Colorado AG and CFPB Complaint Pack

COLORADO AG AND CFPB COMPLAINT PACK

TABLE OF CONTENTS

1. Section A — Colorado Attorney General Consumer Complaint
2. Section B — Consumer Financial Protection Bureau Complaint
3. Section C — Supplementary Filings (FTC, FCC, BBB)
4. Section D — Document Inventory
5. Colorado Practice Notes
6. Sources and References

1. SECTION A — COLORADO ATTORNEY GENERAL CONSUMER COMPLAINT

A.1. Submission Information

A.2. Complainant (Consumer) Information

Name: [FULL LEGAL NAME]

Address: [STREET], [CITY], Colorado [ZIP]

Telephone: [NUMBER] Email: [EMAIL]

Preferred contact method: ☐ Email ☐ Phone ☐ Mail

Are you represented by counsel? ☐ Yes ☐ No

If yes, Attorney name: [___], Bar No.: [___], Phone: [___].

A.3. Respondent (Business) Information

Business name: [___]

DBA / trade name(s): [___]

Street address: [___]

Telephone: [___] Website: [___]

Industry: ☐ Debt collection ☐ Credit reporting ☐ Lending ☐ Auto sales ☐ Home improvement ☐ Telecom ☐ Healthcare billing ☐ Online retailer ☐ Other: [___]

Colorado license/registration (if any): [___]

Have you previously filed a complaint against this business? ☐ Yes ☐ No

A.4. Transaction Information

Date(s) of transaction or violation: [__/__/____] to [__/__/____]

Amount in dispute: $[___]

How was the transaction initiated? ☐ In person ☐ Online ☐ Phone ☐ Mail ☐ Door-to-door ☐ Other: [___]

Method of payment: ☐ Credit card ☐ Debit ☐ Bank draft ☐ Cash ☐ Check ☐ Wire ☐ Crypto ☐ Other: [___]

A.5. Statement of Facts

1. On [__/__/____], I [describe how you first encountered the business — advertisement, cold call, in-store visit, online listing].

2. The business represented that [describe representations made].

3. I relied on those representations and [describe action taken — signed contract, paid deposit, provided information].

4. After the transaction, [describe what happened — non-delivery, hidden fees, harassment, unauthorized charges, deceptive billing].

5. I attempted to resolve the matter directly by [describe — calls on dates, letters, return visits]. The business [response or lack thereof].

6. The business's conduct appears to be standardized and applied to other Colorado consumers based on [describe basis — similar online reviews, BBB reports, news coverage].

7. As a result, I have suffered the following injuries:

• ☐ Out-of-pocket loss of $[___];
• ☐ Damage to credit file;
• ☐ Time lost: approximately [___] hours;
• ☐ Emotional distress;
• ☐ Other: [___].

A.6. Identification of Conduct (Check All That Apply)

The conduct described above appears to violate the Colorado Consumer Protection Act, C.R.S. § 6-1-105:

• ☐ Knowingly making false representations about goods, services, or property (§ 6-1-105(1)(e));
• ☐ Representing that goods/services have characteristics they do not have (§ 6-1-105(1)(g));
• ☐ Failing to disclose material information with intent to induce (§ 6-1-105(1)(u));
• ☐ Bait advertising (§ 6-1-105(1)(i));
• ☐ Deceptive pricing (§ 6-1-105(1)(l));
• ☐ Unconscionable contract terms;
• ☐ Violations of the Colorado Fair Debt Collection Practices Act, C.R.S. § 5-16-101 et seq.;
• ☐ Violations of Colorado data-breach notification law, C.R.S. § 6-1-716;
• ☐ Violations of Colorado Charitable Solicitations Act, Lemon Law, or other Title 6 statutes (specify): [___].

