{"took":291,"timed_out":false,"_shards":{"total":5,"successful":5,"skipped":0,"failed":0},"hits":{"total":{"value":26,"relation":"eq"},"max_score":null,"hits":[{"_index":"complaint-public-v1","_id":"6417045","_score":23.438831,"_source":{"product":"Credit card or prepaid card","complaint_what_happened":"On XXXX XXXX, 2022 at XXXX XXXX I called XXXX to speak to the institution who holds my deposits on a prepaid debit card given to me to receive my funds after XXXX donations at XXXX. Per the Fee Schedule provided my deposits are held at Regions Bank and there is some third party relationship with XXXX. Also, the prepaid card is issued by Comdata. \n\nThe reason for my call is that when I received the prepaid card at XXXX at the beginning of my relationship the card was in a sealed envelope which contained a prepaid card attached to a schedule of fees ( XXXX side was the Welcome letter the other side was the list of all fees ). Per the schedule of fees there are only XXXX ways to access your funds free of charge after XXXX donations. Either by conducting a POS Transaction as a credit transaction that requires a signature or via Bank XXXX Withdrawal ( for banks participating in the XXXX Network ). I called to ask where I can make a Bank XXXX Withdrawal to withdraw my funds without being charged. The Operator explained that what I was seeing on the schedule of fees is not associated with my debit card but with their payroll card. I explained the fee schedule was confusing and deceptive because it appears there is a way to withdraw funds from the account without being charged but only after I called them am I being notified that was wrong. I told them about XXXX and that this fee schedule was deceptive as there is no way to withdraw funds after I make a XXXX  donation without being charged. The bank works with XXXX as an in-network ATM, the cost is XXXX if you withdraw your money and it is XXXX  if you withdraw at a POS system. The Operator acknowledged that it was deceptive but she provided no further assistance. I would reccomend that regulators listen to my conversation with the bank at the time listed above. They let me know the call was recorded. \n\nI want the bank to update their fee schedule so they do not receive consumers. When I told the bank about the issue they pushed the blame to the XXXX donation center. I told them they could not absolve themselves of responsibility just because they give a third party authority to issue prepaid cards and the cards are sealed in envelopes sent by the bank. The Supervisor at the bank was not concerned about it even though I recommended they communicate with whomever has authority to enhance their fee schedules. I fear they are taking advantage of XXXX people who donate their XXXX and might rely on the payment and are not aware the bank is making every effort to deceive the donors and take part of their income. There are other prepaid cards for XXXX centers who have chosen not to charge fees for the first withdrawal after a XXXX donation ( for example, XXXX XXXX ).","date_sent_to_company":"2023-01-09T17:49:35.000Z","issue":"Unexpected or other fees","sub_product":"General-purpose prepaid card","zip_code":"92705","tags":null,"has_narrative":true,"complaint_id":"6417045","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"REGIONS FINANCIAL CORPORATION","date_received":"2023-01-09T17:20:28.000Z","state":"CA","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":null},"highlight":{"complaint_what_happened":["I explained the fee schedule was confusing and <em>deceptive</em> <em>because</em> it <em>appears</em> there is a way to <em>withdraw</em> <em>funds</em> from the <em>account</em> <em>without</em> being charged but only after I called them am I being notified that was wrong. I told them about XXXX and that this fee schedule was <em>deceptive</em> as there is no way to <em>withdraw</em> <em>funds</em> after I make a XXXX  donation <em>without</em> being charged."]},"sort":[23.438831,"6417045"]},{"_index":"complaint-public-v1","_id":"1550795","_score":16.427277,"_source":{"product":"Bank account or service","complaint_what_happened":"I am writing to complain about ineffective and deceptive banking services provided by Citibank : Citibank enrolled me in Checking Plus, a deceptive and predatory product ; provided me inadequate assistance when I indicated concern about my account ; provided me notices in a language I do not understand ; and failed to investigate fraud I suspected occurred on my account. \nIn or around XX/XX/XXXX I noticed on my statement that I was enrolled in a product called Checking Plus ( \" CP '' ) and that it appeared I had taken out a {$3200.00} loan. I did not recall consenting to the opening of the CP account, so I went to XXXX XXXX XXXX, XXXX, my local Citibank, to inquire about CP. The branch employee told me that CP was merely a loan offer. I understood CP to be a conventional loan, and I thought I would have to request money at a branch to utilize CP. The bank employee did not explain that Citibank would automatically transfer money to my checking account if I had a negative balance, or that I would be charged fees and interest without prior notice from Citibank. \nI told the representative that I only spoke XXXX, and I plainly brought in a statement in English. Citibank did not offer to provide XXXX notices at this time. During the next three years, I continued to reach out in XXXX about problems with my accounts and request statements in XXXX -- both via phone and at my local branch -- but I was never offered XXXX statements or notices. The bank 's failure to provide information in XXXX has made it impossible to fully understand my accounts or address my concerns with the bank. \nDuring the next two years, I continued to bank as I had in the past. But because I was misinformed about how CP worked, I accumulated at least {$260.00} in fees and {$3400.00} in debt-at least {$630.00} of this amount in interest. Because my paycheck is deposited on Fridays, on Saturdays I would check my balance and then withdraw funds from my checking account for the upcoming week at my local branch ATM. I would never withdraw more than the displayed balance. With legal help, I recently learned that an automatic {$50.00} transfer to my saving account processed on Monday morning would overdraw my checking account. Instead of notifying me of the negative balance, Citibank automatically borrowed {$100.00} from the CP account at a 18.25 % interest rate and charged a {$10.00} fee. \nEach month I reviewed my statement to ensure my account balances looked correct. Because the fees and loan payments often neared the amount lent from CP to my checking account, I did not realize that I was borrowing money. But between XX/XX/XXXX and XX/XX/XXXX, I spoke with Citibank representatives multiple times about the CP account because I was concerned after reviewing my statements. I was assured multiple times that CP was merely money that was available for me to use, even though all along I was actively borrowing money. Nobody explained that Citibank had already transferred money to my checking account, charged me fees, or made automatic payments from my checking account. I also brought up suspected fraud on my accounts but Citibank did not look into the fraud at any point in time. \nI realized that I was in substantial debt because of CP XX/XX/XXXX after I went to withdraw money and my checking balance was much lower than expected because of automatic payments to the maxed out CP account. I again brought up this issue with Citibank representatives : even after speaking to representatives in Spanish, I received written replies in English, which I could not understand. I am now in collections on this account, and continue to receive notices in English. \nCitibank failed to explain this product to me or address my concerns, and has made it impossible for me to effectively bank by communicating with me in English. Because of Citibank 's CP product, I accumulated significant debt, fees, and interest without my consent.","date_sent_to_company":"2015-09-03T15:27:49.000Z","issue":"Account opening, closing, or management","sub_product":"Checking account","zip_code":"11378","tags":null,"has_narrative":true,"complaint_id":"1550795","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"CITIBANK, N.A.","date_received":"2015-09-03T15:27:48.000Z","state":"NY","company_public_response":"Company chooses not to provide a public response","sub_issue":null},"highlight":{"complaint_what_happened":["But <em>because</em> I was misinformed about how CP worked, I accumulated at least {$260.00} in fees and {$3400.00} in debt-at least {$630.00} of this amount in interest. <em>Because</em> my paycheck is deposited on Fridays, on Saturdays I would check my balance and then <em>withdraw</em> <em>funds</em> from my checking <em>account</em> for the upcoming week at my local branch ATM. I would never <em>withdraw</em> more than the displayed balance."],"product":["Bank <em>account</em> or service"],"issue":["<em>Account</em> opening, closing, or management"],"sub_product":["Checking <em>account</em>"]},"sort":[16.427277,"1550795"]},{"_index":"complaint-public-v1","_id":"20084660","_score":16.282427,"_source":{"product":"Checking or savings account","complaint_what_happened":"I am disputing a series of electronic fund transfers ( EFTs ) from my bank account to XXXX XXXX or XXXX XXXX XXXX ( operating as XXXX ), because the merchant accepted my payments for services but failed to provide the expected benefit by refusing my legitimate withdrawal request for funds that were clearly eligible for withdrawal per their own rules and displays. Disputes filed with my bank, Chime, were unsuccessful despite the evidence provided, and no satisfactory explanation was given for their denial of my claim. \nKey Facts of the Transaction ( s ) : Between XX/XX/XXXX and XX/XX/year>, I made payments/deposits totaling approximately {$300.00} to Prudent Owl via debit and credit card associated with my Chime bank account for access to XXXX XXXX sweepstakes or games. These funds were used as intended, and the merchants interface/system subsequently showed that a portionor allof my balance, specifically {$580.00}, was eligible and available for withdrawal. \nI submitted withdrawal request ( XXXX ) on XX/XX/year>, following the merchants stated procedures, but received only automated system responses to my emails and no meaningful acknowledgment or action on my request. \nThe merchant denied or refused these withdrawal requests without valid justification, despite the funds being marked as eligible. This resulted in my not receiving the promised value, including access to my eligible funds. \nI made repeated good-faith efforts to resolve this directly with the merchant, including emails and live chat attempts, but received no satisfactory response. Although they did not acknowledge my initial emails, after I informed them that I would initiate a chargeback with my bank, they refunded {$70.00} of my prior purchases. \nAs a result, I did not receive the service/benefit I paid for ( i.e., the ability to withdraw eligible winnings/funds as advertised and agreed upon ). \nAdditional Concerns : The merchants XXXX includes a clause ( Section XXXX ) stating that if a user disputes any matter with them ( or is in the process of disputing ), the user is limited to recouping only the exact amount paid in purchases over the previous XXXX daysregardless of how much is shown as eligible for withdrawal or any additional value accrued. This provision appears to provide the merchant with a built-in mechanism to refuse payouts exceeding recent deposit amounts whenever a consumer raises a legitimate dispute, where the eligible balance is substantially higher due to accumulated winnings or credits. Such a limitation directly contradicts the fundamental appeal of these platforms, which heavily market the opportunity for users to accumulate and redeem far more than their initial deposits. This raises serious questions about whether the clause constitutes an unconscionable or deceptive practice under applicable consumer protection laws, including the Texas Deceptive Trade Practices Act ( DTPA ), as it appears to take advantage of consumers to a grossly unfair degree by allowing the merchant to retain excess funds while denying promised withdrawals and discouraging valid recourse.\n\nBasis for the Claim : Under federal law ( Electronic Fund Transfer Act / Regulation E ), consumers have rights to dispute EFTs where there is an error, including situations involving failure to receive the expected benefit from a paid transaction. My bank investigated but denied the claim ; however, the evidence ( screenshots of eligible balances, denial messages, communication logs, etc. ) clearly demonstrates the merchants non-fulfillment. Additionally, in XXXX, the Deceptive Trade Practices Act ( DTPA ) prohibits false, misleading, or deceptive acts in trade or commerce, including failure to deliver promised services after payment and unfair contract terms that take advantage of consumers.\n\nI am seeking reversal/refund of my deposits ( less the {$70.00} previously refunded ), totaling approximately {$230.00}. Although this is significantly less than the {$580.00} value of my eligible balance at the time of the dispute, it reflects my willingness to honor their TOS ( Section 15.4 ) while seeking fair resolution.","date_sent_to_company":"2026-03-09T06:52:02.000Z","issue":"Managing an account","sub_product":"Checking account","zip_code":"754XX","tags":null,"has_narrative":true,"complaint_id":"20084660","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Chime Financial Inc","date_received":"2026-03-09T06:34:12.000Z","state":"TX","company_public_response":null,"sub_issue":"Deposits and withdrawals"},"highlight":{"complaint_what_happened":["As a result, I did not receive the service/benefit I paid for ( i.e., the ability to <em>withdraw</em> eligible winnings/<em>funds</em> as advertised and agreed upon )."],"product":["Checking or savings <em>account</em>"],"issue":["Managing an <em>account</em>"],"sub_product":["Checking <em>account</em>"]},"sort":[16.282427,"20084660"]},{"_index":"complaint-public-v1","_id":"12372986","_score":15.891235,"_source":{"product":"Checking or savings account","complaint_what_happened":"To: Consumer Financial Protection Bureau (CFPB); XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX; Office of the Comptroller of the Currency (OCC); Federal Reserve Board. \n \n\nFrom: XXXX XXXX XXXX, Santander Bank Customer. \nDate: XXXX XXXX XXXX \n\nComplaint against Santander Bank for denial of access to available funds, possible racial discrimination, and multiple violations of banking and consumer protection laws. \n\nDear Sir or Madam: \n\nI am writing to formally lodge a comprehensive complaint against Santander Bank, N.A. for its actions on XXXX XXXX XXXX which resulted in my wrongful denial of available funds, public humiliation, and suspected racial discrimination. The following outlines the factual timeline of events, the laws and regulations I believe were violated, and the remedies and actions I am requesting from your agencies. I have supporting evidence of these events (including recorded phone calls with Santander customer service and screenshots of my online banking showing funds availability and account restrictions), which I can provide upon request or attach herewith. \n\n1. Factual Timeline of Events XXXX XXXX XXXX XXXX XXXX EFT  Deposit Marked Available: I received an Electronic Funds Transfer (EFT) into my Santander Bank account around XXXX XXXX XXXX XXXX XXXX XXXX. This deposit was reflected in my account balance and was marked as available for use immediately. There were no indications of any holds or restrictions on these funds in my online banking portal or via any notification from the bank. \n\n \n\nXXXX XXXX  New Account Opened at XXXX XXXX & Denial of $9,000 Withdrawal: Around XXXX XXXX the same day, I visited Santander Banks XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX) to open a new checking account. After opening this account, I attempted to withdraw $9,000 in cash from my available funds. Despite the funds showing as fully available in Santanders system, the branch manager refused to allow the withdrawal. I was denied access to $9,000 of my own money, with no valid explanation. The manager only cited that it was a large amount and gave no written notice of any hold or issue. This denial occurred even though the money was inside Santanders network (not an out-of-bank transfer) and thus should have been accessible to me without delay. I was taken aback and concerned, as there was no legal hold on the funds and no justification provided for the refusal. \n\n \n\nApproximately XXXX XXXX   Successful XXXX XXXXXXXX  Transfer Demonstrating Funds Accessibility: Immediately after being denied the cash withdrawal at the branch, I initiated an electronic transfer to test whether my funds were truly available. I used XXXX  (a digital payment service) to send XXXX from my Santander account to another account. This XXXX  transfer was completed successfully without any issues or holds. The success of this transfer confirmed that the banks systems recognized the funds as unrestricted and available. In other words, Santander itself allowed me to electronically move part of the money out, which contradicts the branch managers refusal to let me withdraw cash. This inconsistency left me confused and concerned about why I was being prevented from accessing a larger portion of my money in person. \n\n \n\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Branch & Denial of $XXXX  Withdrawal: Still needing access to my funds, I then traveled to Santanders XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX later that afternoon. I decided to request a smaller amount, attempting to withdraw $XXXX  in cash from the same account. To my shock, I was again denied access to my money by the branch manager at this second location. The managers stated reason for denying the withdrawal was that because the deposit was made that same day, it had to clear. I informed the manager that the deposit was an EFT (not a check) and was already marked as cleared/available per the banks own system. In fact, I called Santanders customer service while at the branch to double-check the status of the funds. The customer service representative confirmed that the funds were fully available in my account with no holds or restrictions. I relayed this information to the XXXX XXXX XXXX XXXX and staff, yet they still refused to allow the withdrawal. They provided no written notice or valid reason for disallowing the cash withdrawal of already-available funds. This conflicting information (branch insisting the money isnt accessible vs. customer service and online system indicating it is) was not only frustrating but is indicative of improper and inconsistent handling by the bank. \n\n \n\nBranch Staff Threaten Police Involvement  Public Humiliation: When I respectfully persisted, asserting my right to access my own money and pointing out that no legitimate hold existed, the XXXX XXXX XXXX staff escalated the situation. Instead of resolving the discrepancy or honoring the availability of funds, the manager threatened to call the police to remove me from the premises if I did not leave without my cash. I was treated as if I were a suspicious person or a criminal for simply trying to withdraw money from my own account. This was said loudly in the bank, in front of other customers and employees, causing me extreme embarrassment and public humiliation. The threat of police intervention was entirely unwarranted given that I was the rightful account holder asking for a routine service. This incident left me feeling traumatized, harassed, and discriminated against. I was made to feel as though I had done something wrong  when in fact Santander Bank was in the wrong for denying me my funds. \n\n \n\nAccount Restrictions Imposed After Branch Visits: Following the confrontations at the branches, I discovered that my Santander account was suddenly restricted from external transactions. In the evening on XXXX XXXX XXXX I noticed I could no longer perform certain transactions that I had been able to earlier. For example, I attempted to use my debit card and also initiate another external transfer, but these transactions were declined or blocked. Prior to visiting the branches, my account was fully functional (as evidenced by the successful XXXX  transfer and other internal movements of funds I made that day). It appears that after I challenged the branch managers about my withdrawals, the bank (or the branch personnel) placed an unjustified freeze or hold on my account without notifying me. I received no email, no phone call, and no written communication about any account restriction; I simply discovered it when my transactions started failing. This effectively locked me out from freely using my money externally, compounding the harm already done. \n\n \n\nInability to Make Purchases (Phone Charger Incident) & Additional Distress: As a direct consequence of these unwarranted account restrictions, I was unable to carry out even small daily transactions, which caused further hardship and embarrassment. Notably, I could not purchase a phone charger on the evening of XXXX XXXX because my card was declined due to the account restriction. I was stranded without a charged phone and had to reach out to a friend/family member for emergency financial help to pay for the charger. This experience was humiliating  I had ample funds in my bank that should have been accessible, yet I was left unable to pay for a basic necessity because Santander improperly locked down my money. The overall ordeal not only caused me financial inconvenience but also significant emotional distress, as I felt helpless and wrongly suspected or punished by the bank. \n\nThroughout all these events, Santander Bank never provided any written notice or valid explanation for denying access to my funds. The money was confirmed available by their own systems and representatives. Yet I was treated with suspicion, stonewalled in person, threatened with law enforcement, and then quietly restricted from using my account. I believe that my race played a role in how I was treated by the branch personnel (I am a person of color, and I felt that I was being judged or profiled when I tried to withdraw a large sum, as though I were not entitled to my own money). There were no objective, non-discriminatory reasons to block my withdrawals, especially after confirming funds availability. \n\nIn summary, the factual record shows a disturbing pattern of Santander Banks misconduct on XXXX XXXX XXXX: despite having a valid deposit and clear available balance, I was repeatedly denied my right to withdraw funds, met with inconsistent and false explanations, subjected to threatening and discriminatory treatment, and ultimately cut off from accessing my account externally. These actions are not only unjust but also illegal, as detailed in the next section. \n\n2. Legal Violations \n\nSantander Banks actions on XXXX XXXX XXXX violated several banking regulations, consumer protection laws, and civil rights statutes, as well as basic principles of fairness and duty of care. I urge the regulatory and enforcement agencies to consider the following violations: \n\nBanking Law Violations \n\nRegulation CC (12 C.F.R. Part 229) and the Expedited Funds Availability Act (EFAA, 12 U.S.C.  4001 et seq.)  