{"took":332,"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":"19410422","_score":30.271553,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"Formal Complaint Against PayPal I am filing this complaint regarding unauthorized recurring charges processed by PayPal beginning in 2014. \nSince approximately 2014, PayPal has been processing a recurring {$13.00} monthly charge labeled XXXX XXXX. I did not knowingly authorize this charge, did not subscribe to this service, and did not use XXXX XXXX or XXXX XXXX in connection with these payments. I also never received any emails, invoices, or notifications from PayPal regarding this recurring billing arrangement over the course of nearly XXXX years. \nI contacted XXXX to investigate, and they confirmed they are unable to locate any active or historical XXXX subscription associated with any of my XXXX accounts XXXX would explain or justify these charges. Despite this, PayPal maintained and continued a recurring billing agreement tied to this charge. \nI have now canceled the payment in PayPals Automatic Payments section, confirming that this was indeed an active billing agreement controlled by PayPal not by XXXX. \nBecause XXXX can not locate any subscription tied to my accounts, and because I was never notified of this recurring billing arrangement, I believe this charge was unauthorized and improperly maintained by PayPal for an extended period of time. \nI am requesting that PayPal : Identify and provide the billing agreement ID associated with this charge. \nDisclose the original creation date of this billing agreement.\n\nExplain how this agreement remained active for nearly ten years without my knowledge or consent.\n\nIssue a refund for unauthorized recurring charges to the maximum extent permitted. \nI am seeking a full investigation into this matter and a written response. \nThank you for your attention to this complaint.","date_sent_to_company":"2026-02-11T06:12:58.000Z","issue":"Unauthorized transactions or other transaction problem","sub_product":"Mobile or digital wallet","zip_code":"07747","tags":null,"has_narrative":true,"complaint_id":"19410422","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Paypal Holdings, Inc","date_received":"2026-02-11T06:04:25.000Z","state":"NJ","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["Formal Complaint Against PayPal I am filing this complaint regarding <em>unauthorized</em> <em>recurring</em> <em>charges</em> <em>processed</em> by PayPal beginning in 2014. \nSince approximately 2014, PayPal has <em>been</em> <em>processing</em> a <em>recurring</em> {$13.00} monthly <em>charge</em> <em>labeled</em> XXXX XXXX. I did not knowingly authorize this <em>charge</em>, did not subscribe to this service, and did not use XXXX XXXX or XXXX XXXX in connection with these payments."],"issue":["<em>Unauthorized</em> transactions or other transaction problem"]},"sort":[30.271553,"19410422"]},{"_index":"complaint-public-v1","_id":"8428461","_score":22.333485,"_source":{"product":"Credit card","complaint_what_happened":"I am writing to bring to your attention a concerning issue I have encountered with JP Morgan Chase & Co., a prominent financial institution. My complaint pertains to misleading practices surrounding their credit card locking feature, which has led to unauthorized transactions being processed despite the supposed security measure in place.\n\nAs a responsible consumer, I have taken proactive steps to safeguard my financial accounts by utilizing JP Morgan Chase & Co. 's credit card locking feature through both their mobile application and web browser interface. This feature, as advertised, is purported to prevent any transactions from occurring on the locked credit card, providing peace of mind to customers like myself. \n\nHowever, it has come to my attention that JP Morgan Chase & Co. has been disregarding the lock status set by customers and allowing certain transactions to bypass this security measure under the classification of \" recurring transactions. '' Despite my explicit instructions to lock my credit card, unauthorized charges labeled as recurring have been processed without my consent, leading to unnecessary financial strain and frustration.\n\nThis deceptive practice not only undermines the trust between consumers and financial institutions but also poses a significant risk to the financial well-being of customers. By falsely representing the effectiveness of their credit card locking feature, JP Morgan Chase & Co. is failing to fulfill their obligation to provide reliable and secure banking services to their clients.\n\nFurthermore, this issue extends beyond a mere inconvenience ; it raises serious concerns regarding consumer protection and financial security. Customers should be able to rely on the features and safeguards implemented by their bank to protect against fraudulent activities and unauthorized transactions. The blatant disregard for the lock status set by customers is not only unacceptable but also constitutes a breach of trust.\n\nIn light of these troubling practices, I urge the Consumer Financial Protection Bureau to investigate this matter thoroughly and take appropriate action to hold JP Morgan Chase & Co. accountable for their misleading practices. Additionally, I request that measures be implemented to ensure that the credit card locking feature functions as advertised, providing customers with the security and peace of mind they deserve. \n\nThank you for your attention to this matter. I trust that the Consumer Financial Protection Bureau will take swift and decisive action to address this issue and uphold the rights and interests of consumers.","date_sent_to_company":"2024-02-28T05:13:33.000Z","issue":"Problem with a purchase shown on your statement","sub_product":"General-purpose credit card or charge card","zip_code":"39110","tags":null,"has_narrative":true,"complaint_id":"8428461","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"JPMORGAN CHASE & CO.","date_received":"2024-02-28T05:08:12.000Z","state":"MS","company_public_response":null,"sub_issue":"Card was charged for something you did not purchase with the card"},"highlight":{"complaint_what_happened":["However, it has come to my attention that JP Morgan Chase & Co. has <em>been</em> disregarding the lock status set by customers and allowing certain transactions to bypass this security measure under the classification of \" <em>recurring</em> transactions. '' Despite my explicit instructions to lock my credit card, <em>unauthorized</em> <em>charges</em> <em>labeled</em> as <em>recurring</em> <em>have</em> <em>been</em> <em>processed</em> <em>without</em> my consent, leading to unnecessary financial strain and frustration."],"sub_product":["General-purpose credit card or <em>charge</em> card"]},"sort":[22.333485,"8428461"]},{"_index":"complaint-public-v1","_id":"14797834","_score":17.073114,"_source":{"product":"Debt collection","complaint_what_happened":"I am filing a formal complaint against Navy Federal Credit Union ( NFCU ) for engaging in unauthorized, recurring withdrawals from my personal checking account to collect on a charged-off debt reported closed on XXXX  XXXX XXXX.while reporting to XXXX  as XX/XX/XXXX. These withdrawals began as early as XXXX and have occurred without my permission, without a court order, and in clear violation of consumer protection laws. I was made aware of such debits last night on my credit report noticing a new payment date had been added however I had not made the payment. I then disputed the information. When I saw it on a secondary report I thought to check my account. And said last payment was drafted without my knowledge on XX/XX/XXXX which I had not made knowledge of because it was under the guise of adjustment on my account without no notation as to for what or where the money went to. \nKey Issues : * Unauthorized Debits : NFCU has been deducting funds from my account without consent or court judgment. They continue to tell me over the phone. They have the right to do so that it is page 2 of a three page document which they have failed to send to me even upon request. Speaking with multiple representatives, they have continued to tell me they have every right to do so and threaten to continue to do so illegally, claiming the document excludes them from laws and regulations that prohibit their actions. I am still waiting receipt of bank statements for the last seven years as I I am just now being made aware they are still drafting my account and I need to check how many occasions this has happened. Especially considering for the last seven years the money deposited into my account is my VA XXXX, which is clearly labeled when deposited. I have requested those statements and have also not received them yet. \n* Charged-Off Account : The debt in question was charged off and closed according to their reporting to transunion in XX/XX/XXXX, yet they continue to take money. \n* No Written Reauthorization : I have not given post-charge-off consent to resume or permit withdrawals. Or any consent ever, they have even taken from my XXXX childrens account as well. \n* I live in Texas : Texas law does not allow self-help bank offsets or wage garnishment for consumer debts without a court order. \n\nViolations Alleged : * Electronic Fund Transfer Act ( EFTA, Reg E ) : Unauthorized electronic fund transfers from my account. \n* Fair Credit Reporting Act ( FCRA ) : Continued negative credit reporting despite improper collection. \n* Fair Debt Collection Practices Act ( FDCPA ) : Misleading and abusive practices in debt recovery. \n* Texas Finance Code 392 & Property Code 42 : Prohibits post-judgment garnishment without legal process.