Consumer Financial Protection Bureau v. Transunion

Order issued in response to previous settlement

Excerpt

TransUnion deceived consumers by falsely marketing credit scores and credit-related products, enrolling consumers without consent, lacking cancellation mechanisms, and providing misleading information about the products' costs, purpose, and protection of personal information.

Our analysis

TransUnion engaged in deceptive practices by manipulating consumers to sign up for subscription services, violating the Consumer Financial Protection Act (CFPA). They enrolled consumers without consent, failed to offer cancellation mechanisms, misrepresented products as free or $1, falsely portrayed the purpose of collecting payment information, provided misleading information about their credit score, and misrepresented the consequences of product cancellation. Transunion manipulated its consumers to sign up for the subscription services. The follow up examination revealed that the defendant violated the settlement agreed and while it required credit card information for verification purposes, it contained a button for availing a free credit score which if clicked would result in the user being signed up for a recurring monthly subscription. These disclosures were mentioned in fine print and were difficult to locate. Additionally, they violated the Electronic Fund Transfer Act (EFTA) and Regulation E by not obtaining written authorization for recurring charges and failing to provide copies of such authorizations to consumers.

Outcome

CFPB settled charges with TransUnion, requiring the company to pay $13.9 million in restitution and $3 million in civil penalties. TransUnion was also bound by a law enforcement order to warn consumers about the limited use of credit scores, obtain consent for recurring payments, provide easy cancellation options, and comply with other requirements. Despite initial violations in 2019, TransUnion continued to violate the order and engage in further legal violations, leading to further consequences from the CFPB.

Parties

Consumer Financial Protection Bureau and Transunion

Case number

1:22-cv-01880

Related deceptive patterns

Related laws

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