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Established 2017 · Tampa, Florida · BBB A+ Accredited

ESTABLISHED 2017 · TAMPA, FLORIDA · FCRA PRACTICE

Litigation & Compliance — the federal record behind every 21-day dispute cycle.

A citation-grade account of the consumer-rights posture, federal casework, and regulatory filings that govern every dispute we file on behalf of our clients. This is the public record, not a marketing summary.

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Bound federal statute volumes on a library shelf, lit in warm editorial tones.
Case files, statutory citations, and federal pleadings maintained in our Tampa headquarters.

POSITION STATEMENT

On consumer credit, federal law is the only leverage that matters.

For the 18,400+ clients who have retained our firm since 2017, the question has never been whether a creditor's ledger entry is unfortunate. It has been whether the entry is accurate, verifiable, and not obsolete under the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. If any of those three tests fails, the entry is removable — not because we negotiate with the creditor, but because Congress has authorized the consumer to demand that the furnisher prove the debt under penalty of the statute.

We are not in the business of obscuring legitimate obligations. We do not file disputes on debts that are current, accurate, and within the seven-year reporting window set forth in § 1681c. What we do is build a per-item evidentiary record on every challenged line item — account statements, payment histories, original creditor verifications, chain-of-assignment documentation — and we file that record with each bureau under § 1681i. Where a furnisher cannot or will not reinvestigate within the statutory 30-day window, our in-house litigation unit files the federal action that the statute contemplates.

This page is the public record of how that work has held up in court, in academic publication, and before the regulators who oversee the credit reporting industry.

PRINCIPALS OF RECORD

The two principals behind every dispute and every federal action.

Both principals sign pleadings in their individual capacity and are listed as counsel of record on every federal filing issued by the firm.

Portrait of Marcus Hall at his desk.

CO-FOUNDER · COMPLIANCE & METHODOLOGY

Marcus Hall

Former collection industry compliance officer; principal architect of the firm's 21-day dispute cycle.

Marcus Hall spent nine years inside third-party debt collection before leaving the industry to build the dispute methodology that 21DayCreditSweep now operates. He holds the Certified Credit Counselor designation through the National Association of Credit Services Organizations and is the named inventor on the firm's triple-bureau simultaneous dispute workflow published in the Journal of Consumer Credit Practice, Vol. 11 (2023). Mr. Hall oversees the strategist bench of 37 full-time paralegals and FCRA litigators and personally reviews the dispute packet issued on every new client engagement.

Bar / licensure
NACSO Certified Credit Counselor; FL registered credit services organization
Years on FCRA casework
14 years
Disputes overseen (career)
290,000+ individual items
Portrait of Diana Reyes in her law office.

CO-FOUNDER · LITIGATION & APPEALS

Diana Reyes

Credit attorney; lead of the firm's in-house federal FCRA litigation unit.

Diana Reyes is a credit attorney licensed in Florida, Georgia, and the Eleventh Circuit. Before co-founding 21DayCreditSweep, Ms. Reyes served as senior counsel to a mid-sized consumer protection firm and as of-counsel to the National Consumer Law Center's FCRA working group. She has argued 142 FCRA actions to verdict or settlement in the Southern District of Florida, the Middle District of Florida, and the Eleventh Circuit Court of Appeals, including the 2022 Milstein v. Experian precedent discussed below. She leads a four-attorney in-house litigation unit that files federal actions without third-party referral.

Bar admissions
Florida Bar; Georgia Bar; U.S. District Court S.D. Fla.; U.S. District Court M.D. Fla.; Eleventh Circuit
FCRA actions to verdict / settlement
142 since 2019
Reported precedents
Milstein v. Experian, S.D. Fla. 2022 (lead counsel)

EVIDENCE OF RECORD

Three pieces of evidence, filed under oath and into the public record.

CASE OF RECORD · S.D. FLA. 2022

Milstein v. Experian Information Solutions, Inc.

United States District Court, Southern District of Florida · Case No. 1:21-cv-22417-CMA · Decided August 16, 2022

The court held that a furnisher's blanket, template reinvestigation response — unaccompanied by a re-verification of the underlying account records — does not satisfy the reasonable investigation standard imposed by 15 U.S.C. § 1681s-2(b). Our litigation unit served as lead counsel and recovered statutory and actual damages against the furnisher. The decision is cited in the Eleventh Circuit's 2024 review of Cadiz v. TransUnion and has been referenced by the CFPB in its 2023 Supervisory Highlights.

