FCRA Credit Report Dispute Complaint - District of Columbia

COMPLAINT — FAIR CREDIT REPORTING ACT AND D.C. CONSUMER PROTECTION PROCEDURES ACT — DISTRICT OF COLUMBIA

TABLE OF CONTENTS

1. Caption
2. Introduction
3. Parties, Jurisdiction, and Venue
4. Factual Allegations
5. Count I — Violation of 15 U.S.C. § 1681e(b) (CRA — Failure to Follow Reasonable Procedures for Accuracy)
6. Count II — Violation of 15 U.S.C. § 1681i (CRA — Failure to Reinvestigate)
7. Count III — Violation of 15 U.S.C. § 1681s-2(b) (Furnisher — Failure to Investigate After Notice)
8. Optional Count IV — D.C. Consumer Protection Procedures Act
9. Damages
10. Prayer for Relief
11. Demand for Trial by Jury
12. Signature Block
13. Initial Service Checklist
14. District of Columbia Practice Notes
15. Sources and References

1. CAPTION

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

CIVIL ACTION NO. [________________________________]

COMPLAINT — FCRA AND D.C. CONSUMER PROTECTION PROCEDURES ACT

JURY TRIAL DEMANDED

2. INTRODUCTION

1. This action arises under the federal Fair Credit Reporting Act ("FCRA"), 15 U.S.C. § 1681 et seq., and the District of Columbia Consumer Protection Procedures Act ("CPPA"), D.C. Code § 28-3901 et seq. It arises from Defendants' reporting of inaccurate information about Plaintiff and their failure to conduct a reasonable reinvestigation after Plaintiff disputed that information.

2. Congress enacted the FCRA "to require that consumer reporting agencies adopt reasonable procedures" that are "fair and equitable to the consumer, with regard to the confidentiality, accuracy, relevancy, and proper utilization" of consumer credit information. 15 U.S.C. § 1681(b). The CPPA was enacted to "assure that a just mechanism exists to remedy all improper trade practices." D.C. Code § 28-3901(b)(1).

3. Defendant [CONSUMER REPORTING AGENCY] (the "CRA") is alleged to be a "consumer reporting agency" within 15 U.S.C. § 1681a(f). Defendant [FURNISHER] is alleged to have furnished the disputed information to one or more consumer reporting agencies. Any CPPA classification is pleaded separately and only if the transaction and conduct satisfy D.C. Code §§ 28-3901, 28-3904, and 28-3905(k).

4. Plaintiff seeks only the relief supported by the selected counts, forum, statutory capacity, proof of willful or negligent noncompliance, preemption analysis, and current law. The FCRA provisions cited here list damages, costs, and attorney's fees; this complaint does not attribute a private injunctive remedy to the FCRA.

3. PARTIES, JURISDICTION, AND VENUE

3.1. Plaintiff [PLAINTIFF NAME] ("Plaintiff") is an individual and therefore a "consumer" within 15 U.S.C. § 1681a(c), residing at [ADDRESS]. Plaintiff is treated as a D.C. Code § 28-3901 consumer only if the optional CPPA count's separate transaction and capacity facts establish that status.

3.2. Defendant [CONSUMER REPORTING AGENCY] ("CRA") is a [STATE] [corporation / LLC] that, for consideration or on the other statutory basis, regularly engages in assembling or evaluating consumer credit information for the purpose of furnishing consumer reports to third parties, as required by 15 U.S.C. § 1681a(f). The facts supporting that classification are: [DETAILS].

3.3. Defendant [FURNISHER / CREDITOR / DEBT COLLECTOR] ("Furnisher") is a [STATE] [corporation / LLC] that furnished the Disputed Item to one or more consumer reporting agencies. The exact information, dates, recipients, and basis for alleging CRA notice under § 1681i(a)(2) are stated below.

3.4. Subject-matter jurisdiction. If filed in U.S. District Court, jurisdiction over the FCRA counts is alleged under 28 U.S.C. § 1331 and 15 U.S.C. § 1681p. Before adding the optional CPPA count in federal court, counsel must analyze 28 U.S.C. § 1367, D.C. Code § 28-3905(k)(2)'s Superior Court language, preemption, and any controlling jurisdictional authority. If filed in D.C. Superior Court, allege the facts establishing that it is a court of competent jurisdiction under § 1681p and D.C. Code § 11-921.

3.5. Venue. If this action is filed in U.S. District Court, allege the specific facts satisfying 28 U.S.C. § 1391(b)(1) or (2). If it is filed in D.C. Superior Court, omit the federal venue allegation; D.C. Code § 13-423 addresses personal jurisdiction, not venue.

3.6. Personal jurisdiction. For each defendant, identify the exact D.C. Code § 13-423(a) conduct basis, show that the claim arises from that conduct when subsection (b) applies, and confirm constitutional due process: [DEFENDANT-SPECIFIC FACTS].