Under federal law, when a depository institution lists funds as available in an account, those funds must be accessible to the customer. If the bank chooses to place an extended hold on a deposit (for reasons allowed under the law, such as a large check deposit or a new account), it is required to provide written notice to the depositor, including the reason for the hold and when the funds will be made available  \n\nhelpwithmybank.gov. In my case, the EFT deposit was marked available and should have been withdrawable on demand. Santander Bank failed to provide any notice of a hold or delay. In fact, there was no legitimate hold placed in their system at all  their customer service confirmed the funds had no restrictions. By denying cash withdrawals of funds that were officially available, Santander violated Regulation CCs core requirement of making funds available as disclosed. Additionally, if the bank internally decided to treat my deposit as an exception (for example, treating my new account or the large amount with extra caution), they never informed me in writing or otherwise, as mandated by law. This lack of notice and the wrongful withholding of my money is a direct violation of the EFAA and Reg CC. Santanders actions effectively constituted a secret, undisclosed hold on my funds, which is unlawful. \n\nUnfair, Deceptive, or Abusive Acts or Practices (UDAAP)  12 U.S.C.  5531  The Dodd-Frank Wall Street Reform Act prohibits banks and financial institutions from engaging in unfair, deceptive, or abusive acts or practices toward consumers. Santander Banks conduct was unfair and deceptive in multiple ways. First, the bank indicated to me (through the mobile app/online banking and customer service) that my funds were available, yet their branch staff acted in a manner that made this representation false by preventing access. This inconsistency and internal miscommunication created a misleading situation for me as a consumer. Second, the arbitrary denial of service (without any valid explanation or policy-based reason given) is inherently unfair  it caused substantial injury to me (inability to access my money, missed payments/purchases, emotional distress) which I could not reasonably avoid, and there was no legitimate benefit or justification for the banks action. The threatening of police and treatment I received could also be considered abusive, as it was an intimidation tactic that has no place in a customer service context. By violating my trust and refusing to let me use my funds despite telling me they were available, Santander engaged in a deceptive practice. By imposing secret restrictions and humiliating me for trying to withdraw money, they engaged in an unfair and abusive practice. These actions violate 12 U.S.C.  5531s prohibition on UDAAP. I urge the CFPB and relevant regulators to investigate Santander for these unfair and deceptive practices that harmed me as a consumer. \n\nCivil Rights Violations \n\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  XXXX  law guarantees that all persons shall have the right to the full and equal accommodations, advantages, facilities, and privileges of any place of public accommodation, without discrimination on the basis of race, color, or other protected characteristics  \n\nXXXX  A bank branch is a place of public accommodation under state law, as it provides services to the general public. In this incident, I was effectively denied the normal services provided to customers (specifically, withdrawal of funds and respectful treatment during a banking transaction). I strongly believe that my race was a factor in the way Santanders branch managers dealt with me. There was no legitimate business reason to refuse my withdrawals since the funds were verified and available; thus the differential treatment I received (compared to how other customers are treated when withdrawing money) points to racial discrimination. The managers quickness to assume a posture of suspicion and even threaten police involvement suggests that they saw me (a person of color) as someone unworthy of the same trust and courtesy afforded to other (non-minority) customers. This is a textbook violation of XXXX XXXX XXXX which forbids making any distinction or restriction in service based on race. Santander Bank is liable under this law for denial of services and privileges of its branch to me on account of my race, causing me to be a person aggrieved under the statute. I am filing this complaint with the XXXX XXXX XXXX XXXX XXXX  to seek accountability for this violation of my civil rights. \n\n42 U.S.C.  1981 (Federal Civil Rights Act of XXXX, as amended)  This federal law guarantees equal rights under the law to make and enforce contracts regardless of race. Specifically, 42 U.S.C.  XXXX  states that All persons within the jurisdiction of the United States shall have the same right in every State and Territory to make and enforce contracts... as is enjoyed by white citizens  \n\nlaw.cornell.edu. It further defines make and enforce contracts to include the enjoyment of all benefits, privileges, terms, and conditions of the contractual relationship  \n\nlaw.cornell.edu. In my case, my relationship with Santander Bank (as an account holder) is a contractual one  I have a contract governing my bank account. By denying me the benefit of accessing my funds, the bank failed to allow me the enjoyment of the contracts benefits on equal terms. If Santanders employees decision to block my withdrawals and restrict my account was motivated (even in part) by my race, then the bank denied me the full and equal benefit of the banking contract that a white customer would enjoy, violating XXXX. The threatening of police and differential treatment worsens this breach of equality. I was not allowed to enjoy my contract (my bank account services) in the same manner as others, due to discriminatory bias. This is actionable under 42 U.S.C.  XXXX, and I ask that regulators refer this aspect to the Department of Justice or take appropriate measures to enforce federal civil rights laws in banking. \n\nNegligence and Emotional Distress \n\nNegligent/Improper Handling of Account (Banks Breach of Duty)  Santander Bank had a duty to handle my deposit and account in accordance with standard banking practices and legal requirements. Instead, the bank negligently mishandled the situation: they either erroneously flagged my valid deposit or account for fraud without cause, or failed to train their managers on funds availability rules, resulting in my account being unjustly frozen. The lack of communication or rationale for their actions indicates a breach of the duty of care a bank owes its customer. This negligence caused me direct financial harm (I couldnt access my money when needed, impacting my transactions) and foreseeable emotional harm. \n\n \n\nIntentional or Negligent Infliction of Emotional Distress  The actions of Santanders employees went beyond mere inconvenience; they were outrageous and traumatic. Threatening to involve police over a customer attempting to withdraw their own cleared funds is extreme and outrageous conduct. This, coupled with the public humiliation I suffered and the sudden cutting off of my access to money, caused me severe emotional distress. I was left feeling distressed, anxious, and degraded by the experience. Santander Banks conduct was either intentional (in an effort to intimidate me) or grossly reckless in disregard of the high probability that it would cause emotional distress. As a result, I suffered not only financial disruption but also psychological and emotional trauma, for which the bank should be held accountable under principles of tort law. \n\nEvery one of the above points represents a serious violation of my rights as a consumer and as a citizen. Santander Banks failure to follow basic laws (like funds availability rules and anti-discrimination laws) and the mistreatment I endured are unacceptable. These incidents demonstrate both institutional failings (in policies or training) and possibly individual prejudice by branch personnel. I ask that each regulatory and enforcement body address the aspects relevant to their jurisdiction. \n\nConclusion \n\nThank you for your attention to this serious matter. What happened to me on XXXX XXXX XXXX, was deeply disturbing and unacceptable for a banking institution in this country. I am seeking justice not only for myself but to ensure that no other customer faces this kind of wrongful denial of their own funds or discriminatory treatment in the future. I trust that the CFPB, state regulators, XXXX, and other authorities will take my experience seriously and investigate Santander Banks practices thoroughly. \n\nI have preserved evidence supporting every aspect of my account (including recorded phone calls with Santander customer service confirming my funds were available, and screenshots from my Santander online banking showing the deposit marked as available and later screenshots showing payment failures due to the restriction). I am ready to provide this evidence to investigators or attach it to this complaint as needed. Please let me know if any additional information is required. \n\nI respectfully ask for updates on the status of this complaint and the actions taken. I can be contacted at XXXX XXXX XXXX XXXX. I appreciate your time and prompt attention to my case, and I look forward to a resolution that addresses the wrongs committed by Santander Bank. \n\nSincerely, \n\n \n\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX","date_sent_to_company":"2025-03-07T14:15:39.000Z","issue":"Managing an account","sub_product":"Checking account","zip_code":"02121","tags":null,"has_narrative":true,"complaint_id":"12372986","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"SANTANDER HOLDINGS USA, INC.","date_received":"2025-03-07T13:55:34.000Z","state":"MA","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Funds not handled or disbursed as instructed"},"highlight":{"complaint_what_happened":["Prior to visiting the branches, my <em>account</em> was fully functional (as evidenced by the successful XXXX  transfer and other internal movements of <em>funds</em> I made that day). It <em>appears</em> that after I challenged the branch managers about my withdrawals, the bank (or the branch personnel) placed an unjustified freeze or hold on my <em>account</em> <em>without</em> notifying me."],"product":["Checking or savings <em>account</em>"],"issue":["Managing an <em>account</em>"],"sub_product":["Checking <em>account</em>"],"sub_issue":["<em>Funds</em> not handled or disbursed as instructed"]},"sort":[15.891235,"12372986"]},{"_index":"complaint-public-v1","_id":"19566699","_score":14.972137,"_source":{"product":"Debt or credit management","complaint_what_happened":"I enrolled with National Debt Relief ( XXXX ) after being told they would begin negotiating my credit card debt within approximately XXXX  days. Instead, my creditors went unpaid for over XXXX months while XXXX continued withdrawing money from my bank account. During this time, XXXX did not contact my creditors, did not notify them of my enrollment, and did not take any meaningful action on my accounts. \n\nBecause XXXX failed to notify my creditors, I received constant phone calls, emails, and threats of wage or asset garnishment. My accounts became severely delinquent, and my XXXX XXXX dropped below XXXX. XXXX also did not disclose that payments made to them are not reported to credit bureaus, meaning consumers receive no credit benefit while their accounts deteriorate. I specifically requested that XXXX pull my enrollment interview recordings because I felt that several key details including the fact that payments to XXXX do not help your credit were never disclosed to me. \n\nXXXX also created settlement proposals without my consent, including after I had already cancelled my enrollment. XXXX example : early on, I had given consent for XXXX to accept a small settlement offer from a minor creditor an offer I could have handled myself. XXXX took no action on that offer during my entire enrollment. However, after I cancelled the program, XXXX suddenly processed the payment to that creditor and attempted to count it as a completed settlement. When I contacted the creditor directly, they confirmed they would honor the agreement regardless and had no issue continuing it without NDRs involvement. \n\nDespite providing no legitimate service for over XXXX  days, XXXX attempted to charge me multiple fees, including {$9.00}, {$9.00}, and a proposal fee. When I disenrolled due to lack of performance, XXXX attempted to retain part of my funds, even though no settlements had been completed during my enrollment and no creditors had been paid until after cancellation. \n\nIn total, XXXX collected money from me while providing no measurable service, failing to communicate with creditors, damaging my credit, withholding material information during enrollment, and attempting to keep fees upon cancellation. Their advertising and sales practices do not match the actual experience, and consumers are not given full or accurate information about the consequences of enrollment. \n\nI am requesting a full refund of all fees and payments retained by XXXX, and I am reporting these practices because they appear deceptive, misleading, and harmful to consumers.","date_sent_to_company":"2026-02-17T20:31:20.000Z","issue":"Confusing or misleading advertising or marketing","sub_product":"Debt settlement","zip_code":"33063","tags":null,"has_narrative":true,"complaint_id":"19566699","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"NATIONAL DEBT RELIEF LLC","date_received":"2026-02-17T20:22:28.000Z","state":"FL","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["I am requesting a full refund of all fees and payments retained by XXXX, and I am reporting these practices <em>because</em> they <em>appear</em> <em>deceptive</em>, misleading, and harmful to consumers."]},"sort":[14.972137,"19566699"]},{"_index":"complaint-public-v1","_id":"17802435","_score":14.558482,"_source":{"product":"Payday loan, title loan, personal loan, or advance loan","complaint_what_happened":"Summary of the issue : I have a personal loan originally facilitated through XXXX but serviced by a third-party lender ( XXXX XXXX ). I requested a payoff letter because I intended to pay off the loan in full. After paying the amount listed on the payoff letter, XXXX later claimed I still owed an additional fee. They stated it was an insufficient funds fee or possibly interest but this amount was not included in the payoff letter, and I was never notified of any additional charges. The company also attempted to charge an old card on file, without authorization, long after the payoff. \n\nWhat happened : Because the loan was through a third-party lender, I had difficulty finding any customer support through their portal. All communication has been conducted through XXXX and XXXX XXXX representatives. \n\nI requested a payoff letter and was provided XXXX. I paid the full balance listed in that payoff letter. After this, XXXX XXXX claimed there was an additional fee, which they alternately described as an insufficient funds fee or interest. This alleged fee is tied to a payment attempt made months after the loan was already paid off, using what appears to be an outdated card on file. I never authorized this attempt, and I never received any notice that they tried to withdraw funds or that a fee was added. \n\nWhen I first asked about this while requesting the payoff letter, the representative did not mention any additional amounts owed. The payoff letter was presented as the full and accurate amount required to bring the loan to zero. Now, WPM Servicing is treating this amount as a separate, valid charge, even though : -It was not included in the payoff letter -I received no notice of any additional charges -I never authorized a subsequent payment attempt -The attempt seems to have been made to an old or inactive card -This occurred long after the balance had been paid After discovering this erroneous fee, I contacted XXXX XXXX several times. Every representative told me the issue would be fixed within XXXX hours, but the account has never been corrected. Several representatives stated they did not have the accessibility or authority to resolve the issue. When I requested a supervisor, I was repeatedly told that no supervisor was available and that I would receive a call-back a call that never came. \n\nDuring my most recent call, I was again told the same XXXX hour timeline, and I was prompted to make a payment toward this incorrect balance before the company corrected its own mistake. \n\nWhy this is a problem : XXXX XXXX has : -Added a fee or interest amount after payoff -Failed to include this amount in the official payoff letter -Attempted to charge an old, possibly inactive card without authorization -Provided no notification of the attempted charge or resulting fee -Presented contradictory explanations ( interest vs. insufficient funds fee ) -Continued to treat the amount as valid despite being improperly added -Provided false or misleading XXXX hour resolution promises -Failed to escalate the issue to a supervisor despite multiple requests -Pressured me to pay an incorrect and undocumented balance -This behavior is improper, deceptive, and violates payoff accuracy standards. \n\nWhat I have done to try to resolve it : -Requested and paid the full amount listed on the payoff letter -Contacted XXXX XXXX at least XXXX times -Discussed the issue with the representative when requesting the payoff letter -Asked for supervisor escalation multiple times but never received a call-back -Received repeated but unfulfilled promises of resolution within XXXX hours -Still have received no written correction or clarification -Continue to see the erroneous fee on the account","date_sent_to_company":"2025-11-21T21:49:19.000Z","issue":"Charged fees or interest you didn't expect","sub_product":"Installment loan","zip_code":"28303","tags":null,"has_narrative":true,"complaint_id":"17802435","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Westlake Services, LLC","date_received":"2025-11-21T21:26:53.000Z","state":"NC","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["This alleged fee is tied to a payment attempt made months after the loan was already paid off, using what <em>appears</em> to be an outdated card on file. I never authorized this attempt, and I never received any notice that they tried to <em>withdraw</em> <em>funds</em> or that a fee was added. \n\nWhen I first asked about this while requesting the payoff letter, the representative did not mention any additional amounts owed."]},"sort":[14.558482,"17802435"]},{"_index":"complaint-public-v1","_id":"16189211","_score":14.5413885,"_source":{"product":"Debt collection","complaint_what_happened":"On or about XX/XX/XXXX, I was admitted into XXXX XXXX and rushed to begin classes after the semester had already commenced on XX/XX/XXXX. I was not afforded the same opportunity as other students to begin on the official start date. Within three days of my enrollment, on XX/XX/XXXX, I withdrew from the program after consulting with the director, who advised me to do so due to the academic disadvantage caused by my late start. \n\nAt the time of enrollment, XXXX XXXX represented that tuition would be covered through a XXXX grant and Post-9/11 GI Bill benefits. I would not have been permitted to begin classes without proof of tuition assistance or financial means. Therefore, I never personally owed tuition beyond the non-refundable {$50.00} application fee. \n\nPursuant to XXXX XXXX own refund policy, students who withdraw within XXXX ( XXXX ) calendar days of enrollment are entitled to a 100 % refund of tuition and fees, less the non-refundable application fee. I withdrew within three days of my start date, but XXXX XXXX failed to properly honor this refund policy. \n\nFrom XX/XX/XXXX until XX/XX/XXXX, I was never notified of any outstanding balance. My phone number and email address have remained unchanged since that time. I received no invoices, statements, ledgers, or collection notices from XXXX XXXX during this three-year period. \n\nIn XX/XX/XXXX, I was contacted by SIMM Associates, who alleged that I owed {$2500.00} and further claimed that it appears I was making payments as recently as XX/XX/XXXX. This is false. I never made, nor authorized, any payments toward this account. If payments were in fact posted, then the source of those funds must be disclosed, as unauthorized application of VA benefits or XXXX funds would constitute a misuse of federal or state funds. \n\nWhen I requested validation of the debt, XXXX XXXX failed to provide complete records. They only produced an enrollment agreement and a ledger I had never previously received. I was never provided a student handbook despite their attempt to cite handbook policies against me. They have also claimed that I communicated with an individual named XXXX, yet they have failed to provide proof of any such communication, because none occurred. \n\nThis matter constitutes an unfair, deceptive, and abusive practice in violation of consumer protection laws. I have documentary proof of my acceptance letter, tuition plan showing {$0.00} personal balance due, and my withdrawal within the allowable timeframe. The sudden appearance of a ledger and the initiation of debt collection three years later, without any prior notice, is unjust, misleading, and damaging to my credit. \n\nTo further illustrate the misleading information, my enrollment agreement reflects my electronic signature dated XX/XX/XXXX via XXXX, yet it lists a start date of XX/XX/XXXX. In reality, I did not begin until XX/XX/XXXX. See attached.","date_sent_to_company":"2025-10-23T13:15:39.000Z","issue":"Written notification about debt","sub_product":"Private student loan debt","zip_code":"33409","tags":"Servicemember","has_narrative":true,"complaint_id":"16189211","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"SIMM Associates, Inc.","date_received":"2025-09-25T05:28:26.000Z","state":"FL","company_public_response":null,"sub_issue":"Didn't receive notice of right to dispute"},"highlight":{"complaint_what_happened":["In XX/XX/XXXX, I was contacted by SIMM Associates, who alleged that I owed {$2500.00} and further claimed that it <em>appears</em> I was making payments as recently as XX/XX/XXXX. This is false. I never made, nor authorized, any payments toward this <em>account</em>. If payments were in fact posted, then the source of those <em>funds</em> must be disclosed, as unauthorized application of VA benefits or XXXX <em>funds</em> would constitute a misuse of federal or state <em>funds</em>."]