POWER MUST ANSWER.
Case file
Companion article: The Bank's Mistakes Became the Customer's Record
Record assembled: September 18, 2026
The central source is an administrative consent order. Read it together with the stipulation, which sets out the bank's nonadmission position. The regulator's release explains its public characterization; the Reuters report preserves a contemporaneous bank response. Different sources serve different purposes and should not be substituted for one another.
The article contains original analysis of the processes described. Its arithmetic illustration and operational examples are expressly hypothetical. They are not customer testimony or loss estimates.
| ID | Document | Date or type | Use and limit |
|---|---|---|---|
| R01 | CFPB consent order, 2024-CFPB-0009 | September 11, 2024; primary | Findings and required measures. Does not by itself prove subsequent implementation. |
| R02 | TD stipulation | Filed September 11, 2024; primary | Settlement posture and consent. |
| R03 | CFPB case page | September 11, 2024; primary | Official summary and links to filings. |
| R04 | CFPB announcement | September 11, 2024; primary | Agency explanation; broader counts require attention to units and categories. |
| R05 | Reuters contemporaneous report | September 11, 2024; secondary | Source of the bank's contemporary response used in the article. |
| R06 | Direct dispute rule | Regulation V | Duties, scope and exceptions. General context, not advice on a particular dispute. |
| R07 | Policies and procedures rule | Regulation V | Framework for furnishing controls. |
| R08 | Accuracy and integrity guidelines | Regulation V, Appendix E | Operational context. |
| R09 | Consumer reporting company directory | CFPB consumer resource | Explains the wider reporting market. Does not establish individual harm in this case. |
| R10 | Tenant screening guidance | CFPB consumer resource | Illustrates a possible use of reports and applicable consumer rights. |
| R11 | Disputing errors guide | FTC consumer resource | Consumer-facing correction process. |
| R12 | 2020 TD case page | August 20, 2020; primary | Separate earlier proceeding. |
| R13 | 2020 CFPB announcement | August 20, 2020; primary | Details of that earlier action. |
| R14 | TD's own 2020 response | August 20, 2020; bank statement | TD's position about the earlier proceeding. |
| R15 | April 2024 supervisory announcement | April 8, 2024; primary | Broader findings about unnamed entities. They are not all attributable to TD. |
| R16 | Administrative docket | Official docket | Starting point for checking subsequent public filings. This Record does not certify an exhaustive later-history search. |
These are outbound source links. Unchecked does not host or independently authenticate these files.
Paragraph references use the order's numbered paragraphs, not a browser's page counter.
| Issue | Location in R01 |
|---|---|
| Collector payment information | Paragraphs 12 to 18 |
| First delinquency dates | Paragraphs 19 to 25 |
| Direct dispute investigations | Paragraphs 45 to 53 |
| Indirect dispute investigations | Paragraphs 54 to 60 |
| Compliance plan and board responsibility | Paragraphs 114 to 118 |
Consult the full surrounding text for qualifications, defined terms and additional findings. These selected passages support the article; they are not an exhaustive digest of the order.
| Category | Required amount in the September 2024 action | Interpretation |
|---|---|---|
| Consumer redress | $7.76 million | Ordered consumer relief; this Record does not independently verify delivery. |
| Civil money penalty | $20 million | A separate sanction. |
| Combined amount | $27.76 million | Arithmetic sum, sometimes rounded in headlines. |
Source: R03. The combined amount is not a fine, and dividing it by an approximate account count does not give an actual payment per customer.
Federal regulators found that TD Bank sent inaccurate consumer information and mishandled disputes. The case exposes a basic imbalance in financial life: an institution can create a damaging record that the person described cannot fix alone.
| Party or source | Material in hand | New outreach status |
|---|---|---|
| TD Bank | Historical positions in R05 and R14; stipulation in R02 | No new request sent. |
| CFPB | Public documents indexed above | No new request sent. |
| Affected consumers | No original interviews in this Record | No interview requests sent. |
| Reporting companies | No case-specific new response | No new request sent. |