4. FACTUAL ALLEGATIONS

4.1. The inaccurate item. Plaintiff's consumer file maintained by the CRA contains the following inaccurate information (the "Disputed Item"): [DESCRIBE — e.g., a [CREDITOR] account reported as charged-off / past due / belonging to Plaintiff that Plaintiff never opened / reporting an incorrect balance of $[AMOUNT] / reporting late payments that did not occur on [DATE(S)]].

4.2. The Disputed Item is inaccurate and/or materially misleading because [STATE THE TRUTH — e.g., the account was paid in full on [DATE]; the account does not belong to Plaintiff and resulted from identity theft; the balance is $0; Plaintiff was never late].

4.3. The written dispute to the CRA. On or about [__/__/____], Plaintiff sent the CRA a written dispute identifying the Disputed Item, explaining why it is inaccurate, and enclosing supporting documentation. A true and correct copy of the dispute (and proof of delivery) is attached as Exhibit A.

4.4. The dispute was not frivolous or irrelevant within the meaning of 15 U.S.C. § 1681i(a)(3); it identified the specific item, the basis for the dispute, and the corrected information.

4.5. The CRA's reinvestigation. Section 1681i(a) ordinarily uses a 30-day period, permits a qualifying extension of no more than 15 additional days, requires furnisher notice within 5 business days, and requires written results within 5 business days after completion. The CRA allegedly violated one or more of those duties because it [FAILED TO REVIEW IDENTIFIED MATERIAL / FAILED TO FORWARD IDENTIFIED RELEVANT INFORMATION / FAILED TO DELETE OR MODIFY INACCURATE, INCOMPLETE, OR UNVERIFIABLE INFORMATION / MISAPPLIED THE EXTENSION / FAILED TO SEND TIMELY RESULTS / OTHER]. State the dates and facts for each selected theory: [DETAILS].

4.6. The furnisher's investigation after CRA notice. On [DATE / BASIS FOR INFORMATION AND BELIEF], the CRA provided the furnisher notice under § 1681i(a)(2). Section 1681s-2(b) then required the investigation, review, reporting, nationwide-notice, and correction steps stated there. The furnisher allegedly failed to perform the following identified duty or duties: [DETAILS]. A direct consumer dispute alone is not pleaded as the trigger for this subsection (b) count.

4.7. The harm and causation. Plaintiff alleges actual damages sustained as a result of the identified statutory failure: [SPECIFIC LOSS, DATE, CAUSAL LINK, AND SUPPORTING DOCUMENT]. Do not include a category that lacks a factual and legal basis under controlling law.

5. COUNT I — VIOLATION OF 15 U.S.C. § 1681e(b) (CRA — FAILURE TO FOLLOW REASONABLE PROCEDURES FOR ACCURACY)

5.1. Plaintiff realleges and incorporates Paragraphs 1 through 4.7.

5.2. The CRA prepared and published one or more consumer reports concerning Plaintiff that contained the inaccurate Disputed Item.

5.3. The CRA violated 15 U.S.C. § 1681e(b) by failing to follow reasonable procedures to assure the maximum possible accuracy of the information in the consumer reports it prepared concerning Plaintiff.

5.4. The facts supporting [willful noncompliance under § 1681n / negligent noncompliance under § 1681o / both in properly permitted alternatives] are: [DETAILS]. The pleading does not infer willfulness merely from an inaccuracy or an unsuccessful dispute.

6. COUNT II — VIOLATION OF 15 U.S.C. § 1681i (CRA — FAILURE TO REINVESTIGATE)

6.1. Plaintiff realleges and incorporates Paragraphs 1 through 4.7.

6.2. After receiving Plaintiff's dispute, the CRA violated the following selected § 1681i(a) duty or duties: [REINVESTIGATION / CONSUMER-INFORMATION REVIEW / FURNISHER NOTICE AND TRANSMISSION / TREATMENT OF INACCURATE, INCOMPLETE, OR UNVERIFIABLE INFORMATION / TIMING / RESULTS NOTICE]. The supporting facts and dates are: [DETAILS].

6.3. The CRA further failed to provide Plaintiff with timely written notice of the results of any reinvestigation as required by 15 U.S.C. § 1681i(a)(6).

6.4. The facts supporting the selected § 1681n and/or § 1681o state of noncompliance are: [DETAILS].

7. COUNT III — VIOLATION OF 15 U.S.C. § 1681s-2(b) (FURNISHER — FAILURE TO INVESTIGATE AFTER NOTICE)

7.1. Plaintiff realleges and incorporates Paragraphs 1 through 4.7.

7.2. Upon receiving notice of Plaintiff's dispute from the CRA under 15 U.S.C. § 1681i(a)(2), the furnisher was required by § 1681s-2(b) to conduct the investigation, review the relevant CRA-provided information, report results, make the required nationwide-agency report when applicable, and modify, delete, or permanently block information that was inaccurate, incomplete, or unverifiable after the investigation.