},"sort":[14.5413885,"16189211"]},{"_index":"complaint-public-v1","_id":"10936344","_score":14.046961,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"XXXX Payment System : Misrepresentation and Lack of Oversight, Constructive Fraud or Coercion, Contribution to Malpractice : GreenSkys deceptive practices are central to the harm I have endured, particularly its flawed shopping pass system. This system enables service providers to have unrestricted access to funds without borrower oversight, resulting in significant consumer harm. \nXXXX. Misrepresentation of Payment Activation : XXXX pressured me to confirm that services were complete on XX/XX/XXXX, the date of my initial consultation where no substantial services were rendered. This misrepresentation allowed them to bypass ethical and financial safeguards meant to ensure that payments align with service completion.\n\n2. Lack of Borrower Control : The Shopping Pass financing method does not provide borrowers with direct access to funds, effectively removing consumer oversight. Providers can access full payment prematurely without accountability, as occurred in my case.\n\n3. Contribution to Provider Malpractice : By allowing the provider to receive full payment before rendering services, XXXX enabled unethical behavior. The provider exploited XXXX XXXX XXXX XXXX clause to falsely bill for high-priced veneers before completing essential preparatory steps, such as teeth molding and Necessary oral X-rays combined with mandatory compressions of existing teeth structure. This malpractice caused irreversible harm, a situation XXXX system should have prevented through basic oversight. \nXXXX. Violations of XXXX Own Terms GreenSkys agreement states : We XXXX close your purchase window earlier if we determine that your treatment/service is substantially complete. \nHowever, XXXX closed my purchase window on XX/XX/XXXX, the day of my consultation. Chargeable Services were not completed until XXXX months later, this is all according to the XXXX XXXX provided to XXXX from the Provider  XXXX XXXX failed to ensure compliance with its terms, facilitating the providers malpractice. \nXXXX terms stated : That I could allocate funds incrementally based on service completion. By allowing the provider to withdraw the full amount on the first visit, XXXX violated its own terms and denied me the ability to manage the funds responsibly. \n\nXXXX Historical Consumer Violations In addition to XXXX XXXX 's XXXX {$2.00} XXXX settlement with the CFPB and the XXXX {$9.00} XXXX FTC settlement for unauthorized loans, XXXX faced another settlement in XXXX. Specifically, XXXX paid {$11.00} XXXX to resolve issues related to its loan practices. Over several years, these payments were part of broader enforcement actions against the company for failing to obtain proper loan authorizations, misleading consumers, and lack of oversight blatantly violating consumer protection laws. \n\nThese cases highlight a systemic issue with XXXX practices, leaving consumers vulnerable to harm.\n\nNegligence by Credit Reporting Agencies Credit bureaus further compounded this issue through negligence : Despite my disputes, with the credit reporting agencies, they accepted GreenSkys claims without meaningful verification, they stated via notifications to me after my initial CFPB complaint : The account was verified by XXXX because XXXX said it was accurate. \n\nThis business as usual approach disregards the Fair Credit Reporting Act ( FCRA ), which requires bureaus to maintain reasonable procedures for ensuring reporting accuracy. \nFailure of XXXX to Update Ownership Information with Credit bureaus, XXXX was sold in XX/XX/XXXX to XXXX XXXX, XXXX, XXXX XXXX XXXX, and XXXX. Under FCRA Section 1681i, new owners must update account information with credit bureaus. However, my credit report still lists GreenSky as the account owner, in violation of FCRA Sections 1681s-2 ( a ) and 1681e ( b ).\n\nRelevant Legal Violations 1. FCRA Section 1681s-2 ( a ) : Obligation to report accurate information.\n\n2. FCRA Section 1681i : Duty to promptly investigate disputes.\n\n3. FCRA Section 1681e ( b ) : Duty to ensure accurate reporting.\n\n4. Truth in Lending Act ( TILA ) : Failure to enforce ethical payment procedures. \nXXXX does not possess a signed agreementneither a wet signature nor an authenticated electronic signaturefrom me accepting any financing according to my records and documents in the XXXX portal that will not show my signature. \nAdditionally, I did not consent or authorize the premature disbursement of funds to Dentist provider for services that were neither started nor completed. The link I received to confirm services appears to have been used improperly to process payment, further violating my rights as the borrower. \nWithout a valid, signed agreement, XXXX has no legal basis to hold me liable for this debt. \n\n\nThe email stated that I had the option to Accept or Reject the withdrawal or click a link to confirm completion of services. However, the only actionable option was to click the link for completion of services, which effectively forced me to prematurely authorize the full withdrawal without proper consent. And thrust me into immediate debt for services not rendered. Once XXXX was in receipt of the patient ledger, given to them by the provider, they intentionally ignored the unethical behavior that led to Malpractice with their client that paid me under a Mutual Agreement. However, if proper oversight was in place to identify red flags of the providers financial abuse, which left me in harm 's way. The irreversible circumstances wouldnt be the same nor the amount owed would be a factor if responsible incremental payments were released. For this, my consumer protection rights were disregarded.\n\nAuthorization by the Borrower : The provider must obtain my explicit approval to withdraw funds. This typically involves : My signature on an agreement or payment authorization form.\n\nDocumentation or verification that services have been rendered as agreed.\n\n2. Itemized Invoice or Service Confirmation : The provider should present a detailed breakdown of services completed and their costs before withdrawing funds.\n\nIf the agreement allows incremental disbursements, the provider should only request payment for services already provided.\n\n3. Compliance with Loan Terms : Providers must follow the terms of the loan agreement, which may require : Payment only for completed services.\n\nVerification through a third-party platform or financial institution.","date_sent_to_company":"2024-11-26T18:01:32.000Z","issue":"Problem with a company's investigation into an existing problem","sub_product":"Credit reporting","zip_code":"07017","tags":"Servicemember","has_narrative":true,"complaint_id":"10936344","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"EQUIFAX, INC.","date_received":"2024-11-26T17:27:31.000Z","state":"NJ","company_public_response":null,"sub_issue":"Their investigation did not fix an error on your report"},"highlight":{"complaint_what_happened":["Negligence by Credit Reporting Agencies Credit bureaus further compounded this issue through negligence : Despite my disputes, with the credit reporting agencies, they accepted GreenSkys claims <em>without</em> meaningful verification, they stated via notifications to me after my initial CFPB complaint : The <em>account</em> was verified by XXXX <em>because</em> XXXX said it was accurate."]},"sort":[14.046961,"10936344"]},{"_index":"complaint-public-v1","_id":"10937301","_score":14.036944,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"XXXX Payment System : Misrepresentation and Lack of Oversight, Constructive Fraud or Coercion, Contribution to Malpractice : XXXX deceptive practices are central to the harm I have endured, particularly its flawed shopping pass system. This system enables service providers to have unrestricted access to funds without borrower oversight, resulting in significant consumer harm. \n1. Misrepresentation of Payment Activation : XXXX pressured me to confirm that services were complete on XX/XX/XXXX, the date of my initial consultation where no substantial services were rendered. This misrepresentation allowed them to bypass ethical and financial safeguards meant to ensure that payments align with service completion.\n\n2. Lack of Borrower Control : The Shopping Pass financing method does not provide borrowers with direct access to funds, effectively removing consumer oversight. Providers can access full payment prematurely without accountability, as occurred in my case.\n\n3. Contribution to Provider Malpractice : By allowing the provider to receive full payment before rendering services, XXXX enabled unethical behavior. The provider exploited XXXX 30-day Service Completion clause to falsely bill for high-priced veneers before completing essential preparatory steps, such as teeth molding and Necessary XXXX XXXXXXXX combined with mandatory compressions of existing teeth structure. This malpractice caused irreversible harm, a situation XXXX system should have prevented through basic oversight. \n4. Violations of XXXX Own Terms XXXX agreement states : We may close your purchase window earlier if we determine that your treatment/service is substantially complete. \nHowever, XXXX closed my purchase window on XX/XX/XXXX, the day of my consultation. Chargeable Services were not completed until XXXXtwo months later, this is all according to the XXXX XXXX provided to XXXX from the Provider XXXX XXXX failed to ensure compliance with its terms, facilitating the providers malpractice. \nXXXX terms stated : That I could allocate funds incrementally based on service completion. By allowing the provider to withdraw the full amount on the first visit, XXXX violated its own terms and denied me the ability to manage the funds responsibly. \n\nXXXX Historical Consumer Violations In addition to XXXX XXXX XXXX XXXX {$2.00} XXXX settlement with the CFPB and the XXXX {$9.00} XXXX FTC settlement for unauthorized loans, XXXX faced another settlement in XXXX. Specifically, XXXX paid {$11.00} XXXX to resolve issues related to its loan practices. Over several years, these payments were part of broader enforcement actions against the company for failing to obtain proper loan authorizations, misleading consumers, and lack of oversight blatantly violating consumer protection laws. \n\nThese cases highlight a systemic issue with XXXX practices, leaving consumers vulnerable to harm. \nNegligence by Credit Reporting Agencies Credit bureaus further compounded this issue through negligence : Despite my disputes, with the credit reporting agencies, they accepted XXXX claims without meaningful verification, they stated via notifications to me after my initial CFPB complaint : The account was verified by XXXX because XXXX said it was accurate. \n\nThis business as usual approach disregards the Fair Credit Reporting Act ( FCRA ), which requires bureaus to maintain reasonable procedures for ensuring reporting accuracy. \nFailure of XXXX to Update Ownership Information with Credit bureaus, XXXX was sold in XX/XX/XXXX to XXXX XXXX, XXXX, XXXX XXXX XXXX, and XXXX. Under FCRA Section 1681i, new owners must update account information with credit bureaus. However, my credit report still lists XXXX as the account owner, in violation of FCRA Sections 1681s-2 ( a ) and 1681e ( b ).\n\nRelevant Legal Violations 1. FCRA Section 1681s-2 ( a ) : Obligation to report accurate information.\n\n2. FCRA Section 1681i : Duty to promptly investigate disputes.\n\n3. FCRA Section 1681e ( b ) : Duty to ensure accurate reporting.\n\n4. Truth in Lending Act ( TILA ) : Failure to enforce ethical payment procedures. \nXXXX does not possess a signed agreementneither a wet signature nor an authenticated electronic signaturefrom me accepting any financing according to my records and documents in the XXXX portal that will not show my signature. \nAdditionally, I did not consent or authorize the premature disbursement of funds to Dentist provider for services that were neither started nor completed. The link I received to confirm services appears to have been used improperly to process payment, further violating my rights as the borrower. \nWithout a valid, signed agreement, XXXX has no legal basis to hold me liable for this debt. \n\n\nThe email stated that I had the option to Accept or Reject the withdrawal or click a link to confirm completion of services. However, the only actionable option was to click the link for completion of services, which effectively forced me to prematurely authorize the full withdrawal without proper consent. And thrust me into immediate debt for services not rendered. Once XXXX was in receipt of the patient ledger, given to them by the provider, they intentionally ignored the unethical behavior that led to Malpractice with their client that paid me under a Mutual Agreement. However, if proper oversight was in place to identify red flags of the providers financial abuse, which left me in harm 's way. The irreversible circumstances wouldnt be the same nor the amount owed would be a factor if responsible incremental payments were released. For this, my consumer protection rights were disregarded. \n\nAuthorization by the Borrower : The provider must obtain my explicit approval to withdraw funds. This typically involves : My signature on an agreement or payment authorization form.\n\nDocumentation or verification that services have been rendered as agreed.\n\n2. Itemized Invoice or Service Confirmation : The provider should present a detailed breakdown of services completed and their costs before withdrawing funds.\n\nIf the agreement allows incremental disbursements, the provider should only request payment for services already provided.\n\n3. Compliance with Loan Terms : Providers must follow the terms of the loan agreement, which may require : Payment only for completed services.\n\nVerification through a third-party platform or financial institution.","date_sent_to_company":"2024-11-26T18:01:46.000Z","issue":"Problem with a company's investigation into an existing problem","sub_product":"Credit reporting","zip_code":"07017","tags":"Servicemember","has_narrative":true,"complaint_id":"10937301","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Experian Information Solutions Inc.","date_received":"2024-11-26T18:01:43.000Z","state":"NJ","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Their investigation did not fix an error on your report"},"highlight":{"complaint_what_happened":["Negligence by Credit Reporting Agencies Credit bureaus further compounded this issue through negligence : Despite my disputes, with the credit reporting agencies, they accepted XXXX claims <em>without</em> meaningful verification, they stated via notifications to me after my initial CFPB complaint : The <em>account</em> was verified by XXXX <em>because</em> XXXX said it was accurate."]},"sort":[14.036944,"10937301"]},{"_index":"complaint-public-v1","_id":"10937304","_score":14.035407,"_source":{"product":"Credit reporting or other personal consumer reports","complaint_what_happened":"XXXX Payment System : Misrepresentation and Lack of Oversight, Constructive Fraud or Coercion, Contribution to Malpractice : XXXX deceptive practices are central to the harm I have endured, particularly its flawed shopping pass system. This system enables service providers to have unrestricted access to funds without borrower oversight, resulting in significant consumer harm.\n\n1. Misrepresentation of Payment Activation : XXXX pressured me to confirm that services were complete on XX/XX/XXXX, the date of my initial consultation where no substantial services were rendered. This misrepresentation allowed them to bypass ethical and financial safeguards meant to ensure that payments align with service completion. \n\n\n2. Lack of Borrower Control : The Shopping Pass financing method does not provide borrowers with direct access to funds, effectively removing consumer oversight. Providers can access full payment prematurely without accountability, as occurred in my case.\n\n3. Contribution to Provider Malpractice : By allowing the provider to receive full payment before rendering services, XXXX enabled unethical behavior. The provider exploited XXXX 30-day Service Completion clause to falsely bill for high-priced veneers before completing essential preparatory steps, such as teeth molding and Necessary XXXX XXXX combined with mandatory compressions of existing teeth structure. This malpractice caused irreversible harm, a situation XXXX system should have prevented through basic oversight. \n4. Violations of XXXX Own Terms XXXX agreement states : We may close your purchase window earlier if we determine that your treatment/service is substantially complete. \nHowever, XXXX closed my purchase window on XX/XX/XXXX, the day of my consultation. Chargeable Services were not completed until XXXXtwo months later, this is all according to the XXXX XXXX provided to XXXX from the Provider XXXX XXXX failed to ensure compliance with its terms, facilitating the providers malpractice. \nXXXX terms stated : That I could allocate funds incrementally based on service completion. By allowing the provider to withdraw the full amount on the first visit, XXXX violated its own terms and denied me the ability to manage the funds responsibly. \n\nXXXX Historical Consumer Violations In addition to XXXX XXXX 's XXXX {$2.00} XXXX settlement with the CFPB and the XXXX {$9.00} XXXX FTC settlement for unauthorized loans, XXXX faced another settlement in XXXX. Specifically, XXXX paid {$11.00} XXXX to resolve issues related to its loan practices. Over several years, these payments were part of broader enforcement actions against the company for failing to obtain proper loan authorizations, misleading consumers, and lack of oversight blatantly violating consumer protection laws. \n\nThese cases highlight a systemic issue with XXXX practices, leaving consumers vulnerable to harm. \nNegligence by Credit Reporting Agencies Credit bureaus further compounded this issue through negligence : Despite my disputes, with the credit reporting agencies, they accepted XXXX claims without meaningful verification, they stated via notifications to me after my initial CFPB complaint : The account was verified by XXXX because XXXX said it was accurate. \n\nThis business as usual approach disregards the Fair Credit Reporting Act ( FCRA ), which requires bureaus to maintain reasonable procedures for ensuring reporting accuracy. \nFailure of XXXX to Update Ownership Information with Credit bureaus, XXXX was sold in XX/XX/XXXX to XXXX XXXX, XXXX, XXXX XXXX XXXX, and XXXX Under FCRA Section 1681i, new owners must update account information with credit bureaus. However, my credit report still lists XXXX as the account owner, in violation of FCRA Sections 1681s-2 ( a ) and 1681e ( b ).\n\nRelevant Legal Violations 1. FCRA Section 1681s-2 ( a ) : Obligation to report accurate information.\n\n2. FCRA Section 1681i : Duty to promptly investigate disputes.\n\n3. FCRA Section 1681e ( b ) : Duty to ensure accurate reporting.\n\n4. Truth in Lending Act ( TILA ) : Failure to enforce ethical payment procedures. \nXXXX does not possess a signed agreementneither a wet signature nor an authenticated electronic signaturefrom me accepting any financing according to my records and documents in the XXXX portal that will not show my signature. \nAdditionally, I did not consent or authorize the premature disbursement of funds to Dentist provider for services that were neither started nor completed. The link I received to confirm services appears to have been used improperly to process payment, further violating my rights as the borrower. \nWithout a valid, signed agreement, XXXX has no legal basis to hold me liable for this debt. \n\n\nThe email stated that I had the option to Accept or Reject the withdrawal or click a link to confirm completion of services. However, the only actionable option was to click the link for completion of services, which effectively forced me to prematurely authorize the full withdrawal without proper consent. And thrust me into immediate debt for services not rendered. Once XXXX was in receipt of the patient ledger, given to them by the provider, they intentionally ignored the unethical behavior that led to Malpractice with their client that paid me under a Mutual Agreement. However, if proper oversight was in place to identify red flags of the providers financial abuse, which left me in harm 's way. The irreversible circumstances wouldnt be the same nor the amount owed would be a factor if responsible incremental payments were released. For this, my consumer protection rights were disregarded. \n\nAuthorization by the Borrower : The provider must obtain my explicit approval to withdraw funds. This typically involves : My signature on an agreement or payment authorization form. \nDocumentation or verification that services have been rendered as agreed. \n2. Itemized Invoice or Service Confirmation : The provider should present a detailed breakdown of services completed and their costs before withdrawing funds.\n\nIf the agreement allows incremental disbursements, the provider should only request payment for services already provided.\n\n3. Compliance with Loan Terms : Providers must follow the terms of the loan agreement, which may require : Payment only for completed services.\n\nVerification through a third-party platform or financial institution.","date_sent_to_company":"2024-11-26T18:01:46.000Z","issue":"Problem with a company's investigation into an existing problem","sub_product":"Credit reporting","zip_code":"07017","tags":"Servicemember","has_narrative":true,"complaint_id":"10937304","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"TRANSUNION INTERMEDIATE HOLDINGS, INC.","date_received":"2024-11-26T18:01:43.000Z","state":"NJ","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Their investigation did not fix an error on your report"},"highlight":{"complaint_what_happened":["Negligence by Credit Reporting Agencies Credit bureaus further compounded this issue through negligence : Despite my disputes, with the credit reporting agencies, they accepted XXXX claims <em>without</em> meaningful verification, they stated via notifications to me after my initial CFPB complaint : The <em>account</em> was verified by XXXX <em>because</em> XXXX said it was accurate."]