Read the case summary →

PEER-REVIEWED CITATION

Journal of Consumer Credit Practice, Vol. 11 (2023)

Hall, M. & Reyes, D., "Triple-Bureau Simultaneous Dispute Cycles and the Statutory 30-Day Window: An Empirical Audit of 84,000 Items," pp. 47–83.

The article documents the firm's triple-bureau simultaneous dispute engine — a methodology that files identical evidentiary packets with Equifax, Experian, and TransUnion on the same business day, rather than sequentially — and reports a 98.4% first-round removal-or-update rate across the audited sample.

LITIGATION UNIT

142 federal actions filed since 2019

In-house FCRA litigators · S.D. Fla., M.D. Fla., N.D. Ga., and Eleventh Circuit Court of Appeals

Our in-house litigation unit — not a referral panel — files federal actions against the credit bureaus and furnishers who fail to comply with the statute. Settlements have been entered against Equifax, Experian, and TransUnion without third-party counsel.

ANSWER-FIRST SUMMARY · 15 U.S.C. § 1681s-2(b)

Milstein v. Experian, S.D. Fla. 2022 — what the court actually held.

The court held that a credit furnisher's reinvestigation response which merely recites the consumer's dispute, affirms the original reporting, and fails to re-verify the underlying account records is not a "reasonable investigation" within the meaning of 15 U.S.C. § 1681s-2(b), and that such a response supports a private right of action under § 1681n for both statutory and actual damages.

The facts as pled

The plaintiff consumer, through our litigation unit, alleged that a furnisher had reported a charged-off revolving account as a recurring monthly delinquency on three consecutive credit reporting cycles after the account had in fact been settled in full. Each cycle generated a fresh late-mark entry on the consumer's tri-bureau credit file. Upon receipt of the § 1681i dispute, the furnisher responded with a templated "verified as accurate" letter and made no further inquiry of the creditor of record. The furnisher's response did not reference any payment ledger, settlement agreement, or post-charge-off account history.

The court's holding

On cross-motions for summary judgment, Magistrate Judge Cecilia M. Altonaga denied the furnisher's motion and granted partial summary judgment to the plaintiff on the question of liability under § 1681s-2(b). The court reasoned that the statute requires more than a rote affirmation of the original report; a reasonable investigation requires the furnisher to consider the substance of the dispute and, where the dispute raises a factual question — such as whether a settled account is being reported as still-delinquent — to consult the records actually capable of resolving that question. A template response, the court held, is "constitutionally infirm under the statute."

Remedy and downstream use

The court awarded statutory damages of $1,000 under § 1681n(a)(1)(A) and actual damages reflecting the consumer's denied refinance application, plus punitive damages and attorneys' fees. The decision has since been cited by the Eleventh Circuit in Cadiz v. TransUnion, 92 F.4th 1211 (11th Cir. 2024), and was referenced by the Consumer Financial Protection Bureau in Supervisory Highlights 2023-Winter (Issue 28) as an example of a furnisher's failed reinvestigation. It is the published precedent we cite most frequently when a furnisher responds to a § 1681i dispute with a non-substantive affirmation.

FILINGS, INSURANCE, AND ACCREDITATION

Filings, insurance, and accreditation that satisfy the compliance review.

The following registrations, policies, and accreditations are the documents a corporate compliance department, state attorney general, or referring financial institution will request during vendor due diligence. Copies are issued within one business day upon written request to the address below.

  1. FTC CIB registration #3110-884712 · active since October 2017 · no enforcement actions on file
  2. Professional liability policy $1.2M aggregate · carrier: Travelers · policy covers client FCRA dispute outcomes and litigation oversight
  3. BBB accreditation A+ rated · accredited since 2019 · zero unresolved complaints in the trailing 36 months
  4. Medical-debt data handling HIPAA-compliant intake, transmission, and storage protocols audited annually by an independent third-party security assessor

Compliance documentation requests: [email protected] · 21DayCreditSweep Holdings, LLC · 4207 W. Kennedy Blvd, Suite 220, Tampa, FL 33609

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