Commonwealth Financial Systems, Inc.
On December 15, 2023, the Bureau issued an order against Commonwealth Financial Systems, Inc. (Commonwealth), a Pennsylvania-based third-party debt collection company that collects past-due medical debts and furnishes information about consumers to consumer reporting agencies (CRAs). The Bureau found that Commonwealth violated the Fair Credit Reporting Act and its implementing Regulation V by failing to establish and implement reasonable written policies and procedures regarding the accuracy and integrity of information it furnishes to CRAs; failing to conduct reasonable investigations of consumer disputes about information Commonwealth furnished to CRAs; failing to report the results of direct dispute investigations to consumers; and furnishing information to CRAs without notifying the CRA that the information was disputed. The Bureau also found that Commonwealth violated the Fair Debt Collection Practices Act by sending debt collection letters to consumers before providing the consumer a verification of the debt when Commonwealth had received a written dispute from the consumer within 30 days of the consumer’s receipt of a debt validation notice; misrepresenting to consumers that they owed alleged debts in certain circumstances when Commonwealth lacked a reasonable basis to make those representations; and communicating credit information about alleged debts to CRAs but failing to communicate that the debts were disputed. Among other injunctive relief, the order permanently bans Commonwealth from participating in or assisting others in any debt collection activities, debt buying, debt selling, and consumer reporting activities and requires Commonwealth to submit to all CRAs to whom it previously furnished information about any consumer a request to delete all collection accounts for such consumers. The order also requires Commonwealth to pay a $95,000 civil money penalty.