Wyoming AG and CFPB Consumer Complaint Pack

CONSUMER COMPLAINT PACK — WYOMING AG + CFPB + FEDERAL AGENCIES

TABLE OF CONTENTS

1. Part A — Wyoming Attorney General Complaint
2. Part B — CFPB Complaint Narrative
3. Part C — Federal Trade Commission Report
4. Part D — Sector-Specific Federal and Wyoming Agencies
5. Part E — Document Inventory and Routing Slip
6. Wyoming Practice Notes
7. Sources and References

1. PART A — WYOMING ATTORNEY GENERAL COMPLAINT

[CONSUMER NAME]

[STREET ADDRESS]

[CITY], Wyoming [ZIP]**

[PHONE]

[EMAIL]

Date: [__/__/____]

To: Wyoming Attorney General

Consumer Protection and Antitrust Unit

109 State Capitol

Cheyenne, WY 82002

Phone: (307) 777-6397 / (307) 777-8962

Fax: (307) 777-3435

Email: [email protected]

Online: https://attorneygeneral.wyo.gov/law-office-division/consumer-protection-and-antitrust-unit/consumer-complaints

Re: Consumer Complaint Against [BUSINESS / RESPONDENT NAME]

A.1. CONSUMER INFORMATION

A.2. RESPONDENT (BUSINESS) INFORMATION

A.3. TRANSACTION SUMMARY

A.4. STATEMENT OF FACTS

A.4.1. On or about [DATE], I [describe how the transaction or contact began].

A.4.2. [Continue with a chronological, fact-based narrative. Use short numbered paragraphs. Avoid argument or legal conclusions.]

A.4.3. [Identify the specific deceptive act or unfair practice — e.g., misrepresentation of source/origin/sponsorship; misrepresentation of standard/grade/style; bait-and-switch advertising; false price-reduction representations; misrepresentation of warranty terms; representing that replacement or repair is needed when it is not; advertising merchandise with no intent to sell as advertised. Tie each fact to a subsection of Wyo. Stat. § 40-12-105.]

A.4.4. As a result, I have suffered actual damages of $[AMOUNT].

A.4.5. I attempted to resolve the matter directly with [BUSINESS] by [describe — phone calls on dates, written demand on date]. The response was [describe].

A.5. RESOLUTION REQUESTED

I respectfully request that the Wyoming Attorney General's Consumer Protection and Antitrust Unit:

• ☐ Mediate this dispute and assist in obtaining a refund of $[AMOUNT];
• ☐ Investigate the business for possible violations of the Wyoming Consumer Protection Act, Wyo. Stat. §§ 40-12-101 through 40-12-114;
• ☐ Consider seeking an assurance of voluntary compliance under Wyo. Stat. § 40-12-107;
• ☐ Consider seeking injunctive relief and/or civil penalties under Wyo. Stat. §§ 40-12-106 and 40-12-113 if warranted;
• ☐ Coordinate with the CFPB / FTC / [OTHER AGENCY];
• ☐ Maintain this complaint in the agency record and Consumer Sentinel Network for pattern detection.

A.6. AUTHORIZATION AND CERTIFICATION

I authorize the Wyoming Attorney General's Office to (a) share this complaint and supporting documents with the named respondent; (b) share this complaint with other state and federal agencies; and (c) use this complaint in any administrative or judicial proceeding. I understand that complaints filed with the Wyoming AG may be subject to disclosure under the Wyoming Public Records Act, Wyo. Stat. §§ 16-4-201 through 16-4-205, and I have redacted sensitive personal identifiers (full SSN, full account numbers, government IDs) accordingly.

I certify that the foregoing statements are true and correct to the best of my knowledge.

