.","date_received":"2025-05-21T16:37:02.000Z","state":"FL","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Reporting company used your report improperly"},"highlight":{"complaint_what_happened":["Additionally, my credit scores should be recalculated without the influence of this derogatory item, and I should be provided some assurance that any lingering negative impact ( such as low score or <em>risk</em> flags caused by the account ) has been fully <em>mitigated</em>. \nGoodwill <em>Measures</em> for Damage Done : While the immediate deletion is top priority, I also ask that Experian and Equifax take steps to <em>mitigate</em> the damage Ive suffered."]},"sort":[7.267872,"13642769"]},{"_index":"complaint-public-v1","_id":"10981005","_score":6.3902016,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"XXXX XXXX XXXX XXXX XXXX XXXX\nConsumer Financial Protection Bureau (CFPB)\nXXXX XXXX XXXX XXXX XXXX, DC XXXX\nThis is to complain against RIA XXXX: HIGH\nIMPORTANCE: HIGH\n[WITHOUT PREJUDICE]\nI wish to practice my right as a customer of RIA to use your organisation's service, seeking a formal,\nimpartial investigation to amicably settle my dispute with RIA.\nIn order to clear up the myriad of letters and correspondences I have hitherto sent to RIA respecting my\ncomplaint, I believe it will substantially strengthen both my case and your understanding, by taking a\ndeeper look at the happenings of my case, and analysing the relevant facts in an objective and\ncomprehensive fashion.\nIt is crucial to note that I have been manipulated, socially-engineered and coerced to engage these\nfraudulent criminals. Much to my embarrassment, I recognise that I am the victim of an investment scam.\nMy complaint to the CFPB has arisen as I do not consider, by any stretch of the imagination, the conduct\nof RIA to be commensurate with their legal role and responsibility to their customers. They sell a service\nto look after their customers, protect their money and are a financial institution that maintains a traditional\nrelationship and way of working with its customers.\nDuring the complaints process with RIA, I found their communication ineffective, which further hides\ntheir conduct to management and diminishes the service offering to their clients. They are struggling to\nadapt their business offering in the ever-changing world of IT development. The internet is presenting a\nreal problem which they choose to manage in a way which is not in line with rules and regulations of\nCFPB as well as their own internal policy and procedures sold to their clients.\nGeneral Obligation:\nCommencing on XXXX XXXX, I fell victim to a multilayered scam operation orchestrated by XXXX XXXX (the Fraudsters or Company).\nMoney was transferred from my account in the total amount of XXXX XXXX.\nWhen determining whats reasonable and fair, we should focus on the issue of liability; common queries\ninclude, but are not limited to, the following (i)\nwhether RIA did not take notice of any rule, law, or regulation, and/or possibly missed any material\nelements of the relevant bylaws or codes of conduct, that may have prevented them from protecting my\nfinancial safety; (ii) whether by virtue of RIAs custodianship over my funds or by its control over them,\nthey owed a fiduciary duty to the me and if so, whether that duty was breached; (iii) whether RIA\npromoted the transaction(s) in question despite being aware of the nature of the transaction(s) in question\n(iv) whether RIA was in compliance with its own policies and procedures; (v) whether RIA owed duties\nto myself, what the scope of those duties was, and whether RIA did not uphold those duties; (vi) whether\nRIAs conduct was unfair; and (vii) whether RIA has within its power the ability to, and should,\ncompensate me for the harm that has befallen me.\nUpon identification of such unusual or suspicious activity, it is crucial that the relevant staff member\nadequately describe the factors making an activity or transaction suspicious, thoroughly depict the extent\nand nature of this activity and properly communicate to the customer that such activity meets the relevant\ncriteria of fraud.\nIn providing its services to a customer, a financial institution is required by law to exercise the care and\nskill of a diligent, prudent banker. In this case, this means that the payment service provider should not\nturn a blind eye to known facts pointing to a real possibility that their customer is being scammed. In\nother words, RIA must have had special knowledge of what was occurring or been alerted to a real\npossibility of fraud taking place. The financial institution must have known or reasonably ought to have\nknown that I was dealing with a scammer.\nGranted, there is room for diversity of view insofar as reasonableness is concerned. Indeed, there is a\nsense in which the standard of care of the reasonable person involves in its application a subjective\nelement.