\n\n* CFPB Consent OrdeXXXX ( XXXX ) : NFCU was previously fined and ordered to stop these exact practices. This indicates a knowing, willful violation of federal law and prior enforcement action. \n- [ ] Federal Rule : 31 CFR 212 ( Garnishment of Accounts Containing Federal Benefit Payments ) - [ ] Social Security Act 207 * VA Benefits Protections under 38 USC 5301 * XXXX XXXX Act Requested Resolution : * A full investigation into Navy Federals post-charge-off collection tactics * Refund of all money deducted from my account without legal authority since XXXX * Civil penalties for repeated violations of CFPBs prior order * A written response from Navy Federal including an accounting of all actions taken * Public record of this investigation to protect other consumers from harm I have attached : * My credit report showing the charge-off * Bank statements showing unauthorized drafts * My cease and desist letter * Proof of Texas residency * I also have my latest phone calls recorded asking for refund of charges, being denied and transferred. Even after citing legal framework being violated.\n\nThank you for reviewing this serious matter. I request urgent enforcement action and restitution under the applicable federal consumer protection laws.","date_sent_to_company":"2025-07-22T21:59:29.000Z","issue":"Took or threatened to take negative or legal action","sub_product":"Credit card debt","zip_code":"752XX","tags":"Servicemember","has_narrative":true,"complaint_id":"14797834","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"NAVY FEDERAL CREDIT UNION","date_received":"2025-07-22T21:37:41.000Z","state":"TX","company_public_response":"Company believes it acted appropriately as authorized by contract or law","sub_issue":"Collected or attempted to collect exempt funds"},"highlight":{"complaint_what_happened":["Key Issues : * <em>Unauthorized</em> Debits : NFCU has <em>been</em> deducting funds from my account <em>without</em> consent or court judgment. They continue to tell me over the phone. They <em>have</em> the right to do so that it is page 2 of a three page document which they <em>have</em> failed to send to me even upon request."]},"sort":[17.073114,"14797834"]},{"_index":"complaint-public-v1","_id":"13063421","_score":13.623481,"_source":{"product":"Payday loan, title loan, personal loan, or advance loan","complaint_what_happened":"Giggle Finance is misrepresenting a fixed-repayment, high-pressure loan product as revenue-based financing in order to evade lending regulations and mislead vulnerable independent contractors, freelancers, and small business owners. \n\nTheir marketing promises flexible repayment based on your incomebut what follows is a coercive, non-consensual collection model that includes unauthorized withdrawals, threats of credit reporting over 1-day delays, and an enforcement structure identical to companies already shut down by federal regulators for operating illegal MCAs. \n\nKey Issues 1. False Product Classification ( FTC Act 5 Deceptive Practices/ UDAAP Violations ) : Giggles public website claims : We purchase a portion of your future income at a discount. \nNo loans, no interest, and no hidden fees. \nIf your revenue slows, no problemjust let us know and well adjust your payment day. \n\nIn reality, their internal messaging and actions directly contradict this. Below are verbatim messages from their official SMS payment coordination thread : Your payment that was due on XXXX was never made after multiple attempts daily for your SCHEDULED AUTHORIZED payment. \nWe continue to attempt any missed payment until successfully processed, whether via debit or ACH. \nYou can not revoke your auto-payments with a past-due account. \nSo if missed by even 1 day, the payment is reported to the credit bureaus. \nWe dont allow for delays with these payments. \nYou were 2 weeks behind but we were able to take 1 of your missed payments this morning. \nYour third payment was due this morning this payment can not be delayed. \nDelays are not allowed what time will it be ready today? \n\nThis is not revenue-based financing. This is a fixed, non-adjustable repayment schedule, enforced regardless of actual income and disguised as something more flexible. \n\n2. Unauthorized ACH Debits ( EFTA / Reg E 12 CFR 1005.10 & 1005.11 ) : Giggle initiated a debit from a business checking account that was never explicitly authorized for ACH repayment, after receiving multiple written notices that no revenue had been received.\n\nPrior withdrawals had only occurred via personal debit cards The unauthorized ACH occurred immediately after a new deposit Communication instructing them not to charge had already been sent There is strong circumstantial evidence that XXXX  was used to monitor account activity and time the charge This violates Regulation E, which mandates : Written preauthorization for recurring ACH debits Immediate cessation upon revocation, regardless of account status 3. Coercive and Abusive Collection Practices ( FDCPA / FCRA 623 Violations ) : Giggle employs coercive, high-pressure collection tactics via their official SMS number, including : Threats of credit reporting for a single-day delay, in direct violation of FCRA 's 30-day reporting rule Refusals to acknowledge payment revocation, claiming SMS notice is invaliddespite using that same SMS line for all account coordination Ongoing extraction attempts after being told no revenue was available Emotionally manipulative messaging patterns designed to pressure vulnerable borrowers into payment under duress These tactics are documented in full, with timestamps and preserved screenshots. \n\n4. Use of XXXX  to Circumvent Consent and Time Withdrawals ( Breach of Platform Use + Deceptive Access ) : Giggle requires XXXX  during onboarding, citing underwriting purposes only. However : They initiated a withdrawal immediately after deposit activity Their user dashboard flagged a disconnected status only after XXXX  access was manually revoked This strongly suggests XXXX was used as a surveillance tool to time extractionswithout active consent Regulatory Pattern & Enforcement History : Giggle Finance is operating from the same illegal playbook that regulators have already dismantled : Par Funding Shut down by the SEC for XXXX XXXX XXXX XXXX $ XXXX FTC settlement for unauthorized debits and misrepresentation XXXX XXXX XXXXXXXX Targeted by state AGs for fixed-payback loans disguised as cash advances Giggle is presenting itself as a revenue-based financing partnerbut is, in practice, running an unlicensed, fixed-repayment loan operation under the false label of an XXXX. \n\nRequested Action : I am formally requesting an investigation into Giggle Finance for : Misrepresentation of loan classification under deceptive marketing Unauthorized ACH withdrawal activity Retaliatory and coercive messaging, including credit threats Use of XXXX  ( or equivalent ) to time collections post-onboarding Operating without valid lending licenses ( state and/or federal ) Evidence Available Upon Request : Full SMS message thread from Giggles official payment coordination number Screenshots of marketing claims on their public website ( * after I escalated this to XXXX, they have since edited their website. I have downloads and screenshots available of the original. It's also available on Archive.org ) Timestamps showing ACH activity post-notification Complaints filed ( or being filed ) with XXXX, XXXX, the Texas Attorney General, and Florida XXXX  Closing Statement : Giggle Finance is preying on financially vulnerable small businesses and independent workers by promising flexibilitythen delivering a fixed-payment loan enforced through threats and illegal withdrawals. This is not a misunderstanding or policy issue. This is a deliberate evasion of lending regulationsone that mirrors the exact behavior of firms already shut down. \n\nTheir own written communications confirm every element of the misconduct.","date_sent_to_company":"2025-04-18T18:35:56.000Z","issue":"Problem when making payments","sub_product":"Installment loan","zip_code":"787XX","tags":null,"has_narrative":true,"complaint_id":"13063421","timely":"No","company_response":"Closed with explanation","submitted_via":"Web","company":"Giggle Finance Inc.","date_received":"2025-04-18T18:02:20.000Z","state":"TX","company_public_response":"Company disputes the facts presented in the complaint","sub_issue":null},"highlight":{"complaint_what_happened":["Prior withdrawals had only occurred via personal debit cards The <em>unauthorized</em> ACH occurred immediately after a new deposit Communication instructing them not to <em>charge</em> had already <em>been</em> sent There is strong circumstantial evidence that XXXX  was used to monitor account activity and time the <em>charge</em> This violates Regulation E, which mandates : Written preauthorization for <em>recurring</em> ACH debits Immediate cessation upon revocation, regardless of account status 3."]