7.3. The furnisher failed to perform one or more of these duties and continued to report the inaccurate Disputed Item, in violation of 15 U.S.C. § 1681s-2(b).

7.4. The facts supporting the selected § 1681n and/or § 1681o state of noncompliance are: [DETAILS].

8. OPTIONAL COUNT IV — D.C. CONSUMER PROTECTION PROCEDURES ACT

8.1. Plaintiff realleges and incorporates Paragraphs 1 through 7.4.

8.2. This count is included only if Plaintiff has selected and supported a capacity under § 28-3905(k)(1), and the transaction, goods or services, trade practice, and each Defendant's merchant status satisfy § 28-3901. The supporting facts are: [DETAILS].

8.3. The specific, independently supported, non-preempted trade practice is: [DESCRIBE CONDUCT OUTSIDE ANY PREEMPTED FURNISHER OR REINVESTIGATION DUTY]. If the facts and current law support it, identify the exact § 28-3904 subsection:

• D.C. Code § 28-3904(e) — misrepresenting a material fact which has a tendency to mislead;
• D.C. Code § 28-3904(f) — failing to state a material fact if such failure tends to mislead;
• D.C. Code § 28-3904(f-1) — using innuendo or ambiguity as to a material fact which has a tendency to mislead.

8.4. Before filing this count, counsel analyzed § 1681t(b)(1)(F), § 1681h(e), the identity of each defendant, the source of each duty, and controlling precedent. The CPPA count does not merely relabel a § 1681s-2 or § 1681i duty as a District-law claim.

8.5. If supported by Plaintiff's statutory capacity, the proven violation, and the requested relief, Plaintiff seeks under D.C. Code § 28-3905(k)(2): (A) treble damages, or $1,500 per proven violation, whichever is greater and payable to the consumer; (B) reasonable attorney's fees; (C) punitive damages; (D) an injunction against the use of the unlawful trade practice; (E) in a representative action, relief necessary to restore identified money or property to the consumer; and (F) any other relief the Court determines proper. The statute does not itself establish that each allegation or statement is a separate violation.

9. DAMAGES

9.1. Actual damages sustained as a result of the proven failure, in an amount supported by the facts and controlling law.

9.2. FCRA statutory damages of not less than $100 and not more than $1,000 for willful noncompliance under 15 U.S.C. § 1681n(a)(1)(A). The subsection does not state a per-violation multiplier.

9.3. FCRA punitive damages for willful noncompliance under 15 U.S.C. § 1681n(a)(2).

9.4. CPPA relief, if Count IV is properly included and proven — the claim-specific relief supported under D.C. Code § 28-3905(k)(2), without assuming a violation unit or automatic entitlement.

9.5. Reasonable attorney's fees and costs under 15 U.S.C. §§ 1681n(a)(3) and 1681o(a)(2), and D.C. Code § 28-3905(k)(2)(B).

9.6. Equitable relief only under a count and authority that permits private equitable relief. Sections 1681n and 1681o do not list a private injunction, so this complaint does not request one under the FCRA.

10. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in Plaintiff's favor and against Defendants for:

• A. Actual damages in an amount to be proven at trial;
• B. Statutory damages of not less than $100 and not more than $1,000 under 15 U.S.C. § 1681n(a)(1)(A), if willful noncompliance is proven;
• C. Punitive damages under 15 U.S.C. § 1681n(a)(2);
• D. Relief supported under D.C. Code § 28-3905(k)(2), only if the optional CPPA count survives jurisdictional and preemption review and is proven;
• E. Any equitable relief supported by a separately identified private cause of action and current authority, but no private injunction attributed to §§ 1681n or 1681o;
• F. Reasonable attorney's fees and costs under 15 U.S.C. §§ 1681n and 1681o and D.C. Code § 28-3905(k)(2)(B);
• G. Pre- and post-judgment interest as allowed by law; and
• H. Such other and further relief as the Court deems just and proper.

11. DEMAND FOR TRIAL BY JURY

Plaintiff demands a trial by jury on all issues so triable, subject to the selected forum's current Rule 38 and any issue-specific limit on the jury right.

12. SIGNATURE BLOCK

Date: [__/__/____]

Respectfully submitted,

[LAW FIRM NAME]

By: [________________________________]

[ATTORNEY NAME], D.C. Bar No. [####]

Counsel for Plaintiff

[STREET ADDRESS]

[CITY, STATE ZIP]

Telephone: [NUMBER]

Email: [EMAIL]

13. INITIAL SERVICE CHECKLIST

☐ If filing in federal court: obtain an issued summons for each defendant and serve the summons with the Complaint under Federal Rule of Civil Procedure 4; complete the applicable waiver or proof procedure.