[________________________________]

[CONSUMER NAME]

Date: [__/__/____]

A.7. ENCLOSURES

• ☐ Copy of contract or written agreement
• ☐ Copies of receipts, invoices, billing statements
• ☐ Copies of correspondence with the business (letters, emails, text messages)
• ☐ Copies of advertisements or website screenshots
• ☐ Copy of canceled check, credit-card statement, or bank record
• ☐ Copy of warranty or service agreement
• ☐ Copy of any pre-suit § 40-12-109 notice (if separately served)
• ☐ Other: [DESCRIBE]

2. PART B — CFPB COMPLAINT NARRATIVE

B.1. PRODUCT AND ISSUE SELECTION

When prompted by the CFPB portal, select the product and issue that most closely match the conduct:

• Debt collection — for FDCPA violations
• Credit reporting, credit repair services, or other personal consumer reports — for FCRA disputes
• Mortgage — for RESPA / loan-servicing complaints
• Credit card or prepaid card — for billing-error or rewards disputes
• Checking or savings account — for EFTA / Reg E disputes
• Vehicle loan or lease — for auto-finance complaints
• Payday loan, title loan, personal loan, or advance — for short-term lending
• Money transfer, virtual currency, or money service — for Reg E / cross-border transfer claims
• Student loan

B.2. CONSUMER STATEMENT — "WHAT HAPPENED?"

I, [CONSUMER NAME], a resident of [CITY], Wyoming, file this complaint against [RESPONDENT] for conduct that I believe violates [FDCPA / FCRA / TILA / RESPA / EFTA / UDAAP under 12 U.S.C. § 5536].

Background. [Describe the underlying account or transaction in 2-3 sentences.]

The conduct at issue. [Describe each violative act with dates, channel, and content. Use bullets where helpful.]

• On [DATE], the company [did X].
• On [DATE], the company [did Y].
• On [DATE], after I sent a written dispute, the company [did Z].

Harm. I have suffered [describe — out-of-pocket loss of $X, damaged credit, emotional distress, lost time] as a direct result of this conduct.

Resolution sought. I request that the company (a) [cease the conduct], (b) [correct the credit reporting / refund the disputed amount / provide validation / honor the contract], and (c) [provide a written explanation].

State law overlay. I have also filed a parallel complaint with the Wyoming Attorney General — Consumer Protection and Antitrust Unit, citing the Wyoming Consumer Protection Act, Wyo. Stat. §§ 40-12-101 through 40-12-114.

B.3. SUBMITTING ATTACHMENTS

The CFPB portal accepts up to 50 MB of attachments per complaint (PDF, JPG, PNG, DOCX). Redact full SSN, full account numbers, and government IDs before uploading; the CFPB shares attachments with the responding company.

B.4. EXPECTED TIMELINE

• Day 0: Consumer submits complaint.
• Day 1-15: CFPB forwards complaint to responding company.
• Day 15: Company should provide initial response.
• Day 60: Company should provide final response.
• Day 60+: Consumer may dispute the company's response and request additional review.

3. PART C — FEDERAL TRADE COMMISSION REPORT

C.1. WHEN TO USE

File an FTC report when the conduct involves:

• Telemarketing fraud, robocalls, or Do-Not-Call Registry violations
• Imposter scams (government, business, romance, tech support)
• Online shopping fraud
• False advertising or deceptive marketing under 15 U.S.C. § 45
• Pyramid schemes
• Identity theft (file at IdentityTheft.gov instead of reportfraud.ftc.gov)

C.2. INFORMATION TO INCLUDE

• The respondent's full business name, address, phone, and website
• The medium of contact (call, text, email, website, in-person)
• A short narrative of the scheme
• Loss amount and method of payment
• Whether you have already contacted the respondent

4. PART D — SECTOR-SPECIFIC FEDERAL AND WYOMING AGENCIES

5. PART E — DOCUMENT INVENTORY AND ROUTING SLIP

Mailing record (Wyoming AG).

• Sent: [__/__/____] via ☐ U.S. Certified Mail RRR ☐ Email ☐ Online portal
• Tracking / Reference No.: [________________________________]

CFPB submission.

• Submitted: [__/__/____] at https://www.consumerfinance.gov/complaint/
• CFPB Case No.: [________________________________]

FTC submission.

