Chain of title: the documents a debt buyer has to produce

Chain of title is the documented path an account travels from the bank that opened it to the company that sued you. If any link is missing, the plaintiff has a standing problem.

The links

For a typical resold credit card account, a complete chain looks like this:

1. The original creditor's account records establishing that the account existed and the balance
2. A bill of sale from the original creditor to Buyer A
3. An account-level schedule attached to that bill of sale, listing your account
4. A bill of sale and schedule from Buyer A to Buyer B, if it was resold
5. Any assignment documents executed along the way
6. Proof that the entity named in the caption is the same entity that received the account

Nothing in that list is exotic. It is the ordinary evidence of a purchase.

What plaintiffs usually file instead

Most complaints attach a generic bill of sale referring to "the accounts described in Exhibit A," with Exhibit A absent, heavily redacted, or replaced by a one-page printout the plaintiff generated from its own database. The printout typically shows your name, an account number, and a balance, formatted to look official.

Ask the question that matters: who created this document, and when? A record the plaintiff typed up after buying the portfolio is not evidence that your account was included in the sale. It is evidence of what the plaintiff believes.

Redaction is not automatically fatal, but it is not automatically fine either

Plaintiffs redact schedules to protect other consumers' data, which is reasonable. What is not reasonable is redacting the schedule so completely that nothing connects it to you, then arguing the sealed document proves ownership. Courts routinely address this by requiring an unredacted version showing your account, filed under seal or produced in discovery.

Where the allonge fits

An allonge is a paper attached to a negotiable instrument to hold additional endorsements when there is no room on the original. In consumer debt cases, allonges appear more often in loan and note cases than credit card cases, and a freestanding allonge that arrives years later, unattached to anything, invites scrutiny about when and why it was created.

The discovery requests that expose the gap

• Every bill of sale for this account, with the account-level schedule identifying it
• Every assignment or transfer document naming this account
• The purchase and sale agreement governing the portfolio, including warranty and disclaimer provisions
• The price paid for the portfolio and allocated to this account
• The name and role of every entity that held the account

One clean, simple demand summarizes all of it: produce the document, created by the original creditor, that names my account number and shows it in the sale you rely on.

Optional background: pooled and securitized receivables

You do not need this section in order to file anything, and it will not change what you ask for. It is here only if you are curious about where these batches go.

Some batches of accounts are packaged into larger pools that investors hold interests in, a process called securitization. The transfer documents for those pools describe the pool, not individual consumers. Account-level detail exists somewhere, often with a servicer, under agreements that are not in the court file. That does not make a debt invalid. It is simply another reason the plaintiff has to go find a document that names your account, which is exactly what you are already asking for.