\nHowever, it must be remembered that the correct test is always reasonable care in all circumstances, not\naverage care. The fact that most people behave in a certain way may be good evidence that the conduct is\nreasonable, but this is not necessarily the case. Although reasonableness is a very fluid concept, all of\nthe evidence suggests that RIA did not foresee the fraud and disregarded even the most obvious dangers\nin this respect.\nSituations do tend to repeat themselves and it is advisable to examine previous outcomes to see how the\nstandard of the reasonable person should be applied, and that lessons can be learnt from the errors of the\npast.\nRIAs Position:\nPlease find attached all relevant evidence below.\nRIA conspicuously touts their security as a reason to use their service. Specifically, RIA writes on\ntheir website:\nWe work hard to protect you from fraud. That's why we:\n Apply best-in-class security technologies expertise to protect you 24/7, all year round.\n Secure every method of banking we offer including online, mobile, ATM and telephone\nbanking.\n Offer free security software from our trusted tech partners to download on to your devices.\n Frequently train our employees on the latest practices in cyber and physical security.\n Give you the security tips and resources you need to protect yourself from potential threats.\nRefuting RIAs arguments from a purely logical perspective:\nRIAs position is that the features of the situation at hand do not generate a genuine obligation to protect\ninnocent and helpless victims; they are essentially arguing that common-sense-based approaches are\ndoomed to fail, leaving their exclusively technical account of the subject matter as the only meaningful\nchoice. For reasons which are unclear, this extremely serious situation barely gets the attention it deserves\neven though ample evidence has been offered in support of this complaint.\nIn RIAs view, it is implied that we should not home in (and consequently rely) on unwritten laws,\npracticality, good judgement, reasonableness, sharpness, sensibleness, past outcomes, and insight, when\ntaking appropriate precautions. To underscore, once again, such views are at odds with common sense\nand are wildly irresponsible.\nImagine a view according to which the one and only thing that can make RIA morally obligated to do\nsomething is having it written down somewhere. Pursuant to this view, if RIA encounter the suffering of\ntotally naive victims, they are only obligated to intervene in or remedy the situation, to the degree\nrequired by written material. This is unbecoming for a reputable establishment such as RIA.\nI have reviewed the material hereto sent by RIA carefully, and it unfortunately provides no response to\nmy fundamental argument concerning the degree of care. Given its size, influence, and the resources at its\ndisposal, this establishment clearly had a far greater capacity than an individual such as myself had, to\ndetermine the level and likelihood of risk that a client such as myself is subjected to and had a duty to\nintervene as they now do to query in particular out-of-pattern transactions of this kind.\nIt is perfectly obvious that RIA, inadvertently, employs a subtle approach in addressing some of the key\nquestions in a manner which neither provides me with adequate support nor protects anything other than\nits own interests.\nIt is RIA here, who has the burden of proof, to show that it has exercised the duty of care, that is to say,\nthat RIA adhered to a standard of reasonable care in relation to the matter at issue given its extensive\nexperience compared to mine. It is RIA that claims that the damages which I have suffered in connection\nto this matter have not been reasonably foreseeable, and that my proposed degree of care is not, and has\nnot been, commensurate with RIAs capacity, experience, expertise, or scope of services in any way. To\nreemphasize, RIAs indisputable overriding purpose is by no means to purely execute transactions in a\nblind and blank fashion, but rather to strike a balance between executing those transactions and\ncapitalising on its undeniably vast capabilities to protect consumers thereby enhancing market integrity.\nApropos of the fluidity of the concept of reasonableness, all RIA has done in this regard is set up a\ndichotomy of having or not having the legal obligation under consideration, however, that does not go\none-inch toward explaining why various regulatory authorities, has maintained that financial institutions\ncan, and should, protect consumers using their systems, advanced technologies, and rich experience.\nRIA is obliged to take some action if it is sufficiently aware of a real possibility that a fraud may be being\nperpetuated. If you don't question its customers instructions or raise the possibility of a scam with the\ncustomer in these circumstances, it may be liable if the red flags indicate the customer is:\n particularly vulnerable, or\n if the possibility of fraud was serious or real, not just suspected.\nThere are some recommendations to organisations for protecting customers from financial harm that\nmight occur as a result of fraud or financial abuse; and gives guidance on how to recognise customers\nwho might be at risk, how to assess the potential risks to the individual and how to take the necessary\nactions to prevent or minimise financial harm.