},"sort":[14.035407,"10937304"]},{"_index":"complaint-public-v1","_id":"17895412","_score":13.920589,"_source":{"product":"Checking or savings account","complaint_what_happened":"Complainant : XXXX XXXX XXXX : Huntington Bank Subject : Misclassification of fraud-induced transfers ; failure to apply EFTA / Reg E ; refusal to investigate new evidence ; improper denial of reimbursement ; bank instructing customer to work with scammers I. Introduction and Overview I am filing this complaint because Huntington Bank has repeatedly refused to properly investigate a fraud-related loss involving a deceptive online job scam. Instead of treating the situation as a fraud-induced unauthorized electronic fund transfer ( EFT ) under the Electronic Fund Transfer Act ( EFTA ) and Regulation E, the bank incorrectly labeled the case as a merchant dispute, closed the case without evaluating new evidence, and told me repeatedly that I authorized the transfers even though I was induced to make them through misrepresentation, deception, and illegal instructions from scammers. \n\nBoth XXXX and XXXX, who acted only as payment intermediaries, concluded their own investigations and confirmed that the funds were transferred to a scam XXXX  address and are irretrievable. The actual recipient was not XXXX nor XXXX, but a fraudulent organization posing as XXXX XXXX, which impersonated a legitimate XXXX XXXX  company. \n\nBecause Huntington refuses to reclassify the dispute under EFTA despite the evidence, I am seeking CFPB assistance to require a lawful review.\n\nII. How the Fraud Occurred 1. I was recruited into a fraudulent remote job scheme I responded to what I believed was a legitimate remote position connected to XXXX ( a real company, but this was an impersonation scam ). The scammers presented the opportunity as a paid online review job where I would : complete review tasks to earn compensation, deposit my own funds into a company working account, and withdraw my funds ( plus compensation ) after tasks were completed. \n\nI was repeatedly assured by the scammers that all deposited funds remained my own, stored in my working account, and that I could withdraw them at any time.\n\n2. The job turned out to involve illegal activities Through multiple screenshots, I demonstrated : I was instructed to write fake positive reviews for destinations I have never been to. \nI was told workers provide positive reviews to enhance popularity. \nWhen I questioned the legality ( FTC violation ), the scammers refused to answer and told me to complete the tasks. \nWhen I filed a police report, my mentor disappeared from the chat group entirely. \n\nBecause I hold a XXXX XXXX, I can not engage in illegal activity or any job involving counterfeit endorsements.\n\nIII. The Funds Transfer Process The scammers required me to move funds in the following forced sequence : 1. Deposit money into my bank account and send it to XXXX. \n2. Convert funds inside XXXX to XXXX. \n3. Transfer the XXXX  to XXXX. \n4. Send the XXXX  to a XXXX working address provided only by the scammers. \n\nI had no access to any final receiving wallet. The scammers controlled the endpoint. \n\n4. I attempted to withdraw my funds Once my internal XXXX balance appeared positive, withdrawal was denied, and I was told I could not access my funds unless I : added more money, and completed additional tasks ( which were illegal paid reviews ). \n\nScreenshots show support repeatedly dodging legality questions and urging me to send more deposits. \n\nThis matches the DOJ definition of a progressive deposit scam. \n\n\n\nIV. Confirmation From XXXX XXXX XXXX Both entities completed investigations showing : the funds were transferred fully out of my wallets, I no longer have access to them, the receiving address belongs to a scammer, and no funds remain with XXXX  or XXXX. \n\nBoth stated the funds are considered stolen and irrecoverable. \n\nThis proves unequivocally that the final transfer was to a scammer not a merchant. \n\n\n\nV. Huntington Banks Mishandling of the Case 1. The bank repeatedly misclassified this as merchant dispute Despite providing : police reports, screenshots, confirmations from the XXXX  services, and evidence of deception and coerced transfers, Huntington classified the claim as : Cardholder willingly sent funds This is a merchant dispute. \n\nThis is factually and legally incorrect. \n\n2. Huntington refused to review new evidence On a recorded call, Huntington stated : The case is already reviewed for accuracy. \nNo new information will change the decision. \n\nDespite the fact that I did submit significant new information. \n\n3. The bank told me I needed to work with the merchant The representative read from the investigators notes : We encourage you to contact the merchant directly to resolve the issue. \n\nThe merchant in this case is the scammer who already stole my funds and requires me to commit further illegal acts to pursue retrieval. \n\nWhen I explained this, the representative stated : That is what the investigators are saying you need to do. \n\nThis placed me in the impossible position of being told by my bank to interact with criminals. \n\n\n\nVI. Required Legal Analysis Under EFTA / Reg E CFPBs own FAQ and supervisory guidance establish that : 1. Fraud-induced transfers are NOT authorized.\n\nCFPB : Fraud or coercion that causes a consumer to initiate a transfer does not make the transfer authorized.\n\n2. Authorization requires valid intent and understanding.\n\nScammers misrepresented the purpose of the transfers, making any authorization invalid.\n\n3. Negligence can not be used to impose liability on the consumer. \nCFPB : Negligence by the consumer can not be used as the basis for liability. \n4. Banks must investigate using ALL available evidence.\n\nHuntington closed the case while refusing to review new evidence. \n5. XXXX scams fall under Reg E when banks fail to prevent or properly classify unauthorized transfers. \n\nBecause I was deceived into believing the funds were going into my own working account and would be fully retrievable, I did NOT authorize transfers to a scammer.\n\nVII. Harm Suffered Significant financial loss Emotional distress due to being told to work further with criminals Risk to my professional license if I engage in illegal review activity Loss of trust in my bank Ongoing fear of retaliation or further scam contact VIII. What I Am Requesting from CFPB I respectfully request that the CFPB require Huntington Bank to : 1. Reopen my dispute under the correct legal standard ( fraud-induced unauthorized EFT ).\n\n2. Review all evidence submitted, including police reports, chats, crypto tracing information, and screenshots.\n\n3. Provide reimbursement as required under EFTA / Reg E, since I did not authorize transfers to the actual recipient. \n4. Explain why the bank repeatedly closed the case without investigating new evidence.\n\n5. Cease instructing me to interact with scammers in order to retrieve funds.\n\nIX. Conclusion This situation falls squarely within the protections of the Electronic Fund Transfer Act. I initiated these transfers only because I was misled by criminals posing as a legitimate employer. The banks refusal to apply Reg E violates CFPB guidance and leaves me without recourse. \n\nI request immediate regulatory intervention. \n\nBelow is a complete list of the deposits I was induced to make as part of the fraud scheme. These were not payments for goods or services ; they were deposits the scammers told me were going into my internal working account under the false promise of full withdrawal and compensation. These transfers ultimately went to a fraudulent crypto address controlled by scammers impersonating a legitimate employer. \n\nXX/XX/year> {$550.00} Deposited USD ( from XXXX ) XX/XX/year> XXXX XXXX  ( valued at {$850.00} ) Deposited from XXXX XXXX XX/XX/year> {$760.00} Deposited USD ( # XXXX ) {$5400.00} Deposited USD ( # XXXX ) {$4500.00} Deposited USD ( from XXXX XXXX ) XX/XX/year> {$150.00} Deposited USD ( XXXX XXXX ) {$200.00} Deposited USD ( XXXX XXXX  ) {$150.00} Deposited USD ( XXXX XXXX ) {$2900.00} Deposited USD ( XXXX XXXX ) {$600.00} Deposited USD ( XXXX ) {$600.00} Deposited USD ( XXXX ) {$500.00} Deposited USD ( XXXX XXXX ) {$600.00} Deposited USD ( XXXX ) {$400.00} Deposited USD ( XXXX XXXX  ) XX/XX/year> {$1700.00} Deposited USD ( XXXX XXXX ) {$600.00} Deposited USD ( XXXX ) {$500.00} Deposited USD ( XXXX XXXX ) {$600.00} Deposited USD ( XXXX ) {$400.00} Deposited USD ( XXXX XXXX ) XXXX Deposits ( Converted & forwarded per scammers instructions ) XXXX XXXX ( valued at {$240.00} ) Deposited from XXXX XXXX XXXX XXXX ( valued at {$260.00} ) Deposited via XXXX XXXX  These deposits represent the full sequence of funds I was manipulated into sending through XXXX XXXX XXXX to an external wallet belonging to the scammer. XXXX and XXXX have confirmed the funds are no longer in my possession and were transferred out to a fraudulent address. None of these transfers were authorized to the true recipient, making them fraud-induced unauthorized electronic fund transfers under the Electronic Fund Transfer Act ( EFTA / Reg E ).","date_sent_to_company":"2025-11-25T02:48:35.000Z","issue":"Managing an account","sub_product":"Checking account","zip_code":"44136","tags":"Servicemember","has_narrative":true,"complaint_id":"17895412","timely":"Yes","company_response":"Closed with monetary relief","submitted_via":"Web","company":"HUNTINGTON NATIONAL BANK, THE","date_received":"2025-11-25T02:29:28.000Z","state":"OH","company_public_response":null,"sub_issue":"Problem using a debit or ATM card"},"highlight":{"complaint_what_happened":["The scammers presented the opportunity as a paid online review job where I would : complete review tasks to earn compensation, deposit my own <em>funds</em> into a company working <em>account</em>, and <em>withdraw</em> my <em>funds</em> ( plus compensation ) after tasks were completed. \n\nI was repeatedly assured by the scammers that all deposited <em>funds</em> remained my own, stored in my working <em>account</em>, and that I could <em>withdraw</em> them at any time.\n\n2."],"product":["Checking or savings <em>account</em>"],"issue":["Managing an <em>account</em>"],"sub_product":["Checking <em>account</em>"]},"sort":[13.920589,"17895412"]},{"_index":"complaint-public-v1","_id":"10106655","_score":13.58657,"_source":{"product":"Credit card","complaint_what_happened":"I, XXXX XXXX XXXX, am a customer/consumer as defined under 12 CFR 1006.2 ( e ), and I hold both a trust account and a credit card account with Navy Federal Credit Union XXXX I previously maintained a business relationship with Navy Federal, but I chose to close the business account due to unauthorized withdrawals by Navy Federal.\n\nSince the closure of that account, Navy Federal has continued to withdraw funds from my personal account. I intend to cease business dealings under these circumstances unless the issue reported herein is resolved. Navy Federal is classified as a debt collector under 12 CFR 1006.2 ( i ) and 15 USC 1692a ( 6 ) and ( f ), and it continues to attempt to collect an alleged debt from a credit card account that was opened on XX/XX/XXXX. \nIt appears that Navy Federal used my credit card information to obtain credit using my Social Security number without my consent, as outlined in 15 USC 1602 ( l ). I initially believed this was a routine credit check, but it seems it was intended to mislead me into an alleged contract or agreement. The contract, which is purported to be a promissory note under CFR 674.31, was never signed by me, as I do not recall encountering a signature page online during the agreement process. To my knowledge, no such signature page was provided or signed by me, other than those associated with my Social Security card and passport/ID. \nIn XX/XX/XXXX, I requested a full ledger detailing how funds were deposited, in accordance with GAAP and FAS standards. Navy Federal responded with three bills= ( bills of exchange ), statements= ( explanations ), and a copy of the contract/agreement, which did not meet the requested documentation requirements. A valid contract requires mutual agreement ( a meeting of the minds, capacity, legality offer and acceptance and the failure to provide the requested documentation constitutes a breach of the agreement.\n\nAdditionally, I requested that Navy Federal place the account into billing error status as per 15 USC 1666, cease collection efforts, and correspond solely through written communication until the issue was resolved. Navy Federal refused to comply, continued to withdraw funds from my account, and persisted in collection attempts even after I disconnected all associated email and phone numbers. They subsequently attempted to collect from my trust account, although they were unable to access it, and sent a letter stating it had a negative balance, when indeed there is always funds in the Trust, I just never authorized it, and why did Navy Federal try, not to mention the negative reporting remarks showing two credit card accounts when theres only one, and recently removed remarks from the credit report when I sent a remittance according to 31 CFR 328.5 written on behalf of my trust, on XX/XX/XXXX. Every account updated including NAVY FEDERAL afterwards. ( Exhibit Included ) To add, NAVY FEDERAL was also a part of a home that I tried purchasing last year. They, however, were not told about the home by me, but I found on my tax documents that they were listed as the payer to purchase the home that I acquired through my trust as an investment property to pass down through the trust to my children. I just so happened to look at my transcript in XXXX and noticed that the home was purchased by me through NAVY FEDERAL, but I dont live in it. How can that be? I am seeking arbitration for misleading and deceptive practices, because Navy Federal withheld vital information which should clearly have been disclosed to me according to 12 CFR 1026.17, rather it was credit card or the home purchase. Especially for {$790000.00} that I had no knowledge of, nor had in the bank for that amount, that I feel my promissory note was used to purchase the home that I do not live in. \n\nI am also seeking to rescind the contract, in which I have sent documents to amend the contract that, to my knowledge, still has not been updated, as requested. I never received a right to rescind a contract, nor did I know I had the right to do so, The Truth in Lending Act requires full disclosure of contracts, and being that it was done online, the contract was not fully disclosed. \nIn conclusion, I have made extensive efforts to resolve the issues with Navy Federal, including submitting bills of exchange, remittance payments, checks, and money orders, to both locations in Virginia of XXXX and XXXX. Specifically, a money order meeting the requirements of the Bills of Exchange Act for {$11000.00} was cashed in XXXX, while two others were retained ( Exhibit attached ), leaving the account status unchanged. All documents submitted were notarized.\n\nAdditionally, a final money order was returned with a claim of alteration, despite a similar money order being cashed earlier in XXXX mentioned above. NAVY FEDERAL instructed me to correct and resubmit the money order, which I did for more the next time so it wouldnt be late, but it was returned once again. This inconsistency is perplexing and raises questions about why one money order was accepted while the other was not. I am overwhelmed by the lack of communication and unnecessary spending that it has cost me and taking from my family. \nThe Federal Reserve Act says lawful money should be used for debt payments, and the use of Federal Reserve Notes in this context appears to be in violation. \nGiven the breaches of duty and violations encountered, I am seeking restitution for misleading and deceptive practices along with damages to my credit and harm to my mental capacity this is also to recoup all funds deposited into this account since its inception and for the funds necessary to purchase the home intended for my children. I have consistently made timely payments to Navy Federal for the past four years, with no late payments until the recent issues arose following the discovery of truth in lending discrepancies, and the necessary documents requested to be sent to me as promised. \nAttached are all relevant exhibits including recordings for your review. I request prompt resolution of these matters and look forward to your response. Due to some files being too large they were not able to be submitted. But I'm willing to send whatever needed by all means necessary including phone call conversations admitting to sending me requested documents I asked for. \n\nXXXX XXXX XXXX? XXXX & XXXX","date_sent_to_company":"2024-09-12T22:27:37.000Z","issue":"Other features, terms, or problems","sub_product":"General-purpose credit card or charge card","zip_code":"76502","tags":null,"has_narrative":true,"complaint_id":"10106655","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"NAVY FEDERAL CREDIT UNION","date_received":"2024-09-12T21:40:31.000Z","state":"TX","company_public_response":"Company believes it acted appropriately as authorized by contract or law","sub_issue":"Other problem"},"highlight":{"complaint_what_happened":["I, XXXX XXXX XXXX, am a customer/consumer as defined under 12 CFR 1006.2 ( e ), and I hold both a trust <em>account</em> and a credit card <em>account</em> with Navy Federal Credit Union XXXX I previously maintained a business relationship with Navy Federal, but I chose to close the business <em>account</em> due to unauthorized withdrawals by Navy Federal.\n\nSince the closure of that <em>account</em>, Navy Federal has continued to <em>withdraw</em> <em>funds</em> from my personal <em>account</em>."]},"sort":[13.58657,"10106655"]},{"_index":"complaint-public-v1","_id":"17840240","_score":13.395876,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"Dear CFPB Case Officer, I am writing to file a formal complaint against Crypto.com, a digital asset service provider operating in the United States and servicing U.S. consumers, for unfair, deceptive, and abusive acts and practices ( UDAAP ) under the Consumer Financial Protection Act. Their actions have resulted in a significant financial loss, the restriction of my account without justification, the withholding of my own funds, and a refusal to provide mandatory disclosures and support records. \nThis complaint concerns a transaction involving {$75000.00} USD, which Crypto.com has refused to restore after preventing me from completing the transaction for which the conversion was made. \nXXXX. Summary of the Issue I deposited {$75000.00} USD into my Crypto.com account via wire transfer. \nI converted it to USDT for the sole purpose of performing an external crypto transfer for futures trading, which was fully allowed on my account at the time. \nCrypto.com permitted the conversion and charged spreads/fees up to approximately {$2300.00}. \nImmediately after the conversion and external wallet transfer, Crypto.com restricted all external crypto transfers on my account without explanation, preventing me from using the USDT for its intended purpose. I need to not that this wan not my first time neither my XXXX time carrying out same transaction. \nWhen I requested reversal of the conversion ( since the transaction could not be completed ), Crypto.com refused. They said I can only make cash withdrawals which requires me to convert back to usd with another potential loss of approx. {$2300.00} As a result, I am being forced to accept a XXXX XXXXXXXX financial loss due to spreads charged on a transaction Crypto.com prevented me from completing. \nXXXX. Concerning Account Restriction Without Explanation Crypto.com claims that my account underwent a routine review, but : They did not identify any specific compliance issue. \nThey did not cite any applicable law requiring the restriction. \nThey did not request any additional XXXX  documentation XXXX \nThey did not provide any remediation steps or appeal process. \nThey claim the decision is final, which is contrary to due process in financial services. \nThis constitutes an unfair practice, as the restriction was applied after they allowed the transaction and charged the associated costs. \nXXXX. Financial Harm Resulting From Their Actions Because the conversion was made solely to allow a withdrawal ( which they later blocked ), I am potentially left with : Over {$5300.00} in losses caused entirely by Crypto.coms unilateral restriction. \nNo access to the service that justified the conversion. \nNo ability to reverse the transaction. \nNo explanation for why my asset withdrawal function are restricted. \nCrypto.com effectively charged me for a service they prevented me from using. \nThis resembles unfair retention of consumer funds, a form of UDAAP violation. \nXXXX. Misrepresentation of Pricing and Spread Practices Crypto.com claims the discrepancy in my exchange value is due to market spreads, but : Their execution price differed materially from widely recognized market rates. \nThey refused to show the exact spread or fee breakdown. \nTheir pricing practices appear opaque and potentially misleading. \nThey avoided addressing why the spread was significantly higher than market norms. \nThis lack of transparency raises concerns regarding misleading pricing, improper disclosure, and deceptive practices. \nXXXX. Refusal to Provide Support Transcript During an in-app support conversation, I clearly explained to Crypto.com that : I was converting USD to USDT only to execute an external transfer, and that the transfer was necessary because Crypto.com does not provide futures trading. \nI repeatedly asked for a transcript of this chat, but : Crypto.com refused, and abruptly closed the chat instead of providing the record. \nThis refusal obstructs my ability to document the issue and further raises concerns regarding transparency and accountability. \nXXXX. Crypto.coms Final Decision Statement Crypto.com has stated that : The restriction is final, No appeal or escalation is available, And they will not reverse the conversion or refund the lost amount. \nThis is inconsistent with standard financial service obligations to provide : an internal review mechanism, a path for reconsideration, and a transparent justification. \nXXXX. Consumer Protection and UDAAP Grounds Crypto.coms actions constitute potential violations of the Consumer Financial Protection Act due to : Unfair Practices Causing financial harm that the consumer can not reasonably avoid. \nRestricting services after allowing the transaction that incurred loss. \nRetaining value derived from an uncompleted service. \nDeceptive Practices Presenting conversion and transfer capabilities as available when they were later removed. \nMisrepresenting pricing mechanisms or refusing to provide spread data. \nAbusive Practices Exploiting asymmetry of information. \nPreventing the consumer from accessing their own assets. \nRefusing transparency or documentation of support interactions. \nXXXX. Requested Relief I respectfully request that the CFPB assist in compelling Crypto.com to : XXXX. Reverse the USD - USDT conversion at the original value, restoring my full {$75000.00} USD. \nXXXX. Allow immediate withdrawal of my funds to my verified bank account. \nXXXX. Provide the transcript of my in-app support conversation. \nXXXX. Provide a written explanation of the specific policy or law used to justify the restriction. \nXXXX. Disclose all internal review notes related to the decision to restrict my account. \nI am not requesting the restoration of my crypto transfer capability, only the fair return of my original funds and the ability to withdraw them. \nXXXX. Supporting Documentation I am prepared to provide : Screenshots of relevant app screens Email correspondence with Crypto.com Transaction details Timeline of events Any additional documentation the CFPB requires Crypto.com has deprived me of the ability to complete a legitimate transaction, charged me for a service they later blocked, refused transparency, and caused significant financial harm. \nI request the CFPBs intervention to ensure the fair and lawful resolution of this matter. \nThank you for your attention to this complaint. I am available to provide further details as needed. \nSincerely, XXXX XXXX","date_sent_to_company":"2025-12-08T19:19:50.000Z","issue":"Other transaction problem","sub_product":"Virtual currency","zip_code":"85335","tags":null,"has_narrative":true,"complaint_id":"17840240","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Foris DAX, Inc.","date_received":"2025-12-08T18:38:40.000Z","state":"AZ","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["Allow immediate withdrawal of my <em>funds</em> to my verified bank <em>account</em>. \nXXXX. Provide the transcript of my in-app support conversation. \nXXXX. Provide a written explanation of the specific policy or law used to justify the restriction. \nXXXX. Disclose all internal review notes related to the decision to restrict my <em>account</em>. \nI am not requesting the restoration of my crypto transfer capability, only the fair return of my original <em>funds</em> and the ability to <em>withdraw</em> them. \nXXXX."]