},"sort":[13.623481,"13063421"]},{"_index":"complaint-public-v1","_id":"4111461","_score":11.430606,"_source":{"product":"Checking or savings account","complaint_what_happened":"I opened two REG-Z complaints in early XXXX with Wells Fargo and with CFPB. Both complaints were closed, without me being allowed to provide detail of REG-E violations ; or without even the labeling of my complaint as REG-E. OCC stated to me this week that I should ask CFPB to open a second complaint on the same UNAUTHORIZED TRANSACTION as a REG-E complaint ( consumer debit card ) and ask for an immedaite provisional credit of the {$2600.00} back into my account, as a pandemic hardship. I am also recovering from serious XXXX illness & symptoms. \n________________ 1. REG-E VIOLATIONS : WELLS FARGO BANK SUMMARY OF REG-E VIOLATIONS A. Wells Fargo put through an UNAUTHORIZED TRANSACTION of {$2600.00} on a closed debit card that cleared my account XX/XX/XXXX, over-drafting it, dislodging other legitimate charges pending, and damaging my credit score just as I was about to initiate a US Federal TSC-poly clearance. This was also an extreme financial hardship for me, costing me housing I was about to move back into from quarantine, after having caught XXXX at the vendor involved ; and then XXXX XXXX, and then XXXX XXXX and XXXX impact. \nB. Wells Fargo closed my claim wrongfully in 1 day, without investigating REG-E violations by itself or the merchant. Bank did not ask me REG-E questions, or allow me to furnish Reg-E documentation ( attached ). Complaint has been re-opened at least twice by \" executive '' offices of the bank but still no provisional credit extended, almost a month later. A pandemic hardship. \nC. Wells Fargo stated in writing to me, justifying closure of my REG-E complaint : \" ..we have determined the transaction was authorized or that a processing error did not occur. '' But the bank ignored my repeated requests to prove to me to show me my written authorization for this dollar amount, or for any pre-authorized installment contract or loan. \nD. I did NOT authorize this amount or this transaction. I had no expectation or warning of it. I do not owe it. \nE. Bank in verbal reviews of this unauthorized transaction with me, repeatedly refers only to my presence at this merchant you stayed there and refuses to address blatant REG-E violations by its personnel. OCC told me this week to ask CFPB and BANK to re-open this as a clear REG-E was the amount authorized? Is there proof of my written authorization AS DETAILED IN REG-E, not as the merchant or bank gloss over, etc? OCC SAID RELEVANT QUESTIONS ARE : Did I authorize this transaction in writing, for this amount, for this merchant and on this card, with understanding? I DID NOT. \nDid Wells Fargo and/or the merchant collude to violate my US Federal Civil Rights as a XXXX patient ; and /or to exploit my weakened condition as a recovering XXXX patient with serious XXXX and XXXX issues? * IF there was intentional exploiting of me as a XXXX patient that might invoke additional FEDERAL CIVIL RIGHTS, XXXX WHISTLE BLOWER, AND SPECIAL PANDEMIC OIG INVESTIGATION AND PROTECTIONS, FOR ME. And make punitive damages more likely. \nF. Wells Fargo forced compulsory credit onto me, by letting this unauthorized transaction clear and overdraft my account by {$1200.00} ; when I was not signed up for, had refused, Overdraft protection. See attached. ANOTHER REG-E VIOLATION.\n\nG. Wells Fargo then tried to claim this was a pre-authorized transaction, but none of the REG-E conditions for a legal pre-authorized transaction were met by bank or merchant. \n\n\n\n2. REG-E VIOLATIONS BY WELLS FARGO DETAIL 1. REG-E - 1005.10 ( d ) ( 2 ) : The published policy Wells sent to me to justify its conclusion that this was an authorized transaction violates REG-E Federal Requirements and definition of Authorized Transaction. \nIn a letter to me dated XX/XX/XXXX, Wells drew my attention to its published consumer account disclosures, including : \" ..if you give your debit card number to a merchant with authorization to bill for payment, or to keep it on file for future purchases or payments, the merchant may receive updated card information to process such payments ... '' Wells ' rationale for deeming this an 'AUTHORIZED ' transaction, it seems, was that if I ever in my lifetime give any merchant / vendor a WF bank card, credit or debit, that merchant has carte blanche ability & permission - from myself and from WF - to put through ANY FUTURE AMOUNT AT ANY TIME WITHOUT ANY WRITTEN PRIOR NOTICE TO ME, THE CONSUMER. IT COULD BE FOR {$1.00} XXXX, ONE WF REP SAID, AND IT COULD BE 10 OR 12 CLOSED BANK CARDS AGO .. WELLS FARGO WOULD STILL SEE THIS AS AN 'AUTHORIZED ' TRANSACTION AND NOT HONOR THE TERMS OF US FEDERAL REG-E. \nUnder this internal published policy and rationale, consumers can not apply Reg-E logic and restrictions because the bank simply ignores or disregards Reg-E requirements : e.g. written notification 10 days prior if the new amount varies from the last amount charged, written approval by the consumer to continue to charge that specific bank card, written approval by consumer for that specific amount, etc. \no I HAD SPECIFICALLY FORBIDDEN AND VENDOR GM XXXX XXXX AND AST MGR AMIT HAD AGREED TO DELETE THIS DEBIT CARD FROM THEIR BILLING SOFTWARE / SYSTEM AND NOT TO PUT ANY FUTURE CHARGES ONTO IT. AND I HAD DIRECTED THE VENDOR REPEATEDLY NOT TO PUT ANY FURTHER UNAUTHORIZED CHARGES ONTO ANY BANK CARD WITHOUT GIVING ME A DETAILED BILL AND ASKING ME FIRST. \n2. REG-E - 1005.10 ( d ) : Notice of transfers varying in amount : Official interpretation of 10 ( d ) Notice of Transfers Varying in Amount Show ( 1 ) Notice. When a preauthorized electronic fund transfer from the consumer 's account will vary in amount from the previous transfer under the same authorization or from the preauthorized amount, the designated payee or the financial institution shall send the consumer written notice of the amount and date of the transfer at least 10 days before the scheduled date of transfer. \nTHIS WAS NOT DONE BY THE MERCHANT. \nWELLS FARGO NEVER GAVE ME A CHANCE TO EXPLAIN OR TO CITE THEM THIS REG-E REQUIREMENT. Instead, the bank said repeatedly that the amount doesnt matter. If you gave them your card once, they can charge it forever. \nThe Unauthorized amount of {$2600.00} was over 600 % higher than the prior authorized amount, of {$440.00} ; or for the most immediately unauthorized amount of {$130.00}, charged without my approval or advance bill / warning, on XX/XX/XXXX. \nI never signed or authorized in writing a recurring, pre-authorized transaction, per REG-E. \nFEDERAL PRECEDENT FOR INTERPRETING REG-E AS I HAVE, IN THIS CONTEXT : This is exactly the offense that XXXX and other banks were fined tens of millions for, XXXX - XXXX : Not applying Reg-E to protect consumers on old, expired, or pre-authorized transactions. \n3. REG-E 1005.10 ( a ) ( 2 ) Pre-Authorized Transactions : 1005.10 ( a ) ( 1 ) ( ii ) ( a ) Preauthorized transfers to consumer 's account WHY THIS WAS NOT PRE-AUTHORIZED Show ( 1 ) Notice by financial institution. When a person initiates preauthorized electronic fund transfers to a consumer 's account at least once every 60 days, the account-holding financial institution shall provide notice to the consumer by : ( WELLS FARGO DID NONE OF THESE. I HAD TO CHECK MY LEDGER TO SEE THIS UNAUTHORIZED TRANSACTION, AND WAS ONLY ALERTED WHEN I ATTEMPTED TO USE MY DEBIT CARD AND IT SUDDENLY DID NOT CLEAR. BUT I HAD OVER {$1700.00} IN MY ACCOUNT, READY FOR RENT. ) ( i ) Positive notice. Providing oral or written notice of the transfer within two business days after the transfer occurs ; or ( ii ) Negative notice. Providing oral or written notice, within two business days after the date on which the transfer was scheduled to occur, that the transfer did not occur ; or ( iii ) Readily-available telephone line. Providing a readily available telephone line that the consumer may call to determine whether the transfer occurred and disclosing the telephone number on the initial disclosure of account terms and on each periodic statement. \n( 2 ) Notice by payor. A financial institution need not provide notice of a transfer if the payor gives the consumer positive notice that the transfer has been initiated. MERCHANT DID NOT DO THIS.