\nThese recommendations are established as a general principle, the organisation should deliver a\nservice that:\n1) Takes a proactive approach to minimising risks, impact and incidences of financial harm and it\nsets out systems and tools for the prevention and detection of fraud and financial abuse. As a general\npoint, it says organisations should ensure that all systems are developed using technologies and\nmethodologies that are effective in the prevention of fraud and financial abuse, through authorised\nand unauthorised payments, thereby minimising the risk of financial harm to customers. As regards to\nthe detection of fraud and financial abuse, it says the organisation:\nA) should have measures in place across all payment channels and products to detect suspicious\ntransactions or activities that might indicate fraud or financial abuse. It then lists the following\nexamples of suspicious activity on customer accounts:\na. multiple cheque books;\nb. sudden increased spending;\nc. transfers to other accounts;\nd. multiple password attempts;\ne. logins from new devices, multiple geographical locations;\nf. sudden changes to the operation of the account; Unusual transactions are\ntransactions whose amount, characteristics and frequency bear no relation to the\neconomic activity of the customer, exceed normal market parameters or have no\napparent legal justification.\ng. a withdrawal or payment for a large amount;\nh. a payment or series of payments to a new payee;\ni. financial activity that matches a known method of fraud or financial abuse.\nB) organisations should have a process in place to ensure that staff make contact with the\ncustomer to verify the financial activity, challenge its authenticity, explain the nature of the\nsuspected or detected fraud and discuss an appropriate plan of action.\nRIA are yet to show, or otherwise provide me with, a compelling argument that their wide-ranging\nexperience and wealth of specialist knowledge in detecting transactional anomalies were not sufficient to\navert the fraud at issue. By contrast, I have provided a multitude of sound and powerful reasons by which\nrequiring their involvement has not only been pressingly relevant but also eminently reasonable and welljustified.\nRather than empathising with and undertaking substantial efforts to convey their knowledge of the\nexistence of such regulations abroad and thereafter use it to protect and proactively relieve the plight of\nconsumers who have been cheated out of their money and whose role in society is properly fulfilled,\npositively contributing to local economic growth, development and sustainability  RIA adopts a rather\ninsouciant attitude toward my financial predicament portrayed herein.\nI am deeply convinced that the disastrous results that I have previously elaborated upon will continue to\nensue if no responsibility is adopted by RIA in relation to this matter. I have also thoroughly detailed why\nthey cannot simply dismiss this problem by strictly adhering to legal technicalities which, after careful\nreflection, struck me as being nothing more than self-interest. Indeed, it seems to me utterly unfair to\ndisregard fragile, sensitive, and vulnerable consumers who are afflicted by such allegedly malevolent acts,\nthereby keeping an unjust status-quo that is corrupting our society at its core.\nConclusion:\nBased on my analysis, and as confirmed by various authorities concerned with such matters, there is\nabundant evidence that forward-thinking financial institutions ought to take reasonable steps to forestall\nfraud, or at least mitigate its risk by using an effective risk management system, demonstrating their\nundisputed ability to responsibly and pre-emptively respond to questionable transactions in the digital\narena. The use of such systems, largely based on newly adopted technologies aimed at effectively\nnavigating the evolving threat landscape, is only one of a number of possible endeavours undertaken in\nthis connection, alongside the application of past knowledge and experience related to popular fraudulent\npractices.\nAstonishingly, I am pondering how it is that, despite being shown that RIAs business conduct was\ninsufficient insofar as background checks are concerned, they keep refuting their indisputable role and\nresponsibility in connection with the matter herein discussed. The points that I have hitherto made are too\ncrucial to be taken lightly. RIAs non-observance of the fundamental principles of justice  that is, to\ncompletely overlook and not even remotely try to mitigate the suffering of vulnerable consumers is\ninexcusable given the size of the establishment and the vast resources at its disposal as the direct result of\nthe patronage of clients like myself.\nIf it was, indeed, solely my responsibility, we must then believe at least one of the following clauses: a)\nfinancial institutions have absolutely no role whatsoever in preventing and detecting fraud, b) the fraud in\nquestion was not reasonably foreseeable, or c) the transactions in question were not sufficiently alarming.