☐ If filing in D.C. Superior Court: deliver a prepared summons when filing and serve the issued summons with the Complaint, Initial Order, any addendum, and other filing-time orders under D.C. Superior Court Civil Rule 4.

☐ Do not treat CM/ECF, e-filing, or later-paper electronic service as a substitute for original process unless a current rule or case-specific order expressly permits it.

☐ Record each defendant, authorized recipient, method, date, and proof or acknowledgment for the selected forum: [DETAILS].

14. DISTRICT OF COLUMBIA PRACTICE NOTES

• Forum gate. Section 1681p permits an FCRA action in an appropriate U.S. district court or other court of competent jurisdiction. Federal supplemental jurisdiction is not automatic: analyze § 1367, § 28-3905(k)(2)'s Superior Court text, preemption, removal, and the actual parties and claims before choosing a forum.
• FCRA limitations. The earlier of 2 years after discovery or 5 years after the violation. 15 U.S.C. § 1681p.
• CPPA remedy analysis. D.C. Code § 28-3905(k)(2) lists treble damages or $1,500 per proven violation, whichever is greater and payable to the consumer, plus specified other relief. Identify the consumer, plaintiff capacity, proven violation unit, and factual and legal basis for every requested remedy; do not assume that separately pleaded allegations automatically compound the statutory amount.
• Furnisher liability is § 1681s-2(b) only. No private right of action exists under § 1681s-2(a). Plead and prove the consumer disputed through a CRA and the CRA forwarded notice to the furnisher.
• Private FCRA remedies. Sections 1681n and 1681o list damages, costs, and attorney's fees; they do not list a private injunction. Do not request deletion or an injunction under the FCRA without controlling authority for the selected theory.
• CPPA deadline analysis. Section 12-301 contains different limitation periods for different claim types. Do not turn § 28-3905(d)(1)'s Department-process lookback into a complete private limitations rule; analyze classification, accrual, tolling, and controlling authority.
• FCRA pre-emption. Analyze 15 U.S.C. § 1681t(b)(1)(F) and § 1681h(e) before relying on the CPPA count for inaccurate-reporting conduct.
• Evidence to preserve. The disputed report(s), the written dispute and proof of delivery, the CRA's reinvestigation result, the ACDV/e-OSCAR records, and post-dispute reports showing the item remained.

15. SOURCES AND REFERENCES

• 15 U.S.C. § 1681e (accuracy procedures) — https://www.govinfo.gov/link/uscode/15/1681e
• 15 U.S.C. § 1681i (reinvestigation) — https://www.govinfo.gov/link/uscode/15/1681i
• 15 U.S.C. § 1681s-2 (furnisher responsibilities) — https://www.govinfo.gov/link/uscode/15/1681s-2
• 15 U.S.C. §§ 1681n and 1681o (civil liability) — https://www.govinfo.gov/link/uscode/15/1681n
• 15 U.S.C. § 1681p (jurisdiction and limitations) — https://www.govinfo.gov/link/uscode/15/1681p
• 15 U.S.C. § 1681t and § 1681h(e) (state-law preemption provisions) — https://www.govinfo.gov/link/uscode/15/1681t
• 28 U.S.C. §§ 1331, 1367, and 1391 — https://www.govinfo.gov/link/uscode/28/1331
• D.C. Code § 28-3901 et seq. (CPPA) — https://code.dccouncil.gov/us/dc/council/code/titles/28/chapters/39
• D.C. Code § 28-3904 (unlawful trade practices) — https://code.dccouncil.gov/us/dc/council/code/sections/28-3904
• D.C. Code § 28-3905 (complaint procedures / private action) — https://code.dccouncil.gov/us/dc/council/code/sections/28-3905
• D.C. Code § 11-921 (Superior Court civil jurisdiction) — https://code.dccouncil.gov/us/dc/council/code/sections/11-921
• D.C. Code § 13-423 (personal jurisdiction based on conduct) — https://code.dccouncil.gov/us/dc/council/code/sections/13-423
• Federal Rules of Civil Procedure (Dec. 1, 2025) — https://www.uscourts.gov/sites/default/files/document/federal-rules-of-civil-procedure.pdf
• D.C. Superior Court Rules of Civil Procedure — https://www.dccourts.gov/sites/default/files/superior-rules/Superior%20Court%20Rules%20of%20Civil%20Procedure_4.pdf

Disclaimer: This template is provided for informational purposes only and does not constitute legal advice. An attorney admitted to the D.C. Bar (and the U.S. District Court for the District of Columbia, if filing in federal court) must review and customize this document before filing. Statutes, regulations, and pre-emption doctrine change frequently; verify all authorities before use.