\n\n( 3 ) Crediting. A financial institution that receives a preauthorized transfer of the type described in paragraph ( a ) ( 1 ) of this section shall credit the amount of the transfer as of the date the funds for the transfer are received. THIS WAS NEVER DONE OR GIVEN TO ME. WELLS NEVER CONSIDERED THIS. \n4. 1005.10 ( C ) ( c ) Consumer 's right to stop payment Official interpretation of 10 ( c ) Consumer 's Right to Stop Payment Show ( 1 ) Notice. A consumer may stop payment of a preauthorized electronic fund transfer from the consumer 's account by notifying the financial institution orally or in writing at least three business days before the scheduled date of the transfer. \n( 2 ) Written confirmation. The financial institution may require the consumer to give written confirmation of a stop-payment order within 14 days of an oral notification. An institution that requires written confirmation shall inform the consumer of the requirement and provide the address where confirmation must be sent when the consumer gives the oral notification. An oral stop-payment order ceases to be binding after 14 days if the consumer fails to provide the required written confirmation. \nBank REFUSED on XX/XX/XXXX when I visited a XXXX branch near the XXXX XXXX XXXX to let me put a stop payment order on my debit card or against this merchant. Bank said Wells Fargo lacked this capability. But under REG-Z Wells is compelled to provide this capability. Bank said that just opening a new debit card would be sufficient protection for me from this merchant or any other future fraud. THAT WAS NOT TRUE. \n5. ( e ) Compulsory use Official interpretation of 10 ( e ) Compulsory UseHide See interpretation of 10 ( e ) Compulsory Use in Supplement I ( 1 ) Credit. No financial institution or other person may condition an extension of credit to a consumer on the consumer 's repayment by preauthorized electronic fund transfers, except for credit extended under an overdraft credit plan or extended to maintain a specified minimum balance in the consumer 's account. This exception does not apply to a covered separate credit feature accessible by a hybrid prepaid-credit card as defined in Regulation Z, 12 CFR 1026.61.\n\nOfficial interpretation of 10 ( e ) ( 1 ) CreditHide 1. General rule for loan payments. Creditors may not require repayment of loans by electronic means on a preauthorized, recurring basis. \nThis provision of REG-E basically addresses the use of mandatory credit or overdraft extension to consumers without their prior written consent or authorization, to pay a merchant debt. I had / have no overdraft protection on the checking account or debit card ( closed or current ) used by the merchant for this unauthorized transaction : THIS OVERDRAFTED MY ACCOUNT BY {$1200.00} or provided me with forced or compulsory credit from Wells Fargo for a transaction I never authorized and am liable for only the first {$50.00} of, under REG-E. And now Wells Fargo also expects me to repay the overdraft of {$1200.00}, and has started to add interest to this owed amount, and is making collection calls against me! \nXXXX WHY THIS COMPLAINT WAS MIS-INTERPRETED BY WELLS FARGO AND CFPB AND A NEW COMPLAINT SHOULD BE OPENED PER THE OFFICE OF THE COMPTROLLER OF THE CURRENCY SO THAT I HAD FAIR TREATMENT UNDER THE LAW : 1. Wells categorized both the {$130.00} and {$2600.00} Unauthorized Transaction complaints on internal postings and in discussions with me in person at branches and over the phone as REG-Z ( credit card, billing dispute ) ; and not REG-E ( consumer debit card, UNAUTHORIZED TRANSACTION, BANK ERROR ), as my concerns should have been classified as. \n2. CFPB also classified and labeled this as something OTHER THAN A REG-E COMPLAINT calling it an account management complaint against Wells. But that is NOT REG-Z. CFPB PER THE OCC, MUST OPEN A PROPER REG-Z COMPLAINT BY ME AGAINST THE BANK. \nHERE IS THE WELLS FARGO VERBAGE THAT VIOLATES REG-E, CITED BY ITS PERSONNEL TO ME REPEATEDLY, STATING THAT ONCE ANY MERCHANT HAS ANY CARD NUMBER / AUTHORIZATION FROM YOU, THEY MAY USE THAT FROM THAT POINT FORWARD, TO INFINITY, FOR ANY AMOUNT. This was an invalid reason for closing my REG-Z claim or for determining that this was an authorized transaction. Because it violates federal consumer law. \n\n-- - MISC BACKGROUND my complaints regarding the conditions and illegal retaliation against me for reporting the hotels sanitation were valid, but OCC says they are REG-Z ( consumer credit ) just as is the merchants billing assertions. However, to the extent to which merchant behavior might be used to construe integrity or honesty or intent for purposes of evaluating REG-E compliance, in this current pandemic situation, here are highlights of my conditions and illegal retaliation remarks, as background only, made to Wells Fargo : Merchant cut off heat to my suites, or rather stopped the engineering team from scheduled repairs to the heat, after I raised XXXX XXXX and health dept sanitation concerns. And stated this openly. \nMerchant caused me to develop XXXX XXXX and worsened symptoms, if not XXXX itself, per my doctors XXXX XXXX XXXX. \nMerchant openly taunted me to just go into the hospital and took back its space heater in XXXX degree weather, after it overheard me speaking on phone about the conditions and possibly speaking to a law firm about personal injury damages. I could not leave, first due to XXXX, and as that came under control, XXXX impact -- if I even stood up my XXXX would either drop to XXXX - XXXX bpm and i would have to sit or lay down not to pass out ; or it would race erratically out of control. typical XXXX XXXX XXXX. The hotel robbed me of a peaceful recovery -- my doctors said repeatedly that they felt I caught XXXX due to the conditions there ; but also, that had I been anywhere else, I might not even have developed symptoms. The hotel was that physically stressful. \nMerchant put new guests, incl myself, into infected rooms without sanitation and engaged in numerous blatant CDC violations see https : XXXX. \nMerchant was billing me a pre-negotiated 'responder ' rate of $ XXXX/day, no tax. And had agreed that I owed nothing for XXXX, and that I would pursue with its owners XXXX XXXX XXXX XXXX XXXX settlement over its treatment, abuse, failure to protect. When merchant billed me {$130.00} XX/XX/XXXX and I rang the front desk to ask about it, they stated that was the entire amount owed. \nMerchant endangered, per CDC and prevailing global Covid19 insight and historical evidence this is a field of expertise for me, as XXXX XXXX XXXX XXXX Innovator of the Year and the XXXX  of XXXX of the top pending global anti-viral products : the entire DC XXXX XXXX  based on guests staying there, including Mayor XXXX  office, the White House, XXXX XXXX, XXXX and XXXX Airports, etc. And in XXXX if you remember, just XXXX XXXX at a hotel led immediately to XXXX infections and over XXXX deaths in that state. This merchants behavior was unconscionable. And could have killed me. And others.","date_sent_to_company":"2021-02-09T15:42:35.000Z","issue":"Problem with a lender or other company charging your account","sub_product":"Checking account","zip_code":"200XX","tags":null,"has_narrative":true,"complaint_id":"4111461","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"WELLS FARGO & COMPANY","date_received":"2021-02-02T20:20:31.000Z","state":"DC","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Transaction was not authorized"},"highlight":{"complaint_what_happened":["If you gave them your card once, they can <em>charge</em> it forever. \nThe <em>Unauthorized</em> amount of {$2600.00} was over 600 % higher than the prior authorized amount, of {$440.00} ; or for the most immediately <em>unauthorized</em> amount of {$130.00}, charged <em>without</em> my approval or advance bill / warning, on XX/XX/XXXX. \nI never signed or authorized in writing a <em>recurring</em>, pre-authorized transaction, per REG-E."]