\nIt is extremely unfortunate that RIA pushes quite hard for me to believe all three of these thingsdespite\nevidence to the contrary.\nIn summary, I respectively ask your organisation to consider my points, given your personal and\ncompanywide obligation to provide a fair and reasonable investigation into the complaint.\nI look forward to your input and would gladly cooperate to reach a fair and reasonable outcome.\nThank you. XXXX XXXX XXXX\nXXXX  THE REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK\nXXXX XXXX XXXX\nTo: RIA\nXXXX XXXX, California , United States\nVia Email\n[Without Prejudice]\nAttn: Complaints/Fraud Dept.\nDear Sir or Madam,\nRe: Demand Letter  Fraud\nI hope this letter has correctly found itself within your complaints/fraud department as it is essential to me that\nyou become aware of the ordeal I have had to go through.\nCommencing on XXXX XXXX I fell victim to a multilayered scam operation orchestrated by XXXX XXXX (the Fraudsters or Company) with the design, development, manufacturing, promoting,\nmarketing, distributing, labeling, and/or sale of illegal and outright fraudulent investment services, all of\nwhich aim at contributing to the goal of robbing and defrauding clients through a predetermined cycle of the\nclient losses to gains.\nMoney was transferred from my account in the total amount of XXXX XXXX utilizing your services.\nOVERVIEW\n This letter shall thrust into the spotlight, inter alia, the increasingly important role those financial\ninstitutions play in the fight against financial crime and fraud, and the pressing need for enhanced\nsupervision and vigilance within your organization.\n Heres an indisputable fact: had you looked at the wider circumstances surrounding the abovereferenced\ntransaction(s), this illicit transfer of wealth could have been prevented.\n Obviously, there is no consensus with respect to the degree and scope to which regulated and licensed\nfinancial institutions must intervene and block suspicious transactions, and indeed, in so doing,\nfinancial institutions may often cause payments to be slowed down unnecessarily or even some\nlegitimate payments may be rejected, however, please be noted that additional frictions such as slower\npayments (such as delaying payments or freezing funds to investigate) is beneficial to and welcomed\nby vulnerable customers and is widely considered to be a positive practice that is necessary in order to\nmaintain their financial safety, particularly for large-value and/or out of pattern.\n Executing transactions without proper authority is not only a severe regulatory offense but also an\nirresponsible and reckless disregard of the customers financial safety.\n Against this background, and without derogating any of my rights, I hereby hold you liable for\nfinancial and emotional harm as well as medical problems relating to this victimization and insist that\nyou reimburse my account in full within 14 days from the date of this letter.\nINTRODUCTION\nFinancial crimes and fraud investigations often involve a high degree of sophistication, complexity, and\nsensitiveness to detail. Accordingly, this letter aims to address the issue at hand as profoundly and fairly as\npossible, by taking into consideration contextual regulations, laws, and bylaws, as well as guidance, standards\nand rules promoted by supervisory authorities, relevant codes of practice and (where suitable) what was good\nindustry practice (GIP) at all times relevant hereto. The allegations contained herein are predicated either\nupon knowledge with respect to myself and my own experience, or upon facts obtained through investigations\nconducted by qualified third parties. I strongly believe that substantive evidence in support of the allegations\nset forth herein will be found after an appropriate opportunity for discovery. Key facts supporting the\nallegations contained herein are known only to the Company and/or are exclusively within their control.\nThe Company cleverly orchestrated a prevalent scheme of deception to lead people to invest significant sums\nwhile knowing that those would-be investors would ultimately lose the money, they had entrusted to it. The\noverall purpose of the scheme, in other words, was to target and defraud people who are often inexperienced\nand naive, in pursuance of illicit wealth through various fraudulent representations.\nI did not know, and through the exercise of reasonable diligence could not have discovered, the fraud\nthat was being perpetrated upon me by the Company. Fraud is commonly conceptualized as withholding\nfrom the weaker party in a financial transaction (e.g., an investor) information which is necessary to make an\ninformed, rational or autonomous decision.\nIn this regard, even access to adequate information is insufficient to achieve complete autonomy. A\ncomplication here is that the weaker party, amateur/unseasoned investors in particular, might have trouble\nanalyzing the data at hand sufficiently well to identify fraudulent schemes. Unfortunately, because financial\nproducts are often abstract and complex, there is no easy solution to this problem. Therefore, full autonomy of\ninvestors might not only require access to sufficient information, but also access to relevant technologies,\nknow-how, processing capabilities, and resources to analyze the information. A reasonable solution is that\nfinancial institutions would be required to promote transparent communication in which they track the\nunderstanding of its customers.