Template #1: General Dispute of Securitized Debt to CRAs

Simply Royal

23d • Q&A Credit Repair

[Your Full Name]

[Your Street Address]

[City, State ZIP Code]

[Email Address]

[Phone Number]

[Today’s Date]

Via Certified Mail / Return Receipt Requested

To:

Experian

P.O. Box 4500

Allen, TX 75013

Equifax

P.O. Box 740256

Atlanta, GA 30374

TransUnion

P.O. Box 2000

Chester, PA 19016

RE: Formal Demand for Deletion of Unverified, Possibly Securitized Debt

Pursuant to FCRA, FDCPA, UCC, GLBA, and SEC Regulations

Dear Consumer Relations Department,

This letter serves as a formal dispute and litigation notice pursuant to the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq., and other federal statutes. I am disputing the validity and continued reporting of the following derogatory account(s) on my consumer report(s):

**Accounts in Dispute:**

[List Name of Creditor, Account Number (last 4 digits), and Account Type]

You are hereby notified that unless strict proof of ownership and non-securitization is provided, this reporting must be immediately removed. You are obligated by law to report with maximum possible accuracy and verify any disputed information under:

- FCRA, 15 U.S.C. §§ 1681e(b), 1681i, 1681s-2

- FDCPA, 15 U.S.C. § 1692e(8)

- UCC §§ 9-203 and 9-208

- Truth in Lending Act (TILA), 15 U.S.C. § 1601 et seq.

- Gramm-Leach-Bliley Act (GLBA), 15 U.S.C. § 6802

- Securities Act of 1933 / Securities Exchange Act of 1934

If the account was securitized, transferred into a Mortgage-Backed Security (MBS), Asset-Backed Security (ABS), Real Estate Mortgage Investment Conduit (REMIC), Special Purpose Vehicle (SPV), or pledged as collateral for credit derivatives, then any reporting party without direct ownership interest lacks standing to report or collect.

### Evidentiary Demands:

To lawfully continue reporting the account(s), you must provide the following within 30 days:

1. Full **chain of title**, showing all assignments, transfers, or sales of the alleged debt

2. A **sworn affidavit** stating the account was never sold into any MBS, ABS, REMIC, SPV, or similar vehicle

3. Proof that the **original creditor maintains enforceable rights** under UCC § 9-203

4. A **statement under penalty of perjury** confirming the furnisher is not merely a servicer or third-party collector

5. **Admissible documentation** under FRE 803(6), verifying authenticity of business records used for reporting

If you cannot furnish these items, you must delete the tradeline(s) immediately.

### Supporting Case Law:

- *Cushman v. Trans Union Corp.*, 115 F.3d 220 (3d Cir. 1997)

- *Richardson v. Fleet Bank*, 190 F. Supp. 2d 81 (D. Mass. 2001)

- *Dennis v. BEH-1, LLC*, 520 F.3d 1066 (9th Cir. 2008)

- *Jackson v. U.S. Bank Trust*, 245 F. Supp. 3d 653 (W.D. Ky. 2017)

- *Safeco Ins. Co. of Am. v. Burr*, 551 U.S. 47 (2007)

- *Dalton v. Capital Associated Indus.*, 257 F.3d 409 (4th Cir. 2001)

These rulings establish that failure to verify the ownership chain and securitization status constitutes a violation of federal law.

### Liability Notice:

If you continue to report the above accounts without strict verification:

- You may be held liable under 15 U.S.C. §§ 1681n and 1681o

- Willful concealment of securitization or title-chain issues may constitute mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), and conspiracy (18 U.S.C. § 371)

### Final Demand:

You have 30 days from receipt of this letter to either:

1. Provide the legally requested documentation above, or

2. Permanently remove the disputed account(s) from my credit report

If you fail to do so, I will pursue all legal remedies including filing complaints with the CFPB, FTC, and initiating litigation in federal court.

Sincerely,

[Your Full Name]

[Your Signature if mailing hard copy]

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