},"sort":[11.430606,"4111461"]},{"_index":"complaint-public-v1","_id":"13089719","_score":7.8648396,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"I am filing this formal complaint against the three nationwide credit bureaus TransUnion, for willful and repeated violations of federal consumer protection laws, including the Fair Credit Reporting Act ( FCRA ) and the Fair Debt Collection Practices Act ( FDCPA ). Despite my numerous disputes, the Bureaus removed certain fraudulent accounts from my credit reports only to unlawfully reinsert them without proper verification or notice. This conduct violates FCRAs reinsertion provisions ( 15 U.S.C. 1681i ( a ) ( 5 ) ( B ) ) which prohibit a credit reporting agency TRANSUNION from reinserting previously deleted information unless the furnisher certifies its accuracy and the CRA notifies the consumer within 5 business days. The Bureaus failed to meet these requirements. They also failed to ensure maximum possible accuracy of my reports ( FCRA 1681e ( b ) ), did not properly reinvestigate my disputes within 30 days ( FCRA 1681i ( a ) ( 1 ) ( A ) ), and ignored my requests for validation and verification in violation of both FCRA and FDCPA. In short, the transunion actions ( and inactions ) have allowed inaccurate, fraudulent accounts to persist and even reappear on my credit file, causing significant harm. \nXXXX. Background of Disputed Accounts I am a victim of identity theft, which I have documented through an FTC Identity Theft Report and police report ( copies provided to the Bureaus ). Unauthorized accounts and inquiries were added to my credit reports without my consent. I exercised my rights under FCRA and FDCPA to dispute these items and to request their validation : Fraudulent Accounts : XXXX CARD : XXXX that I never opened or authorized. After my initial disputes, some of these accounts were deleted as invalid. However, the transunion later reinserted XXXX CARD : XXXX without notifying me in writing within five days, as required by 15 U.S.C. 1681i ( a ) ( 5 ) ( B ) ( ii ). No certification of accuracy was provided to me upon reinsertion, indicating the process did not comply with the law. Reinserting previously removed debts without proper validation also implicates FDCPA 809 ( b ) ( 15 U.S.C. 1692g ( b ) ), since a debt collector must cease reporting a debt if it can not verify it. The Bureaus effectively allowed debt collectors to continue collection by credit reporting, even after disputes, without ever providing me verification. \nUnauthorized Inquiries : Numerous hard inquiries appeared on my reports from lenders I never applied to ( XXXX  XXXX ). This inquiry lack a permissible purpose under FCRA 604 ( 15 U.S.C. 1681b ) and should have been removed. Reporting inquiries without consent is illegal, yet the Bureaus did not delete them despite my disputes.\n\nIncorrect Personal Information : My credit file shows wrong names ( e.g., variations of my name I have never used ) and addresses in states Ive never lived. This indicates failure to assure maximum possible accuracy ( 15 U.S.C. 1681e ( b ) ) and potentially mixed-file issues. I requested correction or removal of this data, but the Bureaus have not fully complied. \nDespite sending formal dispute letters ( via certified mail ) to transunion including documentation of fraud ( identity theft reports, ID, proof of address ) the Bureaus either failed to respond in a timely manner or conducted perfunctory investigations that did not actually verify the debts. Notably, more than 30 days have passed since my disputes with no adequate verification provided ( violating FCRA 1681is 30-day limit and 1681i ( a ) ( 6 ) duty to report results ). They have also failed to block the fraudulent accounts after receiving my identity theft reports, contrary to FCRA 605B ( 15 U.S.C. 1681c-2 ( a ) ), which requires CRAs to block such information within 4 business days of receiving proof of identity theft.\n\nIII. Detailed Violations of Law The Bureaus actions ( and failures to act ) violate multiple provisions of federal law, as detailed below : FCRA 15 U.S.C. 1681i ( a ) ( 1 ) ( A ) Failure to conduct a reasonable reinvestigation within 30 days of my dispute. I notified the Bureaus of inaccuracies ; under FCRA they must reinvestigateor delete the item within 30 days of receiving the dispute. They did not complete proper investigations in this timeframe, nor did they delete all unverified information.\n\nFCRA 15 U.S.C. 1681i ( a ) ( 5 ) ( A ) Failure to delete inaccurate or unverified information. By law, if an item is inaccurate or the furnisher fails to verify it, the CRA must promptly delete or correct that item. Here, furnishers failed to verify the debts ( no contracts or signatures were produced ), yet the accounts remain or were reinserted.\n\nFCRA 15 U.S.C. 1681i ( a ) ( 5 ) ( B ) Unlawful reinsertion of previously deleted information without required certification and notice. Federal law prohibits a CRA from reinserting a deleted item unless the furnisher certifies its accuracy, and even then the CRA must notify the consumer within 5 business days of reinsertion with the furnishers contact details. The Bureaus put deleted fraudulent accounts back on my report without notifying me at all, which is an egregious FCRA violation. I only discovered the reappearance by checking my reports. This denied me the chance to dispute immediately or add a consumer statement, as is my right.\n\nFCRA 15 U.S.C. 1681e ( b ) Failure to maintain reasonable procedures to assure maximum possible accuracy. The recurring inaccurate information on my reports ( fraudulent account, incorrect personal data ) shows the Bureaus procedures are inadequate. In fact, the CFPB has noted that Experian lacked basic matching tools to prevent reinsertions by a new debt collector, causing consumers to see the same inaccurate information reappearwithout explanation under the name of a new furnisher. XXXX  was likewise found to have failed ] to prevent the improper reinsertion of previously deleted information in violation of FCRA. My experience mirrors these findings.\n\nFCRA 15 U.S.C. 1681c-2 ( a ) Failure to block information resulting from identity theft. I provided the Bureaus with an identity theft report identifying specific fraudulent accounts. Under FCRA 605B, a CRA must block those items from my credit file within four business days and notify the furnisher. Any subsequent attempt to reinsert or report that blocked info is unlawful. The Bureaus did not honor this mandatory block, as the accounts continued to report even after they had my theft report. Moreover, if a CRA declines or rescinds a block, it must notify the consumer within 5 days ( 15 U.S.C. 1681c-2 ( c ) ) ; I received no such notices. The CFPBs recent enforcement action against XXXX  confirms that failing to block identity theft accounts ( and failing to notify the consumer of any unblocking ) is a serious violation. \nFCRA 15 U.S.C. 1681i ( a ) ( 6 ) Failure to provide me the results of reinvestigation and verification details. I was entitled to a written notice of the investigation results within 5 business days of completion, including a revised credit report and information on how it was verified or why it was unchanged. Instead, I either received no response or generic form letters that did not explain the outcome. The CFPB found Experian was sending consumers notices that fail to inform them of the investigation results and provided confusing or incorrect information, which is exactly what I experienced. I also requested method of verification details ( e.g. copies of any documents or contracts that prove I owe the debts ), which the Bureaus failed to supply violating FCRA 1681i ( a ) ( 6 ) ( B ) ( iii ) and 1681i ( a ) ( 7 ). \nFDCPA 15 U.S.C. 1692g ( a ) & ( b ) XXXX XXXX  : XXXX Failure of debt collectors to provide validation of the debts and ceasing collection. I notified the furnishers ( collection agencies ) that these accounts were fraudulent and requested validation under FDCPA. Debt collectors must send verification of the debt and original creditor upon request ( and initially advise me of this right ) per 1692g ( a ) ( 4 ) - ( 5 ). None of the collectors provided valid documentation. Moreover, once I disputed and sought validation, they should cease collection activities until providing proof ( 1692g ( b ) ). Reporting a debt to a CRA is considered a collection activity ; by continuing to report or re-report these accounts without validation, the collectors violated FDCPA. Thus, the Bureaus by extension are reporting debts that are legally unvalidated and uncollectible. \nFDCPA 15 U.S.C. 1692e ( 8 ) Communication of false credit information by debt collectors. If a debt is disputed or is the result of identity theft, a collector must mark it as disputed in any reporting. If any collector re-reported the debt under a different account or failed to note my dispute, that is a false representation of the debts status. The reinserted tradelines appeared under new account numbers/names, giving the impression of a new debt. This deceptive practice violates 1692e and 1692e ( 8 ). \nIn summary, the Bureaus have failed to follow the law at multiple steps of the process meant to protect consumers. Instead of performing legitimate investigations, they appear to rely on automated, perfunctory processes that parrot whatever their furnishers respond with, regardless of evidence. Notably, the National Consumer Law Center observes that credit bureaus often engage in sham dispute investigations, always deferring to the creditor or collector a practice called parroting. This bias undermines my rights under FCRAs dispute provisions and has occurred in my case.