\nAccording to the Federal Trade Commissions interpretations of certain terms (like the words deceptive and\nunfair), the FTC has found that a deceptive act or practice encompasses a representation, omission or\npractice that is likely to mislead the consumer acting reasonably in the circumstances, to the consumers\ndetriment.\nThe federal courts have defined a deceptive trade practice [i] as any act or practice that has the tendency or\ncapacity to deceive consumers and have defined an unfair trade practice as any act or practice that offends\npublic policy and is immoral, unethical, oppressive, unscrupulous, or substantially injurious to consumers.\nThe false representations and omissions made by the Company have a tendency or capacity to deceive\nconsumers, such as myself, into unwittingly providing funds that fueled the Companys fraudulent scheme\nand are therefore, by their very nature, jointly immoral, unethical, oppressive, unscrupulous, and\nsubstantially injurious to consumers.\nAs a result of the Companys deceptive trade practices, I was deceived into transferring my funds for\ninvestment returns that were never delivered. I will certainly never receive any monetary value for the\ninvestments considering the way the Company had their scheme rigged, thus causing significant economic\ndamage to me. The false statements of material facts and omissions as described above; and the fraudulent\ntransaction(s) the Company perpetrated upon me; were unfair, unconscionable, and deceptive practices which\nwould have likely deceived any reasonable person under the circumstances.\nMERCHANTS FRAUD SCHEME  ALLEGATIONS\nThe Company hired, managed, and trained personnel, and collaborated with others as accomplices to\ntheir crimes to induce fraud that resulted in my financial and psychological damages. These include,\nbut are not limited to, the following allegations, all of which involve criminal, non-regulated, and\nmalicious activities:\n1. The Company directed and instructed others to work from shell companies that were operating\nfrom various unassociated locations across the globe.\n2. The Company opened bank accounts in multiple countries and used them through their\naccomplices and strawmen from around the world to conceal and disguise the identity of\nillegally obtained proceeds so that they appear to have originated from legitimate sources.\n3. The Company intentionally committed fraudulent misrepresentation, and falsified its agent names,\ncredentials, competencies, qualifications and location. The Companys name is merely a brand name,\nofficially owned by shell corporations located offshore. In reality, the entire operation is being\nconducted from elsewhere (supposed location is evidently fictitious), and on top of that the call center,\nmarketing, and decision making, are all being performed by completely anonymous and hidden\nentities. Concealing true identities and utilizing front companies as a vehicle for a wide spectrum\nof financial maneuvers is a notorious practice of criminal organizations.\n4. The Company has blatantly violated international laws, as it has been practicing without a\nlicense and funneling enormous sums of money, through countries and jurisdictions that require\nregistration to operate.\n5. The Company provided direct investment advice - not utilizing 3rd party recommendations (e.g.,\naccording to Bloomberg TV/Investing.com)\n6. The Company offered investment services/advice not related to real market/exchange data\n(manufacturing false charts etc.). The trading platform was purposely manipulated, in a way that\neach client would ineluctably and unknowingly lose money, as the trades were simply\nconcocted. Instead, the Companys staff and its accomplices simply pocketed the money, using\nit to purchase various luxurious, non-essential items.\n7. The Company prohibited my ability to withdraw my funds.\n8. The Company was guaranteeing returns/yields (unrealistic ones).\n9. The Company furnished me with bonuses - which are not allowed to be given.\n10. My money was not held in a segregated account.\n11. The Company did not advertise/disclose/was not transparent regarding the statistical data representing\nthe percentage of total client losses at the company.\n12. The Company did not mention the commission and overnight swaps.\n13. The Company did not read the risk disclosure prior to my deposit(s).\n14. The Company used high pressure tactics and outbursts, which took a severe toll on my health.\n15. Armed with my personal details, the Companys staff seduced me into transferring all of my\nsavings to them. They utilized their knowledge of my cultural context, which stressed square\nand honorable business dealings along with honesty, in order to maliciously take advantage of\nmy trusting nature.