A.7. Resolution Sought

I respectfully request the following relief:

• ☐ Investigation by the Colorado Attorney General's Consumer Protection Section;
• ☐ Cease-and-desist directive against the business;
• ☐ Restitution and refund of $[___];
• ☐ Civil penalties under C.R.S. § 6-1-112 ($20,000 per violation; $50,000 if directed at an elderly person);
• ☐ Removal of negative credit reporting;
• ☐ Public consumer alert; and
• ☐ Such other and further relief as appropriate.

A.8. Authorization and Verification

I hereby authorize the Colorado Attorney General to share this complaint and supporting documents with the business identified above, with other federal and state regulators, and with any law-enforcement agency for the purpose of investigation. I declare under penalty of perjury under the laws of the State of Colorado that the foregoing is true and correct to the best of my knowledge.

[________________________________] Date: [__/__/____]

[COMPLAINANT NAME]

Submission addresses:

• Online: https://coag.gov/file-complaint or https://www.stopfraudcolorado.gov
• Mail: Colorado Attorney General — Consumer Protection Section, Ralph L. Carr Colorado Judicial Center, 1300 Broadway, 7th Floor, Denver, CO 80203
• Phone (intake): (720) 508-6000 / 1-800-222-4444

2. SECTION B — CONSUMER FINANCIAL PROTECTION BUREAU COMPLAINT

B.1. Product / Issue Selection

Primary product (select one):

• ☐ Debt collection
• ☐ Credit reporting / credit repair / other personal consumer reports
• ☐ Mortgage
• ☐ Credit card or prepaid card
• ☐ Bank account or service
• ☐ Vehicle loan or lease
• ☐ Student loan
• ☐ Payday loan, title loan, personal loan, or installment loan
• ☐ Money transfer, virtual currency, or money service
• ☐ Other financial service

Specific issue: [___]

B.2. What Happened (Narrative)

[Insert chronological narrative consistent with Section A.5 above. Identify dates, amounts, account numbers, and the federal consumer-financial laws implicated, e.g., FDCPA, FCRA, RESPA, TILA, ECOA, EFTA, CFPA Sections 1031/1036 (UDAAP).]

B.3. Resolution Sought

• ☐ Refund or credit of $[___];
• ☐ Correction of credit report;
• ☐ Cessation of unlawful debt-collection conduct;
• ☐ Loan modification / payment plan;
• ☐ Account closure;
• ☐ Apology and explanation;
• ☐ Other: [___].

B.4. Consent and Authorization

• ☐ I consent to publication of my narrative (with personal info scrubbed) on the CFPB Consumer Complaint Database.
• ☐ I authorize the CFPB to share this complaint with the company and with state and federal partners.

B.5. Submission

Online (preferred): https://www.consumerfinance.gov/complaint/

Phone: (855) 411-CFPB (2372); TTY/TDD: (855) 729-2372

Mail: Consumer Financial Protection Bureau, P.O. Box 27170, Washington, DC 20038

The CFPB will forward the complaint to the company and will require a response within 15 days. Most complaints close within 60 days.

3. SECTION C — SUPPLEMENTARY FILINGS (FTC, FCC, BBB)

C.1. Federal Trade Commission

For non-financial consumer matters (deceptive advertising, telemarketing fraud, identity theft, robocalls, scams):

• Online: https://reportfraud.ftc.gov
• Identity theft: https://www.identitytheft.gov

C.2. Federal Communications Commission

For unwanted robocalls, robotexts, and TCPA-related conduct:

• Online: https://consumercomplaints.fcc.gov

C.3. Colorado Better Business Bureau

For voluntary mediation and public record:

• Denver/Boulder: https://www.bbb.org/local-bbb/bbb-of-denverboulder
• Southern Colorado: https://www.bbb.org/local-bbb/bbb-of-southern-colorado

C.4. State Sector Regulators (As Applicable)

4. SECTION D — DOCUMENT INVENTORY

Attach the following to each filing as appropriate (use the same exhibit numbers across all complaints to maintain a unified record):