},"sort":[13.395876,"17840240"]},{"_index":"complaint-public-v1","_id":"6773169","_score":13.204385,"_source":{"product":"Checking or savings account","complaint_what_happened":"An offer was received from Capital One for a limited-time offer to open a 360 Performance Savings account and receive a bonus up to {$1000.00} based on the funds held in the account. Reviewing the offer requirements, it appears the funds need to be held in the account for 90 days following the initial funding period. What the offer fails to state is the 15 days of the initial funding period are not counted as part of the the 90-day period. After opening the account, there is a window of 15 days to deposit money into the account ; however, the 90-day period doesn't start until after the 15-day funding period ends. This information is not clearly stated in the offer and is deceptive to the common reader. When I spoke with a representative at Capital One on the phone, she also agreed with the fact that the language is not clear. It may have been clear to the person writing the requirements, but they were also probably too close to the process to see that consumers XXXX not understand what they were trying to describe. The end result is that I was expecting to receive the highest tier award of {$1000.00} because I held over {$100000.00} in the account for 101 days and only received {$100.00} because I withdrew the funds 4 days prior to meeting the actual requirement of 105 days. The statement that would have been helpful is if they stated the funds have to be held for 90 days after the 15 day initial funding period ends. For an actual total of 105 days. \n\nBelow are the guidelines for the offer. \n\nAbout this message Questions? Give us a buzz at XXXX XXXX XXXX to talk to a real person. Were here 7 days a week, XXXX XXXX XXXX. ET. \nCapital One reserves the right to withdraw this offer, with or without notice, in its sole discretion if it is determined that fraud or any other factor beyond its control is impacting the integrity of the offer and campaign. \nIf you have or had an open 360 Performance Savings, 360 Savings, 360 Money Market, Savings Now or Confidence Savings account as a primary or secondary account holder with Capital One on or after XX/XX/XXXX, you will be ineligible for the bonus. If your account is in default, closed or suspended, or otherwise not in good standing, you will not receive the bonus. \nCertain deposit transactions initiated through the Capital One website to retrieve funds from your external account are subject to limits. If you are subject to these limits, in order to meet the offer requirements, you would need to initiate the deposit by another external method, such as mobile deposit or setting the initial deposit to send ( rather than be retrieved from ) from your external financial institution. \nHeres the full scoop on how to earn your bonus : 1. Open a 360 Performance Savings account betweeXXXX XXXX XXXX ET on XX/XX/XXXX, and XXXXXXXX XXXX  ET on XX/XX/XXXX. When you open your account, ensure the promo code XXXX is entered in the Promo Code XXXX \n2. Deposit a total of {$10000.00} or more ( Deposit Amount ) of new money from externally sourced funds ( transfers between Capital One accounts will not qualify ) within the first 15 days of account opening ( Initial Funding Period ). You will earn a bonus once youve maintained the Deposit Amount of {$10000.00} or more for 90 days following the Initial Funding Period. The amount of your bonus will be determined as follows : {$100.00} bonusThe new money deposited from an external bank during the Initial Funding Period was between $ XXXX {$49000.00}, and you maintained that XXXX XXXX for 90 days. \n{$500.00} bonusThe new money deposited from an external bank during the Initial Funding Period was between $ XXXX {$99000.00}, and you maintained that Deposit Amount for 90 days. \n{$1000.00} bonusThe new money deposited from an external bank during the Initial Funding Period was more than {$100000.00}, and you maintained that Deposit Amount for 90 days. \n3. Capital One will deposit the bonus into your account within 60 days after you have completed all the requirements above, including fulfilling the 90-day holding period. If your account is in default, closed or suspended, or otherwise not in good standing, you will not receive the bonus. If at any time during the 90 days following the Initial Funding Period your Deposit Amount drops into a lower tier, you will be rewarded that tiers cash bonus. If your Deposit Amount decreases to an amount less than {$10000.00}, you will not qualify for a cash bonus. This offer can not be combined with any other 360 Performance Savings account opening offers. Only one promotional code is accepted. Bonus is only valid for one new 360 Performance Savings account. Bonuses are considered interest and will be reported on IRS form 1099-INT. \nWhen will I get my bonus? \nYour bonus will be deposited into your new 360 Performance Savings account by the date stated below :","date_sent_to_company":"2023-03-30T15:57:28.000Z","issue":"Managing an account","sub_product":"Savings account","zip_code":"93458","tags":null,"has_narrative":true,"complaint_id":"6773169","timely":"Yes","company_response":"Closed with monetary relief","submitted_via":"Web","company":"CAPITAL ONE FINANCIAL CORPORATION","date_received":"2023-03-30T14:54:10.000Z","state":"CA","company_public_response":null,"sub_issue":"Banking errors"},"highlight":{"complaint_what_happened":["An offer was received from Capital One for a limited-time offer to open a 360 Performance Savings <em>account</em> and receive a bonus up to {$1000.00} based on the <em>funds</em> held in the <em>account</em>. Reviewing the offer requirements, it <em>appears</em> the <em>funds</em> need to be held in the <em>account</em> for 90 days following the initial funding period. What the offer fails to state is the 15 days of the initial funding period are not counted as part of the the 90-day period."],"product":["Checking or savings <em>account</em>"],"issue":["Managing an <em>account</em>"],"sub_product":["Savings <em>account</em>"]},"sort":[13.204385,"6773169"]},{"_index":"complaint-public-v1","_id":"20298752","_score":13.073882,"_source":{"product":"Debt or credit management","complaint_what_happened":"To : File / Regulatory Complaint Record From : XXXX XXXX XXXX Date : XX/XX/XXXX Company : Americor Funding , LLC d/b/a Americor Financial XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX Re : Contractual Clauses and Potential Violations Debt Settlement Misrepresentation, Improper Fees, and Unauthorized Electronic Withdrawals Complaint I am submitting this complaint against Americor Funding , LLC d/b/a Americor Financial and its affiliated entity XXXX XXXX XXXX XXXX XXXX XXXX XXXX regarding deceptive practices , failure to perform contracted services, improper fees, and unauthorized electronic withdrawals associated with a debt settlement program. \nI relied on Americors representations that it would negotiate settlements with creditors enrolled in the program. Instead, Americor failed to perform the services promised while continuing to withdraw funds from my account. \n\nDebt Settlement Agreement On XX/XX/XXXX, I entered into a Debt Resolution Agreement with Americor Financial. The company represented that it would negotiate settlements with creditors enrolled in the program and that fees would only be charged after a settlement was successfully negotiated and approved by me. \n\n\nUnder the agreement : Americor would negotiate settlements with enrolled creditors. \nFees would only be charged after a settlement was successfully negotiated and I approved the settlement terms. \nAmericors settlement fee was 29 % of the enrolled debt associated with each settlement. \nThe debts enrolled in the program included : XXXX XXXX XXXX XXXX  / XXXX XXXX XXXX / XXXX XXXX  XXXX XXXX The total enrolled debt was approximately {$8200.00}. \n\n\nTimeline XX/XX/XXXX Enrolled in Americors debt settlement program. \nXX/XX/XXXX Sent Americor proof that two enrolled debts had already been paid directly. \nXX/XX/XXXX Americor representative XXXX XXXX confirmed that the Comenity account ending in XXXX and the XXXX account ending in XXXX had been paid in full and removed from the program. \nXX/XX/XXXX Requested that Americor close my account and stop all withdrawals. \nXX/XX/XXXX Americor withdrew additional funds from my account despite my request to terminate the program. \n\n\nFailure to Perform Contracted Services Americor did not negotiate settlements for the XXXX or XXXX accounts. I personally negotiated and paid these debts in full. Americor later acknowledged that the debts had been paid and removed them from the program. \nOn XX/XX/XXXX, Americor representative XXXX XXXX sent written communication confirming that the creditors reported the debts as paid. \nThe communication stated : We have been informed by XXXX that your account ending in XXXX has been paid in full. Due to this, Americor is unable to proceed with negotiations on this account. As a result, we will be removing the debt from your program. Please note that this change only applies to the specific account mentioned above. Your program will continue with any remaining enrolled accounts as normal. \nThe communication further stated : We have been informed by XXXX that your account ending in XXXX has been paid in full. Due to this, Americor is unable to proceed with negotiations on this account. As a result, we will be removing the debt from your program. Please note that this change only applies to the specific account mentioned above. Your program will continue with any remaining enrolled accounts as normal. \nThis confirms that Americor did not negotiate or resolve these debts.\n\nA. No Fee Until Successful Negotiation Clause The agreement states that Americor will not charge any fee for its services until it successfully negotiates a debt and the consumer makes a deposit toward the settlement of that debt.\n\nDespite not negotiating these debts, Americor continued collecting funds from my account. \nDuring a phone call on XX/XX/XXXX, an Americor representative informed me that my account had incurred over {$700.00} in additional fees due to alleged delinquency.This statement is inaccurate. \nDuring the XXXX federal government shutdown, I temporarily paused payments due to financial hardship. However, funds already existed in my Americor account which could have been used for negotiations. \nThe representative also claimed the fees were related to negotiations with XXXX, even though I had already agreed to the settlement terms directly. \nThe amount referenced also appears inconsistent with the 29 % fee structure specified in the contract. \nConcern : Two debts ( XXXX and XXXX ) were paid directly by the consumer and later acknowledged by Americor as already paid. This raises the question of whether any fees were charged for debts that Americor did not negotiate. \nB. Good Faith Negotiation Obligation The agreement states that Americor will work in good faith to resolve each of the debts listed by negotiating settlements with creditors. \nConcern : If negotiations were not attempted before those debts were resolved directly by the consumer, regulators may review whether Americor fulfilled its good-faith negotiation obligation.\n\nC. Settlement Approval Requirement The agreement provides that settlement offers must be presented to the consumer and approved before Americor may proceed with settlement. \nConcern : For the XXXX and XXXX accounts, no Americor-negotiated settlement was presented for approval because the debts were already paid. \n\n\nImproper Fees On XX/XX/XXXX, I requested that Americor close my account and discontinue withdrawals. Despite this request, Americor withdrew funds from my account on XX/XX/XXXX. \nDespite not negotiating these debts, Americor continued collecting funds from my account. On XX/XX/XXXX, I was informed that my account had incurred more than {$700.00} in fees due to alleged delinquency. This explanation appears inconsistent with the agreement stating that settlement fees are earned only after a negotiated settlement and a payment toward that settlement. \nA. Dedicated Settlement Account Structure The agreement requires deposits into a dedicated settlement account intended to fund negotiated settlements and program fees. \nConcern : Funds continued to be withdrawn after the debts were confirmed paid and after a request was made to terminate the program. \nB. Right to Withdraw from the Program The agreement allows the consumer to withdraw from the program at any time without penalty by providing notice. \nOn XX/XX/XXXX, I requested that Americor close my account and stop all ACH withdrawals.\n\nDespite this request, Americor withdrew additional funds from my account on XX/XX/XXXX. \nThis withdrawal occurred after authorization had been revoked and may violate the Electronic Fund Transfer Act ( 15 U.S.C. 1693 ). \nConcern : A withdrawal from the account occurred on XX/XX/XXXX after a termination request was made on XX/XX/XXXX. \nC. Clause Concerning Consumer-Negotiated Settlements The agreement states that settlements reached directly with creditors may still be considered part of the program even if the consumer negotiated them personally.\n\nConcern : Americor later acknowledged the debts had already been paid and removed them from the program, suggesting the company did not negotiate those settlements.\n\nConsiderations The conduct described above may warrant review under consumer protection frameworks governing debt relief services, electronic fund transfers, and unfair or deceptive business practices.\n\nPotential Legal Concerns Missouri Merchandising Practices Act ( Mo. Rev. Stat. 407.020 ) Electronic Fund Transfer Act ( 15 U.S.C. 1693 ) and Regulation E ( 12 C.F.R. Part 1005 ) FTC Telemarketing Sales Rule for Debt Relief Services ( 16 C.F.R. Part 310 ) Federal Trade Commission Act ( 15 U.S.C. 45 ) Supporting Documentation Debt Resolution Agreement with Americor Bank statements showing withdrawals Record of my agreement Screen shots of my Americor account 4 C. Clause Concerning Consumer-Negotiated Settlements The agreement states that settlements reached directly with creditors may still be considered part of the program even if the consumer negotiated them personally.\n\nConcern : Americor later acknowledged the debts had already been paid and removed them from the program, suggesting the company did not negotiate those settlements.\n\nConsiderations The conduct described above may warrant review under consumer protection frameworks governing debt relief services, electronic fund transfers, and unfair or deceptive business practices. \n\n\nPotential Legal Concerns Missouri Merchandising Practices Act ( Mo. Rev. Stat. 407.020 ) Electronic Fund Transfer Act ( 15 U.S.C. 1693 ) and Regulation E ( 12 C.F.R. Part 1005 ) FTC Telemarketing Sales Rule for Debt Relief Services ( 16 C.F.R. Part 310 ) Federal Trade Commission Act ( 15 U.S.C. 45 ) Supporting Documentation Debt Resolution Agreement with Americor Bank statements showing withdrawals Record of my agreement Screen shots of my Americor account","date_sent_to_company":"2026-03-16T16:23:21.000Z","issue":"Unauthorized withdrawals or charges","sub_product":"Debt settlement","zip_code":"64133","tags":null,"has_narrative":true,"complaint_id":"20298752","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Americor Funding, LLC","date_received":"2026-03-16T16:04:49.000Z","state":"MO","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["Concern : <em>Funds</em> continued to be withdrawn after the debts were confirmed paid and after a request was made to terminate the program. \nB. Right to <em>Withdraw</em> from the Program The agreement allows the consumer to <em>withdraw</em> from the program at any time <em>without</em> penalty by providing notice. \nOn XX/XX/XXXX, I requested that Americor close my <em>account</em> and stop all ACH withdrawals.\n\nDespite this request, Americor withdrew additional <em>funds</em> from my <em>account</em> on XX/XX/XXXX."]},"sort":[13.073882,"20298752"]},{"_index":"complaint-public-v1","_id":"10614058","_score":12.9253435,"_source":{"product":"Checking or savings account","complaint_what_happened":"We instructed TD branch representative XXXX XXXX to put my biological children XXXX and XXXX as beneficiaries on our savings account. We specified that we wanted their full legal birth names to be documented as beneficiaries with XX/XX/year> equal disbursement upon our death. XXXX XXXX refused to type my childrens legal birth names on the form. His reason as stated : because XXXX and XXXX are existing TD customers and it has to match the banks names. After we reluctantly signed the form, he refused to give us a copy of what we signed. We left the branch empty handed. We went to another branch a few days later to get a copy of the Personal Account Maintenance form XXXX XXXX created in the TD system. Upon reviewing the form, it appears XXXX XXXX placed our beneficiaries as legal account title owners which is not what we wanted. \nAfter our discovery of what XXXX XXXX did after we left the branch, we asked the XXXX XXXX XXXX about TD Banks policies for joint accounts. ( see attached items 1-5 ) XXXX XXXX did not provide this information to us before or after his actions. Instead, XXXX XXXX obtained our signatures by his own deceptive actions and willful negligence to make us consent to something we didnt ask for in the first place. Number 5 appears to be TDs assumption that they can self-appoint themselves as their own arbitrators and remove our rights to sue the bank in Court. \nShould the Bank receive any process, summons, order injunction, execution, distraint, levy, lien or notice ( hereinafter referred to as Process ) which in the Banks opinion affects this deposit, the Bank may, at its option and without liability thereupon, refuse to honor orders to pay or withdraw sums from this account and may either hold the balance herein until Process is disposed of to the Banks satisfaction or pay the balance to the source of Process. \nMy husband and I do not relinquish our rights to sue TD Bank for : 1. TD Banks financial theft of our deposit 2. Financial damages as a result of TD permitting financial theft of our deposit by false process 3. Financial damages as a result of TDs imposed restrictions and abrogation of our marital contract. 