\n\nIV. Pattern of Non-Compliance CFPB Enforcement Evidence My experience is not isolated ; it reflects systemic problems that the CFPB and courts have recognized and acted upon. I cite the following recent enforcement actions and cases to underscore the severity of these violations and the need for CFPB intervention : CFPB Lawsuit against XXXX  ( XX/XX/XXXX ) : The CFPB sued XXXX  for failing to properly investigate consumer disputes and for reinserting errors on credit reports. The Bureau alleges XXXX  conducted sham investigations and routinely ignored evidence submitted by consumers. Instead of fixing errors, XXXX  allowed deleted inaccuracies to reappear under different furnishers, harming consumers credit access. CFPB XXXX XXXX XXXX noted this misconduct can have serious consequences and that credit reporting giants must follow the law This lawsuit seeks to halt XXXX  unlawful practices and impose penalties. My case involves the very same practices poor dispute handling and improper reinsertion now under CFPB litigation. \nXXXX Settlement with TransUnion ( XX/XX/XXXX ) : TransUnion and a subsidiary agreed to pay {$15.00} XXXX to settle charges of failing to ensure report accuracy. In that case ( involving tenant screening reports ), TransUnion failed to remove inaccurate or incomplete records, which hurt consumers ability to obtain housing. While focused on tenant data, the settlement highlights the Bureaus obligations under FCRAs maximum possible accuracy standard. It shows regulators will impose multi-million dollar penalties when CRAs allow faulty data to remain, reinforcing that the issues in my complaint rise to the level of enforcement. \nCFPB Action against XXXX  ( XX/XX/XXXX ) : The CFPB issued an order against XXXX  for widespread FCRA violations in its dispute handling processes. The Bureau found XXXX  failed to properly conduct reinvestigations, failed to prevent improper reinsertions, and failed to block information resulting from identity theft, among other violations. XXXX  also neglected to send consumers adequate results of investigations. XXXX  was ordered to pay a {$15.00} XXXX civil penalty and fix its procedures. According to XXXX, XXXX  ignored consumer documents and evidence, allowed previously flagged inaccuracies to return to credit reports. This is precisely what I have endured across all three Bureaus. The CFPBs action against XXXX  underscores that reinsertion of disputed data and ignoring identity theft claims are unlawful and punishable. My complaint seeks similar scrutiny and relief with respect to XXXX, XXXX, and TransUnions conduct in my case. \nCase Law : Courts have long interpreted the FCRA to require meaningful dispute investigations by CRAs, not just automated formality. In XXXX XXXX XXXX XXXX XXXXXXXX, the Third Circuit held that a CRA must go beyond the original source [ the creditor ] and can not simply rely on whatever the furnisher says if that approach yields no resolution doing so would violate the FCRAs reinvestigation duty ( XXXX XXXX XXXX, XXXX ( XXXX XXXX. XXXX ) ). Similarly, in XXXX XXXX XXXX, XXXX, XXXX XXXX XXXX ( XXXX XXXXXXXX XXXXXXXX ), the XXXX XXXX emphasized that furnishers of information ( and by extension CRAs ) have a responsibility to investigate and correct disputed information, especially when there are indicia of identity theft or fraud. These cases support that the Bureaus cursory handling of my disputes effectively rubber-stamping the erroneous information falls short of FCRAs requirements and exposes them to liability. Moreover, failure to notify a consumer of reinsertion has been found to violate the FCRA and supports damages ; e.g., XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX. XXXX XXXX ( XXXX XXXX XXXX ) ( CRAs lack of notice of reinsertion was a breach of FCRA 1681i ). In sum, there is ample legal precedent that the Bureaus actions are illegal and harmful. \nXXXX Impact on Consumer ( Harm Caused ) Due to these violations, I have suffered serious negative consequences : my credit score plummeted because of the reinserted bogus accounts and numerous hard inquiries. I have been denied credit and faced higher interest rates on loans. The stress of dealing with identity theft was exacerbated by the Bureaus failure to correct the record. Ive spent countless hours sending disputes, making phone calls, and seeking relief, to little avail. These inaccuracies also jeopardize opportunities for employment and housing ( since many employers and landlords check credit ). The continued presence of fraudulent debt on my reports is a constant source of anxiety and constitutes ongoing damage to my reputation and finances. All of this harm is directly attributable to the Bureaus non-compliance with consumer protection laws. \nVI. Relief Requested I respectfully request the CFPBs assistance to enforce the law and obtain the following relief : Immediate Deletion/Blocking of Fraudulent Data : The CFPB should compel XXXX, TransUnion, and XXXX  to permanently delete all fraudulent accounts and inquiries from my credit files across all bureaus. In addition, any information identified in my identity theft report must be blocked from reappearing, per 15 U.S.C. 1681c-2. This includes the specific accounts I have disputed ( detailed in my correspondence with the Bureaus ) and any related listings by different collection agencies. The bureaus must ensure these items do not reinsert under any name or form unless strict FCRA prerequisites are met.\n\nCompliance Verification : The Bureaus should be required to provide written confirmation that the deletions and blocks have been implemented, along with updated copies of my credit reports showing a clean record. Furthermore, I request that the CFPB review the\nBureaus internal reinvestigation documentation for my disputes how they handled my dispute letters, whether they forwarded my evidence to furnishers, and how the improper reinsertions occurred. If they failed to forward my documents or made only cursory checks, that should be noted as part of enforcement ( as the CFPB has alleged happened in other cases ).\n\nInvestigation into Furnishers : I urge the CFPB to also consider enforcement against the furnishers ( creditors/debt collectors ) who supplied these fraudulent accounts. If a debt collector failed to conduct a reasonable investigation after notice of dispute from the CRA ( violating 15 U.S.C. 1681s-2 ( b ) ) or re-reported a debt without validating it to me ( violating FDCPA and potentially FCRA 1681s-2 ( a ) ( 8 ) ), they should be held accountable. The CFPBs Circular 2022-07 makes clear that regulators can take action against furnishers who do not properly investigate disputes. Such action will complement the relief in my individual case by addressing the source of the erroneous data.\n\nCivil Penalties and Consumer Redress : Given the willful nature of these violations the Bureaus were alerted multiple times and yet persisted maximum penalties are warranted. The CFPB should impose appropriate civil money penalties on each Bureau for these breaches ( consistent with recent fines : e.g. {$15.00} XXXX against XXXX  ). I also seek any available monetary relief for the harm Ive suffered, which the CFPB can facilitate through its complaint resolution process or enforcement action. Under FCRA, I have private rights to damages ( statutory, actual, and punitive under 15 U.S.C. 1681n, 1681o ), but I am first seeking resolution through the CFPBs intervention to hopefully avoid litigation.\n\nSystemic Reforms : Beyond my case, I ask the CFPB to mandate that the Bureaus review and fix their dispute handling systems : specifically, to stop any automated rejection of disputes without human investigation ( ensuring no dispute is improperly labeled frivolous without a valid reason and notice to the consumer ), to integrate fraud report information across all bureaus ( perhaps via the automated system required by FCRA 1681i ( a ) ( 5 ) ( D ) for sharing dispute results, and to implement the basic matching protocols that would prevent deleted items from sneaking back in under slightly different details. The goal is to force improvements so that no other consumer faces the same nightmare of recurring fraudulent entries.