CFPB Files Lawsuit against TransUnion for Alleged Deceptive Marketing & False
Representations to Consumers in Violation of 2017 Consent Order

In an April 12, 2022 press release, the CFPB announced it is filing a lawsuit against
TransUnion, two of its subsidiaries and a TransUnion executive for allegedly violating a
January 3, 2017 consent order the CFPB issued on the company. The consent order
alleges that TransUnion engaged in deceptive marketing practices, including falsely
representing that the credit scores they market to consumers are the same scores
lenders use to determine creditworthiness. The consent order also alleges that
TransUnion allegedly falsely represented that TransUnion products and services were
free or cost a nominal fee, but were actually subscription programs that required
monthly payments, and that TransUnion used “digital dark patterns,” mechanisms that
cause consumers to inadvertently sign up for subscriptions or purchase products or
services, to deceive consumers into enrolling in monthly TransUnion subscription

The April 12 press release by the CFPB states that TransUnion agreed to the terms of
the consent order. According to the press release, the consent order required
TransUnion to warn consumers that the credit scores they market may not be the
scores lenders use to determine creditworthiness, obtain express informed consent for
recurring subscription payments, and provide an easy way to cancel subscriptions. The
press release states that the CFPB commenced an examination of TransUnion in
October 2018, and allegedly found in 2018, 2019, and June 2020, that TransUnion
continued to violate the consent order. By commencing a lawsuit against TransUnion,
the CFPB is seeking monetary relief for consumers, and the imposition of civil money

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