• ☐ Exhibit 1 — Contract or terms of service
• ☐ Exhibit 2 — Billing statements, invoices, payment records
• ☐ Exhibit 3 — Written communications (emails, letters, text messages)
• ☐ Exhibit 4 — Call logs and transcripts (if recorded with one-party consent under C.R.S. § 18-9-303)
• ☐ Exhibit 5 — Advertisements, screenshots, and marketing material
• ☐ Exhibit 6 — Credit reports with disputed items circled
• ☐ Exhibit 7 — Police report and FTC identity-theft report (where applicable)
• ☐ Exhibit 8 — Photographs, video, or audio
• ☐ Exhibit 9 — Prior complaint correspondence and responses
• ☐ Exhibit 10 — Sworn affidavit of complainant

5. COLORADO PRACTICE NOTES

• Colorado AG enforcement scope. The Consumer Protection Section investigates and prosecutes violations of the CCPA, CFDCPA, Charitable Solicitations Act, Uniform Consumer Credit Code (UCCC), and other Title 5 and Title 6 statutes. The Section does not represent individual consumers and cannot recover restitution as a matter of right, but its enforcement actions often include consumer redress.
• Civil penalties. C.R.S. § 6-1-112 authorizes civil penalties up to $20,000 per violation, and up to $50,000 per violation directed at an elderly person (60+). C.R.S. § 6-1-101 et seq.
• Preservation of private rights. Filing an AG complaint does not toll the statute of limitations on private claims (FDCPA: 1 year; CCPA: 3 years). File a private suit on the calendar regardless of administrative status.
• CFPB authority. The CFPB regulates debt collectors, CRAs, mortgage servicers, payday lenders, student-loan servicers, and most consumer-financial institutions. CFPA Sections 1031/1036 prohibit unfair, deceptive, or abusive acts or practices (UDAAPs).
• Interaction with private litigation. Consumer complaint narratives published in the CFPB database may be admissible to show pattern and practice. Mark sensitive narratives carefully.
• AG referrals. The Colorado AG may refer matters to local district attorneys, the FTC, the CFPB, or to civil litigators in private practice through its Consumer Credit Unit.
• Stop Fraud Colorado. https://www.stopfraudcolorado.gov is the AG's public-facing portal and aggregates scam alerts. Sign up for alerts and consult the database before transacting with new businesses.
• Anti-retaliation. C.R.S. § 6-1-104.5 prohibits retaliation against consumers for filing complaints. Document any retaliatory conduct.

6. SOURCES AND REFERENCES

• Colorado AG, File a Complaint — https://coag.gov/file-complaint/
• Colorado AG, Consumer Protection Section — https://coag.gov/office-sections/consumer-protection/
• Stop Fraud Colorado — https://www.stopfraudcolorado.gov
• C.R.S. Title 6, Article 1 (CCPA) — https://leg.colorado.gov/sites/default/files/images/olls/crs2024-title-06.pdf
• C.R.S. § 6-1-105 (deceptive trade practices) — https://leg.colorado.gov/
• C.R.S. § 6-1-112 (civil penalties) — https://leg.colorado.gov/
• C.R.S. Title 5, Article 16 (CFDCPA) — https://leg.colorado.gov/sites/default/files/images/olls/crs2024-title-05.pdf
• CFPB, Submit a Complaint — https://www.consumerfinance.gov/complaint/
• CFPB, Consumer Complaint Database — https://www.consumerfinance.gov/data-research/consumer-complaints/
• FTC, ReportFraud.gov — https://reportfraud.ftc.gov
• FCC Consumer Complaints — https://consumercomplaints.fcc.gov
• DORA Colorado — https://dora.colorado.gov

Disclaimer: This template is provided for informational purposes only and does not constitute legal advice. An attorney licensed in Colorado should review filings before submission, particularly where civil litigation is contemplated, where representations could be used adversely, or where the underlying facts may implicate criminal liability.