\n\nVII. Conclusion The facts demonstrate clear violations of federal law by, TransUnion, in concert with certain furnishers. The Bureau have ignored their duties under FCRA and FDCPA, even after multiple notices, to the severe detriment of my financial well-being. I urge the CFPB to use its authority to investigate this matter, ensure the fraudulent data is removed and blocked, and to take enforcement action as needed. The CFPBs own statements recognize that when companies fail to investigate disputed information, consumers are left paying higher costs and face greater difficulty in life. That is exactly my situation ; I am counting on CFPB to uphold my rights and restore the accuracy and integrity of my credit reports. \nThank you for your attention to this urgent complaint. I am available to provide any additional information or documentation needed. I have attached copies of relevant dispute letters, identity theft reports, and prior correspondence for your reference. \nSincerely, XXXX XXXX","date_sent_to_company":"2025-04-22T01:11:18.000Z","issue":"Problem with a company's investigation into an existing problem","sub_product":"Credit reporting","zip_code":"34746","tags":null,"has_narrative":true,"complaint_id":"13089719","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"TRANSUNION INTERMEDIATE HOLDINGS, INC.","date_received":"2025-04-22T00:24:04.000Z","state":"FL","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Their investigation did not fix an error on your report"},"highlight":{"complaint_what_happened":["The Bureaus effectively allowed debt collectors to continue collection by credit reporting, even after disputes, <em>without</em> ever providing me verification. \n<em>Unauthorized</em> Inquiries : Numerous hard inquiries appeared on my reports from lenders I never applied to ( XXXX  XXXX ). This inquiry lack a permissible purpose under FCRA 604 ( 15 U.S.C. 1681b ) and should <em>have</em> <em>been</em> removed. Reporting inquiries <em>without</em> consent is illegal, yet the Bureaus did not delete them despite my disputes."]},"sort":[7.8648396,"13089719"]},{"_index":"complaint-public-v1","_id":"12646259","_score":5.9042625,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXXXXXX XXXX XXXX XXXXXXXX XXXX XX/XX/XXXX To : Transunion Consumer Financial Protection Bureau ( CFPB ) Federal Trade Commission ( FTC ) Securities and Exchange Commission ( SEC ) Federal Communications Commission ( FCC ) Office of the Comptroller of the Currency ( OCC ) National Association of Attorneys General ( NAAG ) U.S. Department of Justice ( DOJ ) Civil Division DOJ Consumer Protection Branch ( CPB ) RE : Request for Immediate Federal and Multi-State Enforcement Against TransUnion for Systemic Violations of Federal and State Consumer Protection Laws and Obstruction of FCRA Rights I am submitting this formal enforcement referral regarding TransUnion for violating federal and state consumer protection statutes through fraudulent suppression of disputes, evasion of regulatory timelines, failure to properly process consumer dispute claims, and provision of deceptive and misleading responsesall in violation of their statutory obligations under the Fair Credit Reporting Act ( FCRA ), Consumer Financial Protection Act ( CFPA ), and corresponding D.C., Pennsylvania, Illinois, and New York consumer protection laws.\n\nThis referral is supported by an attached, sworn and notarized Affidavit of Truth ( AOT ), which affirms under penalty of perjury the factual accuracy of the allegations and evidentiary timeline presented, and by a formal Federal Trade Commission ( FTC ) Fraud Report, filed to document TransUnions systemic deception and noncompliance under 15 U.S.C. 45. These documents are included to establish factual basis, sworn attestation, and prior regulatory notification. \nAlso attached are letters, received from TransUnion on XX/XX/XXXX in the same envelope, labeled here as XXXX and XXXX, serve as critical evidence of ongoing violations. \nTransUnions Deliberate Failure to Link Communications to Specific Disputes Both Letter XXXX ( Re : Dispute Status ) and Letter XXXX ( Re : Explanation of the Inquiries on Your Credit Report ) were received by me on the same day in the same envelope but fail to identify which dispute or CFPB Complaint ID they address. This is not a clerical oversightit is a recurring practice that : 1. Obstructs consumer understanding of dispute outcomes under FCRA 1681i ( a ) ( 6 ) ( B ), which mandates that CRAs clearly disclose the results of each reinvestigation.\n\n2. Denies procedural transparency by omitting essential identifiers such as : o Dispute subject ( e.g., creditor name or inquiry source ), o Filing date, o Outcome reasoning, o Reinsertion notifications or suppression confirmations.\n\nBy sending generic, ambiguous letters disconnected from any specific complaint, TransUnion has : Frustrated regulatory oversight by making it impossible for agencies like the CFPB to trace outcomes back to specific complaints. \nCompromised consumer recordkeeping, which is essential to maintaining accountability and exercising legal remedies. \nConstructively evaded enforcement by preventing both consumers and regulators from matching TransUnions responses to statutory timelines or legal obligations under pending complaints.\n\nThis lack of linkage directly violates : FCRA 1681i ( a ) ( 7 ) : Failure to describe the procedure used for each reinvestigation.\n\n15 U.S.C. 45 : As a deceptive business practice that creates the illusion of compliance without actual transparency.\n\nState-level statutory requirements in D.C., Pennsylvania, Illinois, and New York , all of which recognize misrepresentation and omission as violations of consumer protection laws.\n\nThis is especially egregious given that I currently have four active CFPB complaints pending against TransUnion : XXXX ( submitted XX/XX/XXXX ) XXXX ( submitted XX/XX/XXXX ) XXXX ( submitted XX/XX/XXXX ) XXXX ( submitted XX/XX/XXXX ) Their responses reflect no effort to identify which, if any, of those complaints they purport to resolvedespite statutory obligations and federal mandates requiring such disclosures in dispute communications. \nAccordingly, I request that this pattern be investigated as a systemic obstruction of due process and be treated as an aggravating factor in any penalties, injunctive relief, or criminal referrals imposed by your offices. \nBreakdown of TransUnion 's Letters and Conduct Letter XXXX : \" Re : Dispute Status '' TransUnion asserts that an item I disputed does not currently appear on my credit report and offers no additional details as to : What item was under review.\n\nWhether any investigation took place. \nWhether the item was previously present, deleted, or never existed.\n\nNo dispute summary, reinvestigation process, or conclusion was disclosed, despite this being required by law.\n\nViolations : 1. FCRA 1681i ( a ) ( 6 ) ( B ) : TransUnion failed to clearly communicate the results of the reinvestigation. The response is conclusory, vague, and materially omits the substance of the outcome.\n\n2. FCRA 1681i ( a ) ( 7 ) : TransUnion failed to provide a description of the procedure used to investigate the dispute.\n\n3. 15 U.S.C. 45 ( FTC Act ) : The response constitutes a deceptive business practice, creating the illusion of compliance while omitting material facts.\n\n4. D.C. CPPA 28-3904 ( f ) & ( e ) : This conduct involves material omissions and misrepresentations about the status and handling of a consumer complaint.\n\n5. Pennsylvania Unfair Trade Practices and Consumer Protection Law, 73 P.S. 201-2 ( 4 ) ( v ), ( xxi ) : Misleading or deceptive conduct likely to confuse a reasonable consumer about their rights or TransUnion 's obligations.\n\n6. Illinois Consumer Fraud and Deceptive Business Practices Act, 815 ILCS 505/2 : TransUnion engaged in unfair and deceptive conduct by failing to properly identify what was being investigated.\n\n7. New York General Business Law 349 : TransUnions failure to disclose dispute findings misleads consumers regarding their credit records and legal rights. \nLetter XXXX : \" Re : Explanation of the Inquiries on Your Credit Report '' TransUnion defended the presence of inquiries based on permissible purpose under FCRA, without identifying the creditor, account, inquiry date, or the basis for assuming authorization. This is a generic form response without tailoring or acknowledgment of the specific dispute submitted.\n\nNotably, TransUnion refused to investigate the inquiry, despite having received a formal dispute that challenged an inquirys legitimacy, see CFPB Complaint ID XXXX. \nViolations : 1. FCRA 1681i ( a ) ( 1 ) : Failure to conduct a reasonable reinvestigation into disputed inquiries.\n\n2. FCRA 1681i ( a ) ( 2 ) : Failure to forward all relevant information about the dispute to the furnisher of the inquiry.\n\n3. FCRA 1681c-2 ( a ) : Failure to block information resulting from fraud, where identity misattribution was raised.\n\n4. FCRA 1681e ( b ) : Failure to ensure maximum possible accuracy where the source or legitimacy of inquiries remains unclear or contested.\n\n5. D.C. CPPA 28-3904 ( f ) & ( e ) : Misrepresenting rights related to dispute of inquiries and permissible purpose.\n\n6. Pennsylvania 73 P.S. 201-2 ( 4 ) ( v ), ( xxi ) : TransUnions refusal to investigate potential unauthorized inquiries constitutes deceptive conduct.\n\n7. Illinois 815 ILCS 505/2 : Failure to explain the inquiry in context constitutes concealment and misrepresentation of consumer credit activity.\n\n8. New York GBL 349 : TransUnions refusal to properly handle a dispute concerning inquiries misrepresents the consumers right to challenge inaccuracies.\n\nLegal Basis for Enforcement Federal Statutory Violations : FCRA 1681i ( a ) ( 1 ), ( 2 ), ( 6 ), ( 7 ), 1681e ( b ), 1681c-2 ( a ) 15 U.S.C. 1681n ( willful noncompliance ), 1681o ( negligent noncompliance ) 15 U.S.C. 45 ( unfair and deceptive acts and practices under the FTC Act ) Criminal Conduct Warranting DOJ Review : 18 U.S.C. 1001 : False statements or material omissions in regulatory disclosures.