4. Financial damages as a result of TDs withholding of funds from our family estate, successors entitled to receive as our beneficiaries 5. Financial damages due to TD Banks negligence, errors, mistakes, and OCC regulation violations as a foreign National Bank operating in the United States and in the State of New York. \n\nArrange to have a TD Branch Manager immediately prepare a corrected Personal Account Maintenance form for us. The form must specify our children as beneficiaries, not account title holders. Their full legal birth names are as follows : XXXX XXXX XXXX 50 % and XXXX XXXX XXXX 50 % We also want to correct our legal names on the account to XXXX XXXX XXXX XXXX and XXXX XXXX XXXX as appropriate for a joint marital account.","date_sent_to_company":"2024-10-29T19:59:33.000Z","issue":"Managing an account","sub_product":"Savings account","zip_code":"117XX","tags":null,"has_narrative":true,"complaint_id":"10614058","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"TD BANK US HOLDING COMPANY","date_received":"2024-10-29T19:45:51.000Z","state":"NY","company_public_response":null,"sub_issue":"Funds not handled or disbursed as instructed"},"highlight":{"complaint_what_happened":["Should the Bank receive any process, summons, order injunction, execution, distraint, levy, lien or notice ( hereinafter referred to as Process ) which in the Banks opinion affects this deposit, the Bank may, at its option and <em>without</em> liability thereupon, refuse to honor orders to pay or <em>withdraw</em> sums from this <em>account</em> and may either hold the balance herein until Process is disposed of to the Banks satisfaction or pay the balance to the source of Process."],"product":["Checking or savings <em>account</em>"],"issue":["Managing an <em>account</em>"],"sub_product":["Savings <em>account</em>"],"sub_issue":["<em>Funds</em> not handled or disbursed as instructed"]},"sort":[12.9253435,"10614058"]},{"_index":"complaint-public-v1","_id":"10998216","_score":12.056506,"_source":{"product":"Checking or savings account","complaint_what_happened":"Follow up to our previous complaint see below. TD Banks answer was : \" We have reviewed all documents and systems, and have confirmed, that both of your designated children were correctly added to your TD Savings Account as Beneficiaries. They are Not listed as Account Owners. '' My husband and I went to the XXXX branch to sign a corrected Account form where TD would insert my children 's full legal names and they would be designated as beneficiaries instead of account holders. We did not get the opportunity to sign a correct account form because the banker refused to issue one and restated that we cold not use the children 's legal names. She stated that \" the language on the form is the banks own language. '' \" the language TD uses means beneficiary ''. As can be seen on the form, the word beneficiary does not appear. We are not convinced that TD properly executed the correct form and used the correct legal language. TD 's refusal to utilize my children 's legal name on their birth certificate and social security card indicates that TD wants to disconnect my children 's names by omitting the legal middle name which appears on the Government documentation from the NYS Department of Health and Social Security Administration. We would like a explanation from TD why the Bank refuses to use my children 's middle name? \n\nWe are asking that a proper form be created for us to sign. \n\n\nPREVIOUS COMPLAINT # XXXX We instructed TD branch representative XXXX XXXX to put my biological children XXXX and XXXX as beneficiaries on our savings account. We specified that we wanted their full legal birth names to be documented as beneficiaries with 50/50XX/XX/year> equal disbursement upon our death. XXXX XXXX refused to type my childrens legal birth names on the form. His reason as stated : because XXXX and XXXX are existing TD customers and it has to match the banks names. After we reluctantly signed the form, he refused to give us a copy of what we signed. We left the branch empty handed. We went to another branch a few days later to get a copy of the Personal Account Maintenance form XXXX XXXX created in the TD system. Upon reviewing the form, it appears XXXX XXXX placed our beneficiaries as legal account title owners which is not what we wanted. After our discovery of what XXXX XXXX did after we left the branch, we asked the XXXX XXXX XXXX about TD Banks policies for joint accounts. ( see attached items 1-5 ) XXXX XXXX did not provide this information to us before or after his actions. Instead, XXXX XXXX obtained our signatures by his own deceptive actions and willful negligence to make us consent to something we didnt ask for in the first place. Number 5 appears to be TDs assumption that they can self-appoint themselves as their own arbitrators and remove our rights to sue the bank in Court. Should the Bank receive any process, summons, order injunction, execution, distraint, levy, lien or notice ( hereinafter referred to as Process ) which in the Banks opinion affects this deposit, the Bank may, at its option and without liability thereupon, refuse to honor orders to pay or withdraw sums from this account and may either hold the balance herein until Process is disposed of to the Banks satisfaction or pay the balance to the source of Process. My husband and I do not relinquish our rights to sue TD Bank for : 1. TD Banks financial theft of our deposit 2. Financial damages as a result of TD permitting financial theft of our deposit by false process 3. Financial damages as a result of TDs imposed restrictions and abrogation of our marital contract. 4. Financial damages as a result of TDs withholding of funds from our family estate, successors entitled to receive as our beneficiaries 5. Financial damages due to TD Banks negligence, errors, mistakes, and OCC regulation violations as a foreign National Bank operating in the United States and in the State of New York. Arrange to have a TD Branch Manager immediately prepare a corrected Personal Account Maintenance form for us. The form must specify our children as beneficiaries, not account title holders. Their full legal birth names are as follows : XXXX XXXX XXXX 50 % and XXXX XXXX XXXX 50 % We also want to correct our legal names on the account to XXXX XXXX XXXX XXXX and XXXX XXXX XXXX as appropriate for a joint marital account.","date_sent_to_company":"2024-12-03T01:08:36.000Z","issue":"Opening an account","sub_product":"Savings account","zip_code":"117XX","tags":null,"has_narrative":true,"complaint_id":"10998216","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"TD BANK US HOLDING COMPANY","date_received":"2024-12-03T00:28:32.000Z","state":"NY","company_public_response":null,"sub_issue":"Confusing or missing disclosures"},"highlight":{"complaint_what_happened":["Should the Bank receive any process, summons, order injunction, execution, distraint, levy, lien or notice ( hereinafter referred to as Process ) which in the Banks opinion affects this deposit, the Bank may, at its option and <em>without</em> liability thereupon, refuse to honor orders to pay or <em>withdraw</em> sums from this <em>account</em> and may either hold the balance herein until Process is disposed of to the Banks satisfaction or pay the balance to the source of Process."],"product":["Checking or savings <em>account</em>"],"issue":["Opening an <em>account</em>"],"sub_product":["Savings <em>account</em>"]},"sort":[12.056506,"10998216"]},{"_index":"complaint-public-v1","_id":"5572167","_score":10.848956,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"Dear Consumer Financial Protection Bureau, I am one of hundreds of victims of theft of cryptocurrency off the exchange run by Gemini Trust Company , LLC ( d/b/aXXXX Gemini XXXX, XXXX ) ( Gemini ) that resulted from Geminis unfair, deceptive, or abusive acts or practices ( UDAAPs ), in violation of the Dodd-Frank Act, 12 U.S.C. 5531. In short, as a result of Geminis failure to adequately safeguard self-directed retirement assets on its exchange from foreseeable misconduct, hackers were able to fraudulently transfer tens of millions of dollars worth of cryptocurrency off the exchange on XX/XX/XXXX, including [ Amount ] ETH from my account. \n\nGemini lured myself and the other victims in by selling security and trust : Trust is our product, they tell the public. We bought it and were led to believe Gemini would adequately safeguard our valuable retirement assets. Gemini advertises its industry leading security, and broadcasts unequivocally that All crypto held online in our exchange wallet is insured. It was precisely statements like these that led me ( and others ) to believe my self-directed retirement funds would be safe on the Gemini exchange and therefore to select a custodian that advertised a partnership with Gemini for this very purpose. At no time, prior to the theft of assets, did Gemini provide any indication that they would not put the full force of their company resources and highly touted security program behind the protection of my assets. To the contrary, upon signing up with Gemini, they sent welcome letters, reiterating promises of their security-first mentality and an ethos of asking for permission, not forgiveness, and they promised the full Gemini experience. \n\nI, and other victims, had every reason to rely on Geminis representations in establishing trust and selecting a place to buy and store valuable retirement assets. However, based on Geminis responses to my inquiries ( and those of other victims ) to date, these representations proved to be unbelievably deceptive. Gemini now claims that all security measures to protect the tens of millions of crypto held on Geminis exchange fell on XXXX XXXX relatively small company that, among other things, takes miniscule fees compared to those taken by Gemini for buying and holding crypto, and that does not sell its product based on its own security but rather that of Gemini. Even though Gemini promised ( among other industry-leading security ) two-factor authentication ( 2FA ), protections against single point of failure, and that in any event crypto is insured against fraud, victims were not notified ( via 2FA or otherwise ) of the withdrawals that Gemini says was due 100 % to IRA Financial ( a single-point of failure ) being severely compromised, and the assets were not insured against this loss. \n\nGemini violated the Dodd-Frank Act by engaging in UDAAPs and harming the victims in several ways. This included unfair acts and practices in the form of inadequate safeguards that caused injuries not reasonably avoidable by consumers. It also included deceptive practices in the form of material misrepresentations reasonably misleading and injuring consumers. Gemini also appears to have violated both state law and possibly the Electronic Funds Transfer Act ( EFTA ), each of which violation would constitute an actionable UDAAP under Dodd-Frank Act as well as a violation of the underlying laws These violations are detailed below.\n\nI. Geminis Unfair Acts and Practices : Failure to Establish Appropriate Policies and Procedures to Prevent, Detect, or Remedy Fraudulent Activity Harming Consumers The fraud that occurred on XX/XX/XXXX was stark. Hackers were able to compromise XXXX XXXX Geminis partner in providing consumers with an option to invest their self-directed retirement funds in cryptocurrency. Amazingly, Gemini had no safeguards against a single point of failure at XXXX  XXXX, where hacked administrative accounts were able to transfer tens of millions of dollars from hundreds of different individual customer accounts under their control into one account, and then transfer from the one account off the exchange, all within dozens of minutes. In statements to victims after this egregious security failure, Gemini has said The subject transactions appeared, from Geminis perspective, to be routine, authorized, and legitimate. This statement from Gemini is incredible and highlights the extreme lack of anything close to proper safeguards.\n\nThe standard for unfairness in the Dodd-Frank Act is that an act or practice is unfair when : ( 1 ) It causes or is likely to cause substantial injury to consumers ; ( 2 ) The injury is not reasonably avoidable by consumers ; and ( 3 ) The injury is not outweighed by countervailing benefits to consumers or to competition. See 15 U.S.C. 45 ( n ) ( The standard for unfairness in the Dodd-Frank Act has the same three-part test as the FTC Act, which was first stated in the FTC Policy Statement on Unfairness ( XXXX XXXX, XXXX ), available at : http : //www.ftc.govXXXX, and later specifically included in the FTC Act. ) As an example, in In re XXXX XXXX, XXXX XXXX, the Office of the Comptroller of the Currency ( OCC ) brought an enforcement action where a bank maintained deposit account relations with telemarketers and payment processors without adequately safeguarding against fraud. In that case, the telemarketers regularly deposited large numbers of remotely created checks drawn against consumers accounts, a large proportion of which were not authorized by consumers. OCCs investigation indicated the bank failed to establish appropriate policies and procedures to prevent, detect, or remedy such activities. Under the three-part test for unfairness, ( 1 ) the consumers lost money from the fraudulent checks was a substantial injury, ( 2 ) consumers could not have avoided the injury from transactions to which they had not consented, and ( 3 ) the cost to the bank of establishing a minimum level of due diligence, monitoring, and response procedures sufficient to remedy the problem would have been far less than the amount of injury to consumers that resulted from the banks avoiding those costs. See CFPB Consumer Laws and Regulations, UDAAPs Manual v.3 at pp.4-5 ( XX/XX/XXXX ) ( discussing the analysis ). \n\nGeminis failures in the present case easily meet the three-part test for unfairness. First, the lost tens of millions of dollars worth of crypto is obviously a substantial injury. Second, there is nothing the consumers could have done to avoid this injuryin fact, not only had the victims not consented to the transfers, but we relied on notifications and two-factor authentication to make any transfers on the Gemini exchange, and yet no notice was provided by Gemini at any time as the accounts were being drained. No protections were offered by Gemini and there was nothing consumers could have done, reasonable or otherwise, to prevent this. Third, as in In re XXXXXXXX XXXX XXXXXXXX XXXX, the cost to Gemini of establishing a minimum level of due diligence, monitoring, and response procedures sufficient to remedy the problem would have been far less than the injury resulting from Geminis avoiding these costs. In other words, Geminis failures were clearly unfair under the meaning of Dodd-Frank , and in accordance with precedent, and CFPB should take action to compel Gemini to restore the victims accounts.\n\nII. Geminis Deceptive Acts and Practices : Misleading Claims and Omissions About Security and Insurance that Consumers Reasonably Relied Upon to their Detriment When I was looking for a platform I could use to invest my self-directed retirement funds in crypto, I picked XXXX  XXXX due to their advertised partnership with Gemini, which holds itself out as an industry leader in security and advertises that all crypto on its exchange is insured. Gemini got my business, and those of countless others no doubt, by promoting a reputation for safety and security. I, and other victims, reasonably relied on Geminis assurances that our assets were safe on the Gemini exchange, and we reasonably believed that, should they be somehow stolen or otherwise compromised, our assets would be protected by Geminis insurance. But all of this appears based on Geminis current position to be egregiously misleading. In other words, Geminis representations were extremely deceptive.\n\nUnder the Dodd-Frank Act, a representation, omission, act, or practice is deceptive when ( 1 ) The representation, omission, act, or practice misleads or is likely to mislead the consumer ; ( 2 ) The consumers interpretation of the representation, omission, act, or practice is reasonable under the circumstances; and ( 3 ) The misleading representation, omission, act, or practice is material. See CFPB Consumer Laws and Regulations, UDAAPs Manual v.3 at p. 5 ( XX/XX/XXXX ) ( citing FTC Policy Statement on Deception, available at http : //www.ftc.govXXXX XXXX \n\nCFPB has explained that, in addition to affirmative representations that are misleading, if material information is necessary to prevent a consumer from being misled, it may be deceptive to omit that information. Id. Examples of deceptive practices may include, among other things, offering to provide a product or service that is not in fact available ;... omitting material limitations or conditions from an offer ; or failing to provide the promised services. Id. \n\nGeminis acts and practices easily meet the test under Dodd-Frank because they lured consumers in with statements creating reasonable expectations for security and insurance, which proved to be totally false and which materially harmed the consumers who relied on these reasonable expectations. Below, I set forth some of the specific statements and representations made or omitted by Gemini, the reasonable expectations these created, and the reality of what occurred and what Gemini is saying now.\n\nA. What Gemini Said : That They Are Safe, Trusted, Leaders in Security, and that Their Protections Include 2FA, Protections Against Single-Points of Failure , and Insurance Against Fraud Geminis entire sales pitch is that they are safe and secure, and that people should trust them to safeguard their valuable assets. Gemini tells the public they are the Safest Crypto Exchange, and make the following representations, among others : Trust is our product.\n\nGeminis founders built Gemini to deliver the first trusted platform that focused on strong security controls and compliance. \nGemini has built a leading security program focused on developing innovative security solutions to help protect and secure our customers and their assets. \nAll crypto held online in our exchange wallet is insured and we use best-in-industry cold storage coverage with leading insurance providers. \n\nSee Gemini Advertising and Marketing Materials, Exhibit A. \n\nAlong the same lines, XXXX  XXXX distinguished itself in advertisements by stressing its partnership with Gemini and underscoring the safety, security, and insurance of the Gemini XXXX. XXXX  XXXX advertised about its partner and their collective products and services, among other things : Gemini is a regulated crypto exchange with over {$10.00} billion in assets. \nHow it works... XXXX  XXXX creates your crypto account on Gemini. Gemini then emails you onboarding instructions. \nGemini is a regulated trust company and offers its clients insurance against fraud. \n\nXXXX  XXXX XXXX and Marketing Materials, Exhibit B. \n\nGemini participated in this partnership and at no time qualified or corrected any statements advertised about the safety, security, and insurance that would protect customers. \n\nNotably, I recall seeing and relying on similar communications and advertisements about the safety and security of Gemini ( and XXXX  XXXX as a result of their partnership with Gemini ), and I understand some materials have since been taken down by one or both companies. I do not have access to all of these, but I believe other victims may have some of these materials that they have provided or may provide to CFBP.\n\nOne stark example of this is Geminis prior claims about insurance, which has now been heavily qualified.\n\nGeminis prior representation about insurance was : All crypto held online in our exchange wallet is insured and we use best-in-industry cold storage coverage with leading insurance providers.\n\nAs of the date of this letter, Gemini has taken this down, tacitly acknowledging its inaccuracy, and Gemini now represents to the public only that : We maintain insurance against certain types of crypto losses from our exchange wallet and from Gemini Custody. To learn more about our insurance, and what it does and does not cover, please visit our User Agreement.\n\nSee Exhibit A. \n\nIn addition to these general promises, Gemini advertises specific details of their industry leading security that protect customers. Some particularly relevant representations include those concerning two-factor authentication and protections against single points of failure : In discussing its specific security practices, Gemini states that Two-Factor Authentication ( 2FA ) is required by default, in order to access your account and make withdrawals.\n\nSimilarly, Gemini toutes its asset security, stating The multisignature digital signature scheme ( multisig ) used eliminates single points of failure and improves our resilience against the loss or compromise of any individual private key.\n\nIt bears noting here that Gemini never corrected any statements advertised by XXXX  XXXX ( or itself ) about the security that would apply to holding retirement account assets on its exchange. In addition, none of the affirmative statements made above were qualified in any way that would communicate to a potential customer of the XXXX  XXXX XXXX Gemini partnership that investing retirement funds are any less protected than investing non-retirement funds. In fact, when onboarding through Gemini after singing up with XXXX  XXXX and Gemini, Gemini communicates the oppositethey sent victims welcome letters, reiterating promises of their security-first mentality and an ethos of asking for permission, not forgiveness, and they promised the full Gemini experience. \n\nB. What Victims Reasonably Understood and Expected : That Our Crypto Was Safe and Insured and that Gemini Would Not Allow Tens of Millions to Be Withdrawn From Our Accounts Without Our Permission or Even Notification, Among other Reasonable Expectations All these statements of assurance and trust workedI and other victims believed Gemini ( and purchased their product ). I and other victims came to the expectation and belief that our crypto was safe from fraud on Geminis exchange, and that in the event anything did happen, Gemini protected our crypto with insurance so there was no appreciable risk of catastrophe. The entire point of selecting XXXX XXXX and Gemini as a place to hold valuable retirement assets was the promised security, safety, and insurance. \n\nSpecific beliefs reasonably held as a result of Geminis representations included that no crypto would be withdrawn from victims accounts without consent via 2FA, that Gemini had adequate protections in place to prevent catastrophic loss from a single-point-of failure, and that in any event our assets were protected against fraudulent withdrawals by Geminis insurance coverage. These beliefs and expectations were eminently reasonable based on the statements above.\n\nFor example, the statement that Geminis security eliminates single points of failure communicates to consumers that we can trust there are multiple layers of security protecting our assets, so that there is no risk of one compromise causing catastrophic loss.\n\nGeminis statement that 2FA is required to make withdrawals gave us the expectation that our accounts would not be able to be drained without our consent or knowledge. My expectations and beliefs on this were also reinforced along the way, including by Geminis requirement for 2FA anytime I executed any transaction on Geminis platform. \n\nThis misrepresentation is particularly egregious given Geminis direct communications to us that they founded Gemini with a security-first mentality and an ethos of asking for permission, not forgiveness. We reasonably expected that they would not allow tens of millions in retirement assets to be withdrawn from our accounts without our permission. This expectation was more than reasonable given their explicit statement that 2FA was required for withdrawals and subsequent practice of asking our permission via 2FA for any buy or trade prior. Not only did they fail to ask for our permission, now they are not even asking our forgivenessto date they have taken zero responsibility for allowing our retirement funds to be funneled off the safest crypto exchange. \n\nGeminis unqualified statement that all crypto on their exchange is insured gave us all confidence that, should anything happen, there is insurance available to cover loss. This was advertised by both Gemini and XXXX XXXX, and a material inducement for us to give them business. Given these broad, unqualified statements, it was reasonable for customers to expect that Gemini would in fact cover crypto with insurance against loss if their security practices failed to prevent the loss, as was the case here. \n\nAs to the rest of my expectations around security and insurance, at no time did I have any reason to question any of the representations and promises initially made that I relied upon in signing up with XXXX XXXX and Gemini. \n\nC. What Actually Happened and What Gemini Now Says About it On XX/XX/XXXX, XXXX  XXXX was hacked. Hackers gained control of XXXX  XXXX administrator accounts, transferred tens of millions of dollars worth of assets from hundreds of victims to one account, created a new external wallet, and transferred the assets off Gemini exchange without notifying victims or apparently raising any flags at Gemini whatsoever. In fact, Gemini told victims The subject transactions appeared, from XXXX perspective, to be routine, authorized, and legitimate. Gemini XX/XX/XXXX Response to Victim CFPB Claim, Exhibit C. As presented to Gemini, these actions satisfied all of Geminis transaction approval requirements and appeared to be authorized transactions made from XXXX  XXXX known and approved devices. Gemini XX/XX/XXXX Response to EFTA Notice, Exhibit D. Further, Gemini has stated their insurance does not cover the loss because Geminis systems were not compromised.