\nPlease take notice that my funds were transferred through means of coercion and under false pretenses.\nAttached, please find supportive statements, screenshots, and further evidence.\nEXPOSING YOUR ORGANIZATIONS MISCONDUCT\nI hereby allege that your organization has completely failed to adequately investigate the circumstances\nsurrounding the transaction(s) in question and willfully blinded itself to obvious red flags.\nMany suspicions should have arisen at your organization as an issue of great concern, with respect to the\nunusual activity taking place in my account. Despite the regulatory and statutory requirements your\norganization should abide by as a licensed and regulated financial institution  and instead of detecting\npatterns, drawing certain conclusions, and taking actions accordingly you at best, merely and insufficiently\nperformed some hasty and haphazard reviews of the transaction(s) or possibly asked only minimal generic\nquestions regarding the suspicious activities, and at worst, shut your eyes completely rather than being careful,\nmethodical, and vigilant. Had you bothered, you would probably have realized that the funds were associated\nwith fraud and financial crime, rather than some other legitimate revenue/activity.\nIn light of the above, and after conducting a comprehensive review of our communication/interactions,\nit has become glaringly obvious to me that no adequate information and/or documentation were sought\nby your organization, at best, and at worst no appropriate safeguards were implemented.\nIf a financial institution executes a customer order to transfer money knowing it to be dishonestly given,\nshutting its eyes to the obvious fact of the dishonesty, or acting recklessly in failing to make such inquiries as\nan honest and reasonable individual would undergo, it would be in breach of its duty of care, even if the\npayment was made in accordance with the terms of the mandate, and the financial institution should still be\nliable for negligence resulting in damages.\nCompliance departments should ensure that staff members understand the legal requirements and where there\nare suspicions, these suspicions be communicated to all relevant personnel whilst being investigated.\nFor the avoidance of doubt, reasonable grounds should not necessarily be interpreted as proof. On the basis of\nvarious signs, you should have assumed that something suspicious was going on therefore should have\nsuspended transaction(s) until reasonable enquiries could be made to verify that the transaction(s)\nwas/were properly executed. In other words, I am a victim of your negligence for facilitating the\nmisappropriation of funds, and doing little to safeguard public financial interests. Any reasonable staff\nmember would have realized that there were many obvious, even glaring, signs that I was being defrauded.\n(XXXX XXXX XXXX (in liquidation) v XXXX XXXX XXXX XXXX XXXX [XXXX] XXXX XXXX) [ii]\nYou knew or should have known that the funds being transferred through your services did not rightfully\nbelong to the recipient fraudsters. Similarly, you knew or should have known that the funds being transferred\nthrough your services serve no legitimate or lawful purpose. You turned a blind eye to the crimes that you\nhave facilitated and thus provided an array of essential money transfer services, acting as a vehicle, with the\nawareness that it was enabling the fraudsters to commit crimes and enrich themselves with the funds of their\nvictims.\nYour services undoubtedly served as a crucial element in the fraudulent scheme detailed herein, and you were\neither unaware of your complicity in the fraud, or, more worryingly, completely aware and silent. Had you\nconducted an adequate account analysis, you would have discovered the nature of the recipient, and\nsubsequently, disclosed and reported the fraudsters activities to law enforcement authorities/agencies and\nregulators. Instead, to satisfy your financial interests, you conveniently closed your eyes, even though you\nundeniably had, at all material times, the necessary controls and resources to influence, whether directly or\nindirectly, those particular transactions.\nYou also had the duty to stop those crimes, yet you refused to do so because you were more interested in\nenriching yourself, even if it meant furthering those crimes and allowing them to cause massive financial\nlosses to plenty of victims  many of whom are probably your customers. Therefore, it is clear that you did\nnot have in place adequate security measures to properly safeguard my assets  hence, you have\nirreparably harmed me and, if not enjoined, will continue to irreparably harm other victims as well as\ntheir loved\nones and associates. You have irreparably harmed me and, if not enjoined, will continue to irreparably\nharm the general public, and our society deserves better.\nA financial institution which wrongly pays money away when it has no authority to do so will usually be\ntreated as if it had paid using its own funds, not those of its customer.