\n\n18 U.S.C. 1343 ( Wire Fraud ) : Communications made with intent to defraud through omissions or deceptive resolution letters.\n\n18 U.S.C. 1962 ( RICO ) : Pattern of deceptive conduct and evasion of lawful regulatory process with commercial gain.\n\nPattern of Evasion, Misrepresentation, and Systemic Risk TransUnions conduct reflects more than isolated oversightit reveals a deliberate and coordinated pattern of regulatory evasion, legal misdirection, and procedural suppression of consumer rights. The companys repeated failure to provide dispute results that are linked, transparent, or complete represents not only noncompliance with statutory mandates, but an intentional effort to frustrate consumer remedies and obstruct regulatory scrutiny. \nBy sending vague, unlinked letters in response to active legal complaintseach omitting dispute identifiers, outcomes, or investigation detailsTransUnion is : Creating the false appearance of compliance while actively circumventing FCRA and CFPA procedural obligations.\n\nAvoiding accountability by denying consumers and regulators the ability to audit or verify whether statutory timelines and investigation duties were met.\n\nSuppressing dispute clarity in a way that weakens the CFPBs ability to monitor patterns across complaints and undermines multi-agency oversight.\n\nThis behavior is not unique to a single incidentit has emerged across multiple complaints, through multiple letters, involving distinct issues such as inquiry legitimacy, personal information suppression, and permissible purpose disputes. When paired with sworn documentation ( Affidavit of Truth ), an FTC fraud report, and active CFPB complaints, this reveals a structure of willful obstruction and legal misrepresentation that can not be resolved through informal channels alone. \nGiven the volume of unresolved complaints, the absence of meaningful engagement, and the critical role TransUnion plays in the national financial infrastructure, these violations expose both consumers and institutions to systemic risk. Enforcement is not merely appropriateit is required to preserve the integrity of the credit reporting system.\n\nPrior Enforcement History and Regulatory Pattern TransUnions current conduct can not be viewed in isolation. In 2017, the Consumer Financial Protection Bureau issued a Consent Order against TransUnion for engaging in deceptive marketing practices and misrepresentations about the usefulness and cost of credit scores and reports. That action resulted in {$13.00} million in restitution and a {$3.00} million civil penalty. More recently, TransUnion has also faced repeated scrutiny for its handling of disputes, failure to maintain accurate consumer information, and use of evasive communications to avoid accountability.\n\nThe pattern of conduct I am reportinggeneric responses, failure to tie dispute outcomes to specific CFPB complaint IDs, suppression of reinvestigation detail, and misrepresentation of permissible purposeis not new. It reflects a continued and willful disregard for statutory compliance, even after having been placed under consent decree and federal supervision. \nGiven this history, I respectfully request that regulators treat this matter as part of an ongoing systemic noncompliance pattern, and not as a one-off violation. Enforcement actions should reflect that TransUnion has had ample opportunity to correct its processes and has instead doubled down on opaque, deceptive, and obstructive tactics.\n\nSupporting Case Law The following federal appellate and district court decisions reinforce the legal arguments presented above and confirm that the conduct exhibited by TransUnionranging from failure to reinvestigate to deceptive dispute communicationshas been previously adjudicated as unlawful under the FCRA. These cases establish binding and persuasive precedent that : 1. Willful and negligent violations of the FCRA carry statutory and compensatory liability ; 2. Reinvestigations must be meaningful, not perfunctory ; and 3. Patterned noncompliance and vague responses constitute actionable failures that expose CRAs to enforcement and judicial remedy.\n\nEach case cited below illustrates the legal threshold for compliance and underscores how TransUnions actions meet or exceed the level of misconduct required to justify regulatory and judicial intervention. \nXXXX. XXXX XXXX. XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) Willful FCRA violations include reckless disregard for legal duties. \nXXXX. XXXX XXXX Trans Union XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) Reinvestigation must go beyond parroting the furnishers response. \nXXXX. XXXX XXXX XXXX, XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) Negligent or minimal FCRA reinvestigation procedures result in liability. \nXXXX. XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) CRA must ensure accuracy under 1681e ( b ). \nXXXX. XXXX v. Trans Union XXXX XXXX. XXXX, XXXX XXXX XXXX ( XXXX Cir. XXXX ) Pattern of inaccuracies supports systemic noncompliance. \nXXXX. XXXX v. XXXX XXXX. XXXX, XXXX XXXX XXXX XXXX XXXX ( C.D. XXXX. XXXX XXXX, XXXX ) Failure to block disputed data under FCRA 1681c-2 ( a ) was actionable. \nXXXX. XXXX v. XXXX, XXXX XXXX XXXX ( XXXX. XXXX XX/XX/XXXX ) Vague or generic response letters violate reinvestigation obligations.\n\nRequest for Immediate Action Based on the conduct described in TransUnions letters and its failure to meet its legal obligations under federal and state law, I request the following : 1. A m\nulti-agency investigation into TransUnions systemic FCRA and CFPA violations.\n\n2. Civil monetary penalties and injunctive relief imposed under the CFPBs UDAAP authority and the FTC Act.\n\n3. Referral to DOJ for potential criminal charges under 18 U.S.C. 1001 and 18 U.S.C. 1343 based on deceptive regulatory correspondence.\n\n4. State Attorney General coordination through NAAG to evaluate violations under D.C., PA, IL, and NY consumer protection statutes.\n\n5. Review by the SEC regarding TransUnions public disclosures and risk reports, in light of growing FCRA liabilities.\n\n6. FCC inquiry into misuse of consumer data across communication channels, particularly if auto-dispute responses originate from third-party integrations.\n\n7. An order compelling TransUnion to lawfully fulfill its statutory obligations under the Fair Credit Reporting Act and Consumer Financial Protection Act by issuing complete, timely, and specific responses to my currently open CFPB complaints : XXXX ( submitted XX/XX/XXXX ), XXXX ( submitted XX/XX/XXXX ), XXXX ( submitted XX/XX/XXXX ), XXXX0 ( submitted XXXX XXXX XXXX ), This includes : i ) Identification of each disputed item, ii ) A clear statement of the outcome, iii ) A description of the reinvestigation procedures used, and iv ) Delivery of these results within the mandated statutory timeframe.\n\n( a ) TransUnions failure to do so constitutes an ongoing violation of FCRA 1681i ( a ) ( 6 ) ( B ) and 1681i ( a ) ( 7 ), and further obstructs regulatory review by the CFPB and other oversight bodies.\n\nI am prepared to submit additional documentation, sworn statements, and certified dispute filings supporting each claim described herein. I am also willing to cooperate with any federal or state agency conducting further review. \nRespectfully, XXXX XXXX XXXX Attachments : Sworn and Notarized Affidavit of Truth FTC Fraud Report : XXXX","date_sent_to_company":"2025-03-24T09:14:23.000Z","issue":"Problem with a company's investigation into an existing problem","sub_product":"Credit reporting","zip_code":"20008","tags":null,"has_narrative":true,"complaint_id":"12646259","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"TRANSUNION INTERMEDIATE HOLDINGS, INC.","date_received":"2025-03-24T09:10:32.000Z","state":"DC","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Was not notified of investigation status or results"},"highlight":{"complaint_what_happened":["It reflects a continued and willful disregard for statutory compliance, even after <em>having</em> <em>been</em> placed under consent decree and federal supervision. \nGiven this history, I respectfully request that regulators treat this matter as part of an ongoing systemic noncompliance pattern, and not as a one-off violation. Enforcement actions should reflect that TransUnion has had ample opportunity to correct its <em>processes</em> and has instead doubled down on opaque, deceptive, and obstructive tactics."]},"sort":[5.9042625,"12646259"]}]},"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":"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":"Checking or savings account","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Checking account","doc_count":1}]}},{"key":"Credit 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