\n\nIn other words, the expectations we reasonably held based on Geminis representations proved dramatically false : Our expectation that Gemini was a safe, secure, trustworthy place to store crypto was eviscerated by their total failure to prevent bad actors from summarily and fraudulently transferring tens of millions of dollars worth of assets off the exchange. \nOur expectation that Gemini would notify us with 2FA and ask permission to withdraw funds proved shockingly false as we heard nothing from Gemini while they allowed our funds to be drained.\n\nOur expectation that their security included multiple layers to protect against single-points of failure such as the hack of an administrator with the power to create new external wallets and transfer off assets without safeguards proved similarly false.\n\nFinally, our expectation that Gemini maintained insurance that would protect our crypto as a fail-safe in case there was a dramatic unexpected breach also proved false. \n\nD. Clear Violation of Standard under XXXX XXXX These misrepresentations easily meet the test for deceptive under the Dodd-Frank Act. First, they are likely to mislead customers. As noted, the whole point of the advertising is to garner trust in Geminis security and get customers to buy their product. Second, as explained above, believing these representations under the circumstances is reasonable. Customers had no reason to question what Gemini and XXXX  XXXX were selling until the catastrophic failures came to light. Finally, the representations were material. The entire reason I ( and others, presumably ) chose Gemini was for the advertised safety and security. \n\nIt is critical to note that, even if all of Geminis claims were technically accurate ( for example, if their 2FA applied to XXXX  XXXX and not the consumer, and if the coins were insured just not against this type of fraud ), these claims remain highly misleading and illegal under XXXX XXXX I was led to believe, as any reasonable consumer would be through these claims, that my crypto was safethat it would not be withdrawn without my own 2FA ( which was required for purchases and transfers ) ; that Geminis systems were not susceptible to single-point of failure attacks ( including, what a reasonable consumer would think constitutes single-point of failurethe hack of Geminis partner administrator ) ; and that in any event, my crypto was protected via Geminis touted insurance policy. All of these beliefs turned out to be false and inaccurate, and yet they are totally reasonable and foreseeable based on Geminis advertising, representations, communications, acts, and practices. These misrepresentations were hugely materialthe trust was the foundation of my ( and other customers ) decision to go with Gemini. In no event would any of us have considered putting our retirement assets on the Gemini exchange had we known that our assets were not in fact protected in the way Gemini led us to believe they would be. \n\nIn other words, whether or not Gemini technically provided all the security they advertised, the fact remains that it was totally inadequate to prevent massive, foreseeable fraud, and this was shocking to customers who reasonably relied on their statements to believe that Gemini would be able to prevent, or at minimum insure loss from, such massive fraud. \n\nIII. Geminis Violations of State and Federal Law In addition the the violations outlined above, violations of applicable state and federal law also constitute UDAAPs, enforceable as violations under Dodd-Frank.\n\nA few noteworthy violations of applicable New York state law include : Gemini was required to conduct risk-assessment of XXXX XXXX platform and evaluate the adequacy of XXXX XXXX cybersecurity practices and protections under 23 NYCRR 500.11 . Gemini failed to do this. This is particularly egregious since Gemini now points to the breach at XXXX  XXXX and says Gemini holds no responsibility, putting all of the weight of responsibility on a security link that they themselves did not evaluate, in contravention of state law. \n\nGemini was required to provide its telephone number for the receipt of complaints under 23 NYCRR 200.20 ( b ) ( 1 ), but had only provided XXXX XXXX with its email address. This violation resulted in delays and significant loss after XXXX  XXXX detected the ongoing theft and Gemini was unresponsive to initial email notifications, with no ability to immediately notify Gemini. \n\nGeminis false, misleading, and deceptive representations and omissions, discussed above, are violations of New York law on advertising and marketing, 23 NYCRR 200.18. Gemini claims that its unqualified advertising that all crypto held on its exchange are insured was modified by language buried in its user agreement. However, as discussed above, even if this is technically true, the unqualified advertisement was highly misleading and deceptive, and itself is false without the separate qualification. Similarly, as discussed above, Geminis advertisements and representations that 2FA was required for withdrawals was misleading, deceptive, and ultimately false. \n\nGemini was required to implement adequate anti-money laundering measures and protections under 23 NYCRR 200.15 ( b ), ( c ). Criminals were able to steal assets from hundreds of accounts, transfer those assets ( one coin at a time ) to a single, unrelated account and then remove the stolen assets to a money-laundering tornado, thereby hiding the identity/ownership of the assets. This criminal laundering scheme involved several hundred transfers that went completely undetected by Gemini, in violation of New York anti-money laundering law. \n\nSimilarly, Gemini was required to monitor its system for transactions that might signify money laundering, tax evasion, or other illegal or criminal activity. 23 NYCRR 200.15 ( e ) ( 3 ). Gemini did not monitor for such activity here, as evidenced by the fact that it permitted hundreds of illegal transfers to occur, one coin at a time, into a single, unrelated account having no connection to its customers XXXX  accounts, and then allowed all of the stolen assets to be removed from its exchange. Subsequently, Gemini stated The subject transactions appeared, from Geminis perspective, to be routine, authorized, and legitimate. \n\nCritically, Gemini was also required to maintain, as part of its anti-money laundering program, a customer identification program. 23 NYCRR 200.15 ( h ). As part of this, Gemini was required to verify the identity of any accountholder initiating a transaction with a value greater than {$3000.00}. Here, as discussed above, Gemini did not verify the identity of the hundreds of customers via 2FA or otherwise of the withdrawals of hundreds of millions of dollars worth of crypto via voluminous transactions, all over {$3000.00} in value.\n\nGemini further failed to have in place appropriate policies and procedures to block or reject specific or impermissible transactions that violate Federal or State laws, rules, or regulations in violation of 23 NYCRR 200.15 ( j ). As discussed above, Geminis failures to monitor for, flag, or notify customers of hundreds of millions of dollars worth of crypto being fraudulently transferred to one account then to a new external wallet off exchange and into the abyss was an egregious failure.\n\nGemini also violated Californias Unfair Competition Law, Cal. Bus. Prof. Code 17200 et seq., which prohibits unfair business practices, including misleading advertising, similar to the federal violations of XXXX discussed above. Geminis unfair and misleading business practices were violations of state law in California because Gemini advertised its services here in California where I and other California victims reside, and Gemini got my business and that of other California victims, who all suffered a loss as a result of these practices.\n\nGemini may also have violated the Electronic Funds Transfer Act. I provided Gemini with notice of unauthorized transfer and requested correction under Regulation E. Gemini responded that Regulation E did not apply to the unauthorized transfer from my Gemini account because the account was a retirement account. It is unclear to me whether this is accuratethe exemption from retirement accounts appears to be focused on exempting the entity complying with IRS retirement obligations, which in this case would be XXXX  XXXX. It is not clear that the exemption would apply to Gemini, who is not regulated as a custodian. Thus, it appears Gemini may also have violated the EFTA. See EFTA Correspondence, Exhibit E.\n\nIV. Conclusion and Request for Remedy Geminis promises of security, notifications, insurance, and trust succeeded in getting the business of hundreds of victims that put tens of millions of dollars of critically important retirement funds on Geminis exchange and trusted Gemini to deliver on its promises, including to ask permission not forgiveness. Yet we found out Gemini failed us dramatically by allowing thieves to fraudulently transfer our retirement savings to one account, create an external wallet, and transfer our savings off Geminis exchange, without so much as notifying us, much less performing any of the promised or required verifications. Gemini did not even flag this as unusual, but instead told victims The subject transactions appeared, from Geminis perspective, to be routine, authorized, and legitimate. And they say it was not insured after all. \n\nThis is an outrageous failure on so many levels. The violations of XXXX are stark and numerous, as set forth above. We were misled by Gemini into buying the trust they were selling. But in the end, they did not protect our assets, and they are not putting the force of their company behind their initial promises of security and insuranceinstead it appears they are putting the force of their company toward gearing up to defend claims and making all the hundreds of victims pay out of pocket to hire private attorneys to enforce their clear rights. It is reprehensible. \n\nI am asking the CFPB to enforce XXXX and require Gemini to make the victims wholespecifically to reimburse victims in-kind for all of the crypto that was allowed to be transferred fraudulently off Geminis exchange, and to reimburse victims for any attorney fees and other costs actually incurred as a result. If CFPB has the power and inclination, I also request further penalties to be issues and further compensation to victims to be paid for their non-monetary damages, including the severe mental stress and emotional turmoil it has had on their lives as theyve dealt with drained retirement accounts and an about-face from the company that promised trust and security. \n\n\nThank you for your immediate care and attention to this matter. \n\nSincerely,","date_sent_to_company":"2022-05-18T00:46:37.000Z","issue":"Fraud or scam","sub_product":"Virtual currency","zip_code":"94107","tags":null,"has_narrative":true,"complaint_id":"5572167","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Winklevoss Exchange LLC","date_received":"2022-05-18T00:20:35.000Z","state":"CA","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["Our expectation that Gemini would notify us with 2FA and ask permission to <em>withdraw</em> <em>funds</em> proved shockingly false as we heard nothing from Gemini while they allowed our <em>funds</em> to be drained.\n\nOur expectation that their security included multiple layers to protect against single-points of failure such as the hack of an administrator with the power to create new external wallets and transfer off assets <em>without</em> safeguards proved similarly false."]},"sort":[10.848956,"5572167"]},{"_index":"complaint-public-v1","_id":"22208230","_score":10.830484,"_source":{"product":"Debt or credit management","complaint_what_happened":"I enrolled in Beyond Finances debt settlement program on XX/XX/XXXX with XXXX unsecured debts totaling approximately {$81000.00} and an estimated program term of 54 months. I began making bi-weekly deposits of {$520.00} on XX/XX/XXXX and have continued making those deposits consistently since enrollment. In XX/XX/XXXX, I removed XXXX XXXX Bank debts from the program ( totaling approximately {$7000.00} at enrollment ) because Beyond Finance had failed to initiate contact with XXXX after XXXX years of enrollment, and I successfully negotiated those debts directly with XXXX myself. In addition, I was forced to scramble for and deposit XXXX large lump-sum amounts ( approximately {$6700.00} in XX/XX/XXXX and {$15000.00} in XX/XX/XXXX ) funded entirely through early withdrawals from my XXXX ( k ) retirement account to settle lawsuits brought against me by creditors during the program. I also made a separate voluntary {$3000.00} deposit in XX/XX/XXXX in an attempt to accelerate program completion. Based on my own records and the transaction ledger Beyond Finance has provided me, my total deposits to the program from XX/XX/XXXX through XX/XX/XXXX are approximately {$63000.00}. As of today, an additional {$5300.00} in deposits is required before I can graduate the program. Despite this substantial payment history and the significant fees collected by Beyond Finance over nearly XXXX years, I have suffered serious financial harm as a direct result of the companys misrepresentations, bad advice, inaction, and lack of transparency. \nMisrepresentations and omissions at enrollment : During my enrollment on XX/XX/XXXX, the Beyond Finance representative made the following representations or omissions that turned out to be materially false or misleading : XXXX. I was instructed to stop paying my creditors and was assured Beyond Finance would handle negotiations on my behalf. \nXXXX. I was told my XXXX XXXX would not take a critical or significant hit. In reality, my XXXX XXXX has dropped from approximately XXXX at enrollment to XXXX a decline of roughly XXXX points that moved me from good credit to poor credit, a different credit tier entirely. \nXXXX. I was told that legal coverage was included in my program, which implied I would be protected from the financial costs of legal action by creditors. The Beyond Finance representative failed to inform me that this legal coverage was limited to the drafting of court responses, and that I would still be personally responsible for court filing fees, settlement amounts, judgments, and any other costs associated with being sued by creditors. As I later learned when I was sued, the actual legal coverage Beyond Finance provided was the drafting of responses to file in court nothing more. \nXXXX Finances written credit impact disclosure is materially misleading : XXXX Finances own client-facing materials describe the credit impact of their program as a drop that is temporary and an anticipated part of the debt resolution process, with assurances that the vast majority of clients have reported a full FICO recovery upon graduating. This disclosure fails to warn consumers of the magnitude of the credit damage ( in my case, a XXXX drop from XXXX to XXXX ), the high likelihood of being sued by creditors during the program, and the personal financial liability for settlement amounts, judgments, and court filing fees resulting from those lawsuits. The disclosure characterizes a years-long, tier-changing credit drop and the risk of multiple lawsuits as routine and temporary, which is materially misleading. \nLawsuits resulting from Beyond Finances instructions and inaction : Because I followed Beyond Finances direct instruction to stop paying creditors, I have been sued twice during my enrollment. Critically, both lawsuits were a direct result of Beyond Finances refusal to even initiate contact with my creditors to begin settlement negotiations during the early years of my enrollment. \nWhen I raised concerns to Beyond Finance about my creditors not being contacted, I was told that they could not call my creditors or begin negotiations because my settlement account did not yet have sufficient funds. This is despite the fact that I was making my required bi-weekly deposits of {$520.00} consistently as agreed, and despite Beyond Finance continuing to collect monthly service fees and other charges from those same deposits throughout that period. \nThe result of this inaction was predictable and avoidable : Bank XXXX XXXX sued me in XX/XX/XXXX approximately 11 months after I enrolled and after I had been instructed to stop paying them because no contact or settlement negotiation had been initiated on my behalf. To resolve this lawsuit, I had to scramble for approximately {$6700.00} on short notice. XXXX Finances program was not funded to cover this amount, and I did not have those funds available in savings. I made the independent decision to take an early withdrawal from my XXXX ( k ) retirement account because it was the only source of funds I had available ; the alternative failing to fund the settlement would have exposed me to a default judgment and likely wage garnishment. Those XXXX ( k ) funds were deposited into my Beyond Finance dedicated account on XX/XX/XXXX as a lump-sum deposit, which Beyond Finance XXXX XXXX to fund the settlement. \nXXXX sued me in XX/XX/XXXX, again because Beyond Finance had not initiated timely contact or negotiations with this creditor. To resolve this lawsuit, I had to scramble for approximately {$15000.00} on short notice again forced to take an early withdrawal from my XXXX ( k ) for the same reason. Those funds were deposited into my Beyond Finance dedicated account as a lump-sum deposit on XX/XX/XXXX, and Beyond Finance XXXX XXXX them to fund the XXXX settlement. \nI also paid approximately {$800.00} in court filing fees out of pocket to file the responses Beyond Finance prepared on my behalf. \nIn total, I was forced to make approximately {$22000.00} in emergency lump-sum deposits funded entirely through early XXXX ( k ) withdrawals to settle lawsuits that Beyond Finances refusal to contact my creditors until the account was sufficiently funded made inevitable. These were funds I had not budgeted for and which were over and above the regular bi-weekly deposits I had already committed to the XXXX program. \nThe pattern this reveals : Beyond Finance instructed me to stop paying my creditors, then refused to contact those creditors to negotiate on my behalf until my settlement account had accumulated sufficient funds all while continuing to collect fees from the deposits I was making. The predictable and foreseeable consequence of this pattern was that creditors who were not receiving payments and were not being contacted by Beyond Finance escalated to litigation. This raises serious concerns about whether Beyond Finances fee collection during periods of inaction complies with the FTC Telemarketing Sales Rules prohibition on collecting fees before debts are actually settled, and whether the companys stop paying creditors instruction combined with its refusal to negotiate until funds accumulated constitutes a deceptive or abusive practice under XXXX. \nCompounded financial harm from forced early retirement withdrawals : The full financial harm caused by Beyond Finances program goes well beyond the {$22000.00} I had to deposit to fund the lawsuit settlements. To be clear, Beyond Finance did not instruct me to withdraw from my XXXX ( k ) retirement account but having been instructed by Beyond Finance to stop paying my creditors, and then facing active lawsuits brought by those creditors with short deadlines to fund settlements and avoid judgments, my XXXX ( k ) was the only source of funds I had available. I made the decision to take early withdrawals because the alternative failing to fund the settlements would have exposed me to further legal action, default judgments, and likely wage garnishment. \nBecause I had to source those funds through early withdrawals from my XXXX ( k ), I incurred significant additional financial penalties that are a direct downstream consequence of Beyond Finances instructions and the lawsuits those instructions produced : XXXX. 10 % IRS early withdrawal penalty on each withdrawal, as I am under retirement age ; XXXX. Federal and state income taxes on the withdrawn amounts, which were treated as ordinary income ; XXXX. Loss of future compound investment growth on the withdrawn retirement funds, which over a working career represents a substantial multiple of the original withdrawal amount ; XXXX. Disruption of long-term retirement planning as a result of liquidating retirement assets to address lawsuits I was assured at enrollment would not occur. \nTo net the approximately {$22000.00} deposited into my Beyond Finance account to settle these lawsuits, I had to withdraw a substantially larger amount from my XXXX ( k ) to cover the early withdrawal penalty and tax withholding. Beyond Finances enrollment representations did not warn me that following their program could put my retirement savings at risk, and their representatives implication that legal coverage was included gave no indication that I might be forced to liquidate retirement funds to settle lawsuits brought by the very creditors Beyond Finance instructed me to stop paying. \nBeyond Finance is unable or unwilling to provide a fee accounting : After receiving conflicting information about fees and settlements over multiple months, I contacted Beyond Finance on XX/XX/XXXX to request a detailed accounting of how my payments have been allocated specifically, a breakdown of fees charged for each settled debt and how those fees were calculated. A Beyond Finance representative informed me that there is no way for them to send me records of how my payments are being allocated beyond what is visible in my Dedicated Account portal, which only displays generic line items labeled Settlement fee, Monthly Service Fees, and BLP Monthly Fee without identifying which debt the fee applies to, the settled amount, or how the fee was calculated. \nFor example, recent transactions in my account show Settlement fee charges of {$450.00} ( XX/XX/XXXX ) and {$590.00} ( XX/XX/XXXX ) with no breakdown of the underlying settlement or fee calculation. Additionally, the transaction ledger Beyond Finance provided to me only covers the period from XX/XX/XXXX onward meaning approximately XXXX months of my deposit and fee history ( from XX/XX/XXXX through early XX/XX/XXXX, representing approximately {$9500.00} in deposits ) is not visible to me in the records Beyond Finance has made available. This is despite my having made bi-weekly deposits of {$520.00} consistently starting XX/XX/XXXX. \nThe companys inability or unwillingness to provide a complete, detailed fee accounting on request and its apparent inability to even produce the first XXXX months of my transaction history prevents me from verifying whether the fees charged comply with the FTCs Telemarketing XXXX XXXX, which requires that fees be proportionally tied to specific settled debts. This lack of transparency is itself a serious concern and supports my request for a full refund of fees paid. \nBeyond Finance misrepresented how a voluntary additional deposit would be used : On XX/XX/XXXX, I made a voluntary {$3000.00} lump-sum deposit into my Beyond Finance dedicated account, in addition to my regular bi-weekly deposits and the emergency XXXX ( k ) deposit I had made XXXX week earlier to settle the Upstart lawsuit. I made this {$3000.00} deposit specifically because Beyond Finance represented to me that the funds would be used to negotiate my last remaining debt and accelerate completion of the program. \nI subsequently learned that the {$3000.00} was not used to negotiate or settle my remaining debt as I had been told. Instead, the funds were applied to fees on debts that had already been previously settled. This was a direct misrepresentation about how a specific deposit would be used and a violation of the trust that Beyond Finance solicited from me when asking me to make an additional voluntary payment. \nThis conduct is particularly concerning because it suggests Beyond Finance solicits additional voluntary deposits from clients by representing that those funds will be used for forward-looking settlement activity, while in fact using the funds to back-fill fees on prior settlements. Combined with the companys inability to provide a fee accounting and its refusal to negotiate with creditors until accounts were sufficiently funded, this raises serious concerns about whether Beyond Finance is structuring fee collection in a manner that complies with the FTC Telemarketing Sales Rules requirement that fees be proportionally tied to specific settled debts, and whether the companys representations to consumers about the use of their deposits constitute deceptive practices under UDAAP. \nI successfully self-negotiated debts Beyond Finance XXXX XXXX to contact, demonstrating that Beyond Finances fees are not tied to value delivered : Of the XXXX debts I originally enrolled with Beyond Finance in XX/XX/XXXX, XXXX were debts owed to XXXX Bank XXXX By XX/XX/XXXX approximately XXXX years into my enrollment Beyond Finance had not initiated contact with XXXX regarding either debt. After being sued by Upstart in XX/XX/XXXX ( also a debt Beyond Finance had failed to negotiate timely ), I became concerned that I would face additional lawsuits from Chase if the inaction continued. On approximately XX/XX/XXXX, I called Beyond Finance and removed both XXXX debts from their program so I could negotiate them directly with the creditor. \nThe results speak for themselves : XXXX XXXX # XXXX : Originally enrolled at approximately {$5000.00}. By the time I negotiated directly with XXXX ( after XXXX years of Beyond Finance inaction ), the balance had grown to approximately {$6000.00} due to interest and fees during the delay. I settled this debt directly with XXXX for {$3200.00} less than the original enrolled amount and approximately 54 % of the grown balance. \nXXXX XXXX # XXXX : Originally enrolled at approximately {$2000.00}. By the time I negotiated directly with XXXX, the balance had grown to approximately {$3000.00}. I settled this debt directly with XXXX for {$1400.00} also less than the original enrolled amount and approximately 49 % of the grown balance. \nBoth XXXX debts were settled easily once I contacted XXXX directly. This directly contradicts Beyond Finances stated rationale for not contacting my creditors ( the settlement account did not yet have sufficient funds ) XXXX was clearly willing to negotiate favorable settlements with minimal effort. To fund these settlements, I again took early withdrawals from my XXXX ( k ) retirement account, incurring the same 10 % early withdrawal penalty, federal and state income taxes, and loss of future compound growth described above. However, by negotiating directly with XXXX rather than through Beyond Finance, I avoided what would otherwise have been approximately {$1700.00} in Beyond Finance fees on these XXXX debts ( calculated at 25 % of the {$7000.00} originally enrolled amount see fee structure concerns below ). \nFee structure concerns and misunderstanding : In a call with Beyond Finance on XX/XX/XXXX, when I requested a detailed XXXX XXXX of how my fees have been assessed and how my payments have been allocated, the representative confirmed that Beyond Finances fee structure is 25 % of the originally enrolled amount of each debt. This is materially different from my understanding at enrollment, which was that the fee would be 25 % of the negotiated/settled amount. These XXXX fee structures produce significantly different outcomes : If fees were 25 % of negotiated amounts : a {$10000.00} enrolled debt settled for {$5000.00} would generate a {$1200.00} fee. \nUnder XXXX Finances actual practice of 25 % of enrolled amounts : the same debt would generate a {$2500.00} fee twice as much. \nAcross my {$81000.00} in enrolled debt, this difference in fee structure represents thousands of dollars in fees beyond what I understood I was agreeing to at enrollment. This concern is amplified by XXXX Finances failure to provide a detailed fee accounting that would allow me to verify exactly how fees have been assessed. I am also concerned that charging fees based on enrolled ( rather than settled ) amounts XXXX not satisfy the FTC XXXX XXXX XXXX requirement that fees be proportionally tied to specific settled debts, particularly given that XXXX Finances program structure can result in debts growing significantly during periods of inaction, meaning the fee base ( enrolled amount ) becomes increasingly disconnected from the actual settled amount over time. \nThe cancellation of my XXXX debts also reveals another concern. When I called Beyond Finance to remove the XXXX Chase debts on approximately XX/XX/XXXX, I was not informed of any fees that had already been assessed against those debts ( despite Beyond Finances fee structure being 25 % of enrolled amount ). It is unclear whether fees had been charged on the XXXX debts during the XXXX years they sat in the program unaddressed, whether those fees were refunded upon cancellation, or whether they were quietly retained or applied to fees on other debts. This is precisely the kind of question that a complete fee accounting which Beyond Finance has been unable to provide would resolve. \nXXXX Finances default practices around payoff and continued withdrawals raise serious consumer protection concerns : In conversations with Beyond Finance about final payoff and program completion, the company disclosed XXXX default practices that I believe warrant the CFPBs attention : XXXX. Refusal to accelerate settlements without explicit instruction, even when funds are available. I was informed that even after I have deposited sufficient funds to settle my remaining debts, Beyond Finance will not accelerate the disbursement of those settlements unless I specifically instruct them to do so. Their default behavior is to disburse settlements slowly over the originally scheduled program timeline through XXXX, regardless of whether the funds in my dedicated account are sufficient to settle the remaining debts immediately. Because Beyond Finance continues to collect monthly service fees ( {$10.00} ) and other recurring fees ( BLP Monthly Fee {$14.00} ) for the entire duration that debts remain in Payments In Progress status, this default practice has the effect of maximizing the fees Beyond Finance can collect at the consumers direct expense. A consumer who is not aware that they must affirmatively request acceleration will pay months or years of additional fees that could otherwise be avoided. \nXXXX. Continued bi-weekly withdrawals beyond what is needed to complete the program, with refund at end as the default remedy. Beyond Finance also informed me that the bi-weekly {$520.00} XXXX withdrawals from my bank account will continue uninterrupted until the end of the originally scheduled program in XXXX, unless I specifically instruct them to stop. They explained that at the end of the scheduled program, their system performs an audit and refunds any overpayments. This means XXXX XXXX default practice is to continue withdrawing money from a consumers checking account even after the program is fully funded, hold those overpaid funds without interest, and only return them at the end of the original scheduled term placing the burden entirely on the consumer to know to instruct them otherwise. \nTogether, these XXXX default practices appear designed to extend the duration of consumers enrollment, maximize fee collection, and float consumer funds for extended periods. A consumer who is not financially sophisticated, who does not know to ask the specific questions I asked, or who simply trusts Beyond Finance to act in their best interest, will be financially harmed by these defaults. These practices raise serious concerns under the XXXX XXXX XXXX XXXX unfair, deceptive, or abusive acts and practices ( XXXX ) specifically, the prohibition on practices that take unreasonable advantage of the inability of the consumer to protect the interests of the consumer in selecting or using a consumer financial product or service, and the prohibition on practices that take unreasonable advantage of the reasonable reliance by the consumer on a covered person to act in the interests of the consumer. \nBeyond Finances in-app representations of program progress are misleading : The Beyond Finance XXXX app displays an Enrolled Debt screen that prominently features XXXX figures : Total Enrolled Debt : {$81000.00} and Estimated Debt Reduction : {$40000.00}. This {$40000.00} figure is displayed as a benefit of the program, suggesting savings of approximately 50 % of my enrolled debt. The actual financial reality is very different. As of XX/XX/XXXX, I have : Deposited approximately {$63000.00} into Beyond Finances program since XX/XX/XXXX, including approximately {$22000.00} in emergency lump-sum deposits funded by XXXX ( k ) withdrawals to settle lawsuits, and a separate voluntary {$3000.00} deposit made in an attempt to accelerate program completion ; Paid approximately {$800.00} in court filing fees out of pocket as a direct result of lawsuits the program made highly likely ; XXXX accounts Synchrony Bank XXXX {$2400.00} ), Bank of XXXX XXXX {$7500.00} ), and Upstart ( {$14000.00} ) still showing as Payments In Progress rather than settled, totaling {$24000.00} in unresolved debt ; An additional {$5300.00} remaining to deposit before graduating from the program. \nBy the time I complete the program, I will have paid approximately {$69000.00} in deposits to Beyond Finance ( {$63000.00} already deposited plus the {$5300.00} remaining ), plus approximately {$800.00} in out-of-pocket court costs, plus the substantial additional cost of XXXX ( k ) early withdrawal penalties, taxes, and lost compound growth against {$81000.00} in original debt. The program will have inflicted a XXXX credit drop, XXXX creditor lawsuits, and depletion of retirement savings along the way. The apps prominent display of a {$40000.00} Estimated Debt Reduction does not reflect XXXX XXXX fees, does not reflect the costs of lawsuits the program made highly likely by instructing me to stop paying creditors, does not reflect the retirement losses I was forced into to fund those settlements, and is materially misleading as a representation of the programs actual financial impact on my situation. \nConcerns regarding compliance with federal law : The FTCs Telemarketing XXXX XXXX ( XXXX CFR XXXX ( a ) ( XXXX ) ) prohibits debt relief companies from charging fees before settling a consumers debt, and requires that fees be proportionally tied to specific settled debts. XXXX Finances inability to produce a fee-by-fee accounting raises serious questions about whether the fees collected from me comply with this rule. XXXX Finances practice of continuing to collect fees during the lengthy periods in which it refused to contact my creditors citing insufficient settlement account funds raises additional questions about compliance with this rule. XXXX Finances fee structure of 25 % of originally enrolled amounts ( as opposed to negotiated/settled amounts ), particularly in combination with its practice of allowing debts to grow during periods of inaction, further raises questions about whether the fees are proportionally tied to specific settled debts as the XXXX requires. The companys specific misrepresentation that my {$3000.00} voluntary deposit would be used to negotiate my final remaining debt, when it was in fact applied to fees on previously settled debts, raises further serious concerns about both XXXX XXXX XXXX compliance and the truthfulness of representations made to solicit voluntary additional payments. I am further concerned that the representations made at enrollment regarding credit impact and legal coverage, combined with the companys materially misleading written disclosures, in-app representations of program savings, and default practices that maximize fee collection and float consumer funds without consumer benefit, XXXX constitute deceptive or abusive practices under the XXXX Acts prohibition on unfair, deceptive, or abusive acts and practices ( XXXX ). \nXXXX requested : I am requesting a full refund of all fees collected by Beyond Finance from my account since enrollment on XX/XX/XXXX. The companys misrepresentations, instructions, and inaction led directly to XXXX lawsuits, the forced liquidation of retirement savings ( including the associated 10 % early withdrawal penalties, federal and state income taxes on the withdrawn amounts, and loss of future compound growth ) to fund settlements totaling approximately {$22000.00} ( plus additional XXXX ( k ) withdrawals to settle the XXXX XXXX debts I had to negotiate directly ), approximately {$800.00} in out-of-pocket court costs, a XXXX drop in my XXXX XXXX, and a program that when complete will have cost me approximately the same amount as the original {$81000.00} in enrolled debt while leaving me with severely damaged credit and depleted retirement savings. These outcomes are the opposite of what I was promised when I enrolled in this XXXX program. \nI am additionally requesting that the CFPB investigate XXXX Finances default practices of ( a ) refusing to accelerate settlements when funds are available without explicit consumer instruction, and ( b ) continuing bi-weekly bank withdrawals beyond what is needed to complete the program until the end of the originally scheduled program term, with refund of overpayments only at audit. These defaults appear designed to maximize fee collection and float consumer funds at consumer expense, and I believe they warrant investigation regardless of the outcome of my individual refund request. \nI am also requesting that the CFPB investigate XXXX Finances fee structure of 25 % of originally enrolled debt amounts particularly in light of its practice of allowing debts to grow during extended periods of inaction. I request investigation of whether this fee structure complies with the FTC XXXX XXXX XXXX requirement that fees be proportionally tied to specific settled debts, and whether XXXX Finances representations at enrollment about the fee structure were materially clear regarding whether fees would be based on enrolled or negotiated amounts. \nGiven Beyond Finances inability to provide a complete and detailed fee accounting on request, I am also requesting that the CFPB direct the company to produce : ( XXXX ) a complete, itemized accounting of every fee charged to my account from XX/XX/XXXX forward ; ( XXXX ) the specific debt each fee was associated with ; ( XXXX ) how each fee was calculated ; ( XXXX ) whether any fees were assessed on the XXXX Chase debts during the XXXX years they sat in the program before I removed them, and if so, whether those fees were refunded ; and ( XXXX ) the missing transaction records from XX/XX/XXXX through early XX/XX/XXXX that are not reflected in the ledger I was provided.","date_sent_to_company":"2026-05-14T17:37:16.000Z","issue":"Didn't provide services promised","sub_product":"Debt settlement","zip_code":"91601","tags":null,"has_narrative":true,"complaint_id":"22208230","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Consumer Financial Services Solutions, Inc.","date_received":"2026-05-14T17:04:10.000Z","state":"CA","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["This means XXXX XXXX default practice is to continue <em>withdrawing</em> money from a consumers checking <em>account</em> even after the program is fully funded, hold those overpaid <em>funds</em> <em>without</em> interest, and only return them at the end of the original scheduled term placing the burden entirely on the consumer to know to instruct them otherwise."]},"sort":[10.830484,"22208230"]},{"_index":"complaint-public-v1","_id":"17760799","_score":10.74898,"_source":{"product":"Checking or savings account","complaint_what_happened":"On XX/XX/XXXX, I transferred {$30000.00} into a SoFi high yield savings account after seeing SoFis promotional language stating Supercharge your savings and earn up to 4.30 % APY and Earn up to 4.30 % APY on the account opening page. These statements appeared prominently and implied that opening the account would provide access to the advertised APY. The conditions were not clearly presented on the pages I accessed when I signed up for the account. \n\nAfter depositing the funds, I discovered that my APY was conditional on meeting recurring XXXXday requirements that were not made clear upfront. The requirement shown to me only after depositing stated : To keep earning our highest APY *, at least XXXX account holder must complete XXXX of the following : Receive a direct deposit every XXXXDay Evaluation Period, Deposit {$5000.00} or more every XXXXDay Evaluation Period, Pay the SoFi XX/XX/XXXX subscription fee every XX/XX/XXXX days. This requirement was never presented clearly before my deposit. \n\nI contacted SoFi support. My initial message said : Hi. I need help immediately. The APY requirements on my account were not clearly disclosed when I opened it. I am filing a CFPB complaint about misleading presentation of the rate terms, and Im preparing to move all my funds out as soon as they clear unless this can somehow be resolved. \n\nWhen the agent asked what requirements I was referring to, I pasted their own APY condition text. I told them : I would never knowingly agree to a savings rate that requires paying a subscription fee. That is XXXX of the least consumer-friendly practices Ive ever seen. The requirement was buried and absolutely not presented in a clear or prominent way. \n\nThe SoFi representative responded : Yes that is really the requirements of sofi to get the highest apy. \n\nLater, the supervisor said : These are the requirements for maintaining our highest available APY and they are not able to be changed. \n\nDuring the escalation process, I stated : It was not presented clearly on the pages I accessed to sign up for the account and requested a resolution. I asked them clearly for confirmation : I want confirmation that you will maintain my current APY for this evaluation period without requiring a SoFi XX/XX/XXXX subscription or any additional qualifying deposit. \n\nThey refused and reiterated that the APY conditions could not be changed. \n\nAt no point did SoFi offer to honor the APY they advertised at the time I deposited {$30000.00}, nor did they address the lack of clear disclosure during signup. Instead, they insisted the rate would only apply if I paid a subscription fee or met recurring deposit requirements. \n\nSoFis advertising ( Supercharge your savings and earn up to 4.30 % APY, Earn up to 4.30 % APY ) did not clearly disclose these paywalled conditions. The APY terms are only shown in fine print ( Earn up to 4.30 % APY on XXXX XXXX with a 0.70 % APY Boost Open a new SoFi Checking & Savings account and enroll in SoFi XX/XX/XXXX Rates variable, subject to change ), and these terms were not apparent during the signup flow. \n\nThis creates a misleading and deceptive impression that simply opening the account provides access to the advertised APY, when in reality the rate is locked behind ongoing requirements, including paying a subscription fee.\n\nI am withdrawing my funds from SoFi as a result and request that the CFPB review SoFis APY advertising and onboarding disclosures for compliance with federal truth-in-savings and unfair or deceptive practices standards. \n\nThe conduct described above is not only misleading in a common-sense consumer understanding, it also aligns closely with what federal courts and regulators have repeatedly held to be deceptive under the Consumer Financial Protection Act ( XXXX ), the Truth in Savings Act ( XXXX ), and the long-standing FTC Act deception standard incorporated into CFPB enforcement. \n\nUnder XXXX, XXXX XXXX. XXXX, a practice is deceptive if : A representation, omission, or practice is likely to mislead a consumer The consumers interpretation is reasonable under the circumstances The misleading information is material Every part of this standard fits SoFis APY advertising. \n\nXXXX. Likely to mislead hidden APY conditions courts reject Federal courts have consistently held that financial advertisements are deceptive when the headline promise is contradicted by buried or unclear conditions. \nExamples include : FTC v. XXXX, XXXX, XXXX XXXX XXXX ( XXXXXX/XX/XXXXXXXX ) XX/XX/XXXXXXXX XXXX held a marketing claim deceptive because the \" net impression '' of the offer misled consumerseven though technical conditions existed somewhere in the fine print. The court emphasized that what matters is the overall takeaway, not isolated disclaimers. \n\nCFPB XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX. XXXX XXXX ( XX/XX/XXXX. XXXX ) The court affirmed that financial offers are deceptive when key conditions are buried in secondary text, making consumers reasonably believe a benefit is available when it is not. \n\nