Case 2, Round II, beginning May, 2003

1. 5/22: Consumer obtains TransUnion file from another source.
   
2. 5/27: Consumer obtains file from TransUnion.
   
3. File obtained directly from TransUnion contains fewer dates of late payments than file from the other source.

4. 6/13: Consumer demands that TransUnion send a complete report.
   
5. 7/2: TransUnion sends a report with less information than before.
   
6. Report from another source shows that the information is now gone. TransUnion's game is to remove the information from its file rather than provide the full disclosure as required by law.
   

Case 2, Round I

• 1/11/03 - Illustration using two actual TransUnion reports:
  1. The $9.00 (mailed) disclosure (required, by law, to show all information in the consumer's file, yet, it does not)
  2. $12.95 (illegal to require consumers to pay more than $9.00 to get all the information) disclosure which gives more information than the $9.00 disclosure (dates of delinquency)
• 01/10/2003 FTC online complaint form response: "If you believe that the FCRA has been violated, we suggest that you consult a private attorney or a local legal services organization." (html)
• 01/08/03 FTC online complaint confirmation
• 01/07/03 letter to the chairman of the Federal Trade Commission (the federal regulator of credit reporting companies)(copies to all FTC commissioners, five FTC staff members, a journalist, a consumer advocate, two members of the U.S. House, and a U.S. Senator): "Force consumer reporting agency TransUnion to disclose to the consumer all information in the consumer’s file... See http://creditaccuracy.com/0002.htm for proof that TransUnion does not comply with the Fair Credit Reporting Act in that regard." (scan)(html)
• 12/02/02 letter to TransUnion consumer relations investigator: "You gave others information that you hid from me, and to obtain it, I had to pay more than the $9.00 prescribed by the U.S. Congress to obtain all information in my file... You did not answer this question from my last letter: What is your supervisor’s name and mailing address? Answer that question. My dispute with you, on your level, is unresolved: My credit reports are still incomplete." (scan)(html)
• 10/08/02 letter from TransUnion: "Please be informed that at this time NACLVD/GLHEC... is no longer being reported to our database." (scan)(html)
• 9/13/02 letter to TransUnion consumer relations investigator: "What is your supervisor's name and mailing address?" (scan)(html)
• 8/23/02 bizarre, desperate letter from TransUnion: Failed to provide a complete disclosure. "Additionally, in response to your concern regarding the 'pay pattern 1-12 and pay pattern 13-24,' this is generated by how many months the account has been reviewed by the creditor." (?)(???!) (scan)(html)
• 7/22/02 letter to TransUnion president: "Other companies gave me-- and others-- information in my TransUnion file that you failed to give me... What are you going to do to make your consumer disclosures complete?" (scan)(html)(confirmation of receipt of certified mail, article number 7001 2510 0007 1255 9616)
• TransUnion document that defines the missing information and proves the case (download it to your hard drive-- it may not exist tomorrow and witnesses may be necessary)

  From the page titled "TransUnion Credit Report Fields":

  PAYPAT: The subject’s payment pattern, which is his/her actual rating, or Manner of Payment, over a period of time. Depending on which option a customer chooses, either 24 months or 12 months of information will be shown. The default setting is 24 months. The first position on the left of the first row corresponds to the account status of the previously reported month. This will not correspond to the MOP field, which represents the most recently reported account status, usually the current month. Each subsequent field to the right corresponds to one month further back in time. In the first example, the first half of the PAYPAT field is 445543211111. The first position indicates the information reported one month ago (MOP=4):

  One month ago—MOP = 4
  Two months ago—MOP = 4
  Three months ago—MOP = 5
  Four months ago—MOP = 5 Etc.

• 2001 exchange with TransUnion
• Online discussion
• Documents that show the reports TransUnion gives to lenders give information not included on consumer disclosures (below)
• Federal law requiring credit reporting agencies to disclose to the consumer "All information in the consumer's file at the time of the request... "

http://www.creditengine.net/mrg02.htm (clever html coding)
https://www.truecredit.com/products/merge/3-in-1CreditReportExample.jsp
http://www.confidentialcredit.com/CREDCO/faq/key11.asp
http://pev.frickco.com/hdocs/sample_full.html
http://credit.chapter7.com/tu/report.htm
http://www.e-verifile.com/everifile/batch_tu_credit.html
http://www.landlordprotect.com/examples/tuc.htm
http://www.sanface.com/pdf/MSEWEBdemo.pdf
http://www.informus.com/hdocs/samrpt.html#REF152_14_0
http://www.a2cb.com/credit/page4.html
http://www.tenantscreeningservices.com/transunion.html
http://www.preferredalliance.com/services/background/creditreport.doc

According to HSH Associates, a publisher of mortgage and consumer loan information, those with "A+" credit quality (no delinquency) get better rates than those with, for instance, "C-" credit quality. One of their definitions of C- is "Installment/Revolving" accounts 4-6 times late in the last 12 months (http://www.hsh.com/bcd-specs.html). So, the lender knows how many times the consumer was late in the past year because the lender's report gives that information. Trans Union's disclosures to consumers do not provide it.

"Every consumer reporting agency shall, upon request, and subject to section 1681h(a)(1) of this title, clearly and accurately disclose to the consumer:

(1)

All information in the consumer's file at the time of the request... "