\nWhen discussing the responsibilities that a financial institution might incur, it is crucial not to forget the fact\nthat a legitimate complaint by, or cause of action on the part of, a client might generate/give rise to further\nstatutory cause of action and/or additional liabilities beholden by a financial institution to the relevant\nregulatory authority. Obligations/duties beholden by a financial institution to a regulator are distinct from\nthose beholden to the customer. Moreover, you may be held liable to more than one regulator.\nAs a regulated and licensed financial institution, you have strict statutory and regulatory obligations to\nmonitor transactions and report any suspicious activities to law enforcement authorities. The importance of\nimplementing robust internal systems to detect and report money laundering and other suspicious activities\nhas been continuously emphasized in the industry in addition to having the appropriate policies, procedures\nand internal controls in place to ensure ongoing compliance in respect to the aforementioned systems. You\nshould have analysed and distinguished thereafter between that which may be normal activity and that which\ncould suggest an illegal activity. This is a well-known standard industry practice which plays a substantial role\nin preventing criminals from liquidating and laundering funds.\nFRAUD\nActual fraud can be described, inter alia, as suppression of that which is true, by one having knowledge or\nbelief of the fact. Therefore, due to your actual knowledge that such scams are so prevalent, you are liable for\ndamages. Similarly, due to the fact that you knew or were grossly negligent in not kn","date_sent_to_company":"2024-11-30T09:15:06.000Z","issue":"Fraud or scam","sub_product":"International money transfer","zip_code":"XXXXX","tags":null,"has_narrative":true,"complaint_id":"10981005","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Ria Envia, LLC","date_received":"2024-11-30T08:54:09.000Z","state":null,"company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["Conclusion:\nBased on my analysis, and as confirmed by various authorities concerned with such matters, there is\nabundant evidence that forward-thinking financial institutions ought to take reasonable steps to forestall\nfraud, or at least <em>mitigate</em> its <em>risk</em> by using an effective <em>risk</em> management system, demonstrating their\nundisputed ability to responsibly and pre-emptively respond to questionable transactions in the digital\narena."]},"sort":[6.3902016,"10981005"]}]},"aggregations":{"has_narrative":{"meta":{},"doc_count":7,"has_narrative":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":1,"key_as_string":"true","doc_count":7}]}},"product":{"doc_count":7,"product":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Money transfer, virtual currency, or money service","doc_count":4,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"International money transfer","doc_count":3},{"key":"Mobile or digital wallet","doc_count":1}]}},{"key":"Credit reporting 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":"Credit card","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"General-purpose credit card or charge card","doc_count":1}]}}]}},"issue":{"doc_count":7,"issue":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Fraud or scam","doc_count":4,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}},{"key":"Improper use of your report","doc_count":2,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Reporting company used your report improperly","doc_count":2}]}},{"key":"Other features, terms, or problems","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Problem with customer service","doc_count":1}]}}]}},"timely":{"doc_count":7,"timely":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Yes","doc_count":7}]}},"company_response":{"doc_count":7,"company_response":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Closed with explanation","doc_count":6},{"key":"Closed with non-monetary relief","doc_count":1}]}},"submitted_via":{"doc_count":7,"submitted_via":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Web","doc_count":7}]}},"company":{"doc_count":7,"company":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"BANK OF THE WEST","doc_count":1},{"key":"EQUIFAX, INC.","doc_count":1},{"key":"Experian Information Solutions Inc.","doc_count":1},{"key":"Foris DAX, Inc.","doc_count":1},{"key":"JPMORGAN CHASE & CO.","doc_count":1},{"key":"Ria Envia, LLC","doc_count":1},{"key":"TRUIST FINANCIAL CORPORATION","doc_count":1}]}},"state":{"doc_count":7,"state":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"FL","doc_count":2},{"key":"CA","doc_count":1},{"key":"MD","doc_count":1},{"key":"NH","doc_count":1}]}},"company_public_response":{"doc_count":7,"company_public_response":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","doc_count":2}]}},"tags":{"doc_count":7,"tags":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Older American, Servicemember","doc_count":1}]}}},"_meta":{"license":"CC0","last_updated":"2026-07-14T12:00:00-05:00","last_indexed":"2026-07-14T12:00:00-05:00","total_record_count":16441818,"is_data_stale":false,"has_data_issue":false,"break_points":{}}}