• Submitted: [__/__/____] at https://reportfraud.ftc.gov/ or https://www.identitytheft.gov/
• FTC Reference No.: [________________________________]

6. WYOMING PRACTICE NOTES

• Wyoming AG — Consumer Protection and Antitrust Unit role. The Unit mediates consumer complaints, issues consumer-protection guidance, and may bring civil enforcement actions under the WCPA. It does NOT represent individual consumers in court and cannot recover individual damages on a consumer's behalf. The Unit reviews and provides written responses to all properly filed complaints but expressly does not handle business-to-business disputes or landlord/tenant matters.
• AG investigative and enforcement authority. The Attorney General is the "enforcing authority" under Wyo. Stat. § 40-12-102(a)(vii). Wyo. Stat. § 40-12-106 authorizes the AG to bring an action to restrain unlawful practices by temporary restraining order or preliminary or permanent injunction. Wyo. Stat. § 40-12-107 authorizes the AG to accept written assurances of voluntary compliance. Wyo. Stat. § 40-12-113 authorizes civil penalties payable to the State for violations of injunctions or assurances (verify current penalty cap).
• Private right of action. Wyo. Stat. § 40-12-108(a) provides a private right of action to a consumer relying upon an "uncured" unlawful deceptive trade practice. The remedy is actual damages — there is NO treble, double, statutory-minimum, or punitive multiplier on the WCPA private right. Reasonable attorney fees are recoverable under Wyo. Stat. § 40-12-108(b) only in CLASS ACTIONS, computed by lodestar.
• WCPA scope is narrow. The WCPA reaches only the practices enumerated in Wyo. Stat. § 40-12-105 and only when committed knowingly and in connection with a "consumer transaction" as defined by Wyo. Stat. § 40-12-102(a)(ii). Wyoming courts have construed the statute restrictively. Tie any WCPA theory to a specific subsection of § 40-12-105.
• Pre-suit notice (CRITICAL). Wyo. Stat. § 40-12-109 imposes a mandatory pre-suit notice requirement on private actions: written notice to the alleged violator within (a) one (1) year of discovery or (b) two (2) years of the consumer transaction (whichever first), describing the deceptive practice and actual damages. The defendant has fifteen (15) days to make a written offer to cure (Wyo. Stat. § 40-12-102(a)(viii)). Suit may be filed only if the practice becomes "uncured" and only within one (1) year after notice. Filing an AG complaint does NOT satisfy this requirement.
• Statute of limitations. WCPA: see Wyo. Stat. § 40-12-109 (above). FDCPA: ONE (1) year (15 U.S.C. § 1692k(d)). FCRA: TWO (2) years from discovery, FIVE (5) years outside (15 U.S.C. § 1681p). Filing administrative complaints does NOT toll these deadlines.
• Exclusivity. Wyo. Stat. § 40-12-114 makes the WCPA's remedies exclusive for actions brought under the WCPA, but does not preempt independent common-law or other statutory claims for similar conduct.
• Exemptions. Wyo. Stat. § 40-12-110 exempts (a) acts or practices required or permitted by state or federal law, rule, regulation, or judicial or administrative decision, and (b) certain advertising-medium publishers without knowledge of the deceptive character of the advertisement.
• Data-breach reporting. Wyo. Stat. §§ 40-12-501 through 40-12-509 require information holders that conduct business in Wyoming and own or license computerized PII about Wyoming residents to (a) conduct a reasonable and prompt investigation upon awareness of a breach, (b) notify affected residents in the most expedient time possible without unreasonable delay, and (c) include the content elements specified at Wyo. Stat. § 40-12-502(e). Enforcement is by the AG; there is no private right of action under the breach statute.
• CFPB jurisdiction. The CFPB has UDAAP authority over "covered persons" offering consumer financial products or services (12 U.S.C. § 5536) and enforces enumerated consumer-financial statutes (FDCPA, FCRA, TILA, RESPA, EFTA, ECOA). The CFPB does not regulate ordinary retail sales of goods or non-financial services — those go to the FTC and Wyoming AG.
• Consumer Sentinel. Both CFPB and FTC complaints are accessible to state AGs through the Consumer Sentinel Network. Filing once with the CFPB or FTC therefore reaches the Wyoming AG indirectly, but a parallel direct filing with the Wyoming AG is recommended to invoke state-level mediation and any state-law enforcement action.
• Public Records Act. Complaints filed with the Wyoming AG may be subject to public disclosure under Wyo. Stat. §§ 16-4-201 through 16-4-205. Redact sensitive personal identifiers and ask the AG to flag any confidential business information that respondents claim is exempt.
• Recordkeeping. Retain originals of all evidentiary documents. Submit copies — never originals — to administrative agencies. Mail by U.S. Certified Mail Return Receipt Requested, or use the agency's online portal and download the confirmation page.
• No retaliation tolling. Filing administrative complaints provides no automatic protection against private litigation by the respondent (e.g., a debt collection lawsuit), but a documented complaint can support FDCPA or WCPA defenses and counterclaims.

7. SOURCES AND REFERENCES

• Wyoming Attorney General — Consumer Protection and Antitrust Unit — https://attorneygeneral.wyo.gov/law-office-division/consumer-protection-and-antitrust-unit
• Wyoming AG — Consumer Complaints page — https://attorneygeneral.wyo.gov/law-office-division/consumer-protection-and-antitrust-unit/consumer-complaints
• Wyoming Consumer Protection Act, Wyo. Stat. §§ 40-12-101 through 40-12-114 — https://wyoleg.gov/statutes/compress/title40.pdf
• Wyo. Stat. § 40-12-105 (unlawful practices) — https://law.justia.com/codes/wyoming/title-40/chapter-12/article-1/section-40-12-105/
• Wyo. Stat. § 40-12-106 (restraining unlawful practices) — https://law.justia.com/codes/wyoming/title-40/chapter-12/article-1/section-40-12-106/
• Wyo. Stat. § 40-12-107 (assurances of voluntary compliance) — https://law.justia.com/codes/wyoming/title-40/chapter-12/article-1/section-40-12-107/
• Wyo. Stat. § 40-12-108 (private remedies) — https://law.justia.com/codes/wyoming/title-40/chapter-12/article-1/section-40-12-108/
• Wyo. Stat. § 40-12-109 (limitation of actions) — https://law.justia.com/codes/wyoming/title-40/chapter-12/article-1/section-40-12-109/
• Wyo. Stat. § 40-12-110 (exemptions) — https://law.justia.com/codes/wyoming/title-40/chapter-12/article-1/section-40-12-110/
• Wyoming Breach of Security Notification statute, Wyo. Stat. §§ 40-12-501 through 40-12-509 — https://law.justia.com/codes/wyoming/title-40/chapter-12/article-5/
• Wyoming Collection Agency Act, Wyo. Stat. §§ 33-11-101 through 33-11-117 — https://wyoleg.gov/
• Consumer Financial Protection Bureau — Submit a Complaint — https://www.consumerfinance.gov/complaint/
• CFPB Consumer Complaint Database — https://www.consumerfinance.gov/data-research/consumer-complaints/
• 12 U.S.C. § 5536 (UDAAP) — https://www.law.cornell.edu/uscode/text/12/5536
• Federal Trade Commission — Report Fraud — https://reportfraud.ftc.gov/
• FTC IdentityTheft.gov — https://www.identitytheft.gov/
• OCC — HelpWithMyBank — https://helpwithmybank.gov/
• NCUA — Consumer Assistance Center — https://www.mycreditunion.gov/consumer-assistance-center
• FDIC — Consumer Assistance — https://ask.fdic.gov/
• SEC — Tips, Complaints, Referrals — https://www.sec.gov/tcr
• FINRA — File a Complaint — https://www.finra.org/investors/file-complaint
• Wyoming Department of Insurance — https://doi.wyo.gov/
• Wyoming Banking Division — https://wyomingbankingdivision.wyo.gov/
• Wyoming Secretary of State — Compliance Division (Securities) — https://sos.wyo.gov/Securities/
• Wyoming Department of Audit — Banking Division (Collection Agency Board) — https://audit.wyo.gov/
• Wyoming Division of Criminal Investigation (DCI) — https://attorneygeneral.wyo.gov/dci
• HUD — File a Fair Housing Complaint — https://www.hud.gov/program_offices/fair_housing_equal_opp
• DOL EBSA — https://www.askebsa.dol.gov/
• FCC — Consumer Complaint Center — https://consumercomplaints.fcc.gov/
• NHTSA — Report a Safety Problem — https://www.nhtsa.gov/report-a-safety-problem

Disclaimer: This template is provided for informational purposes only and does not constitute legal advice. Filing administrative complaints does not create attorney-client privilege, does not toll private statutes of limitations, does not satisfy the Wyo. Stat. § 40-12-109 pre-suit notice requirement, and does not substitute for civil or criminal litigation when warranted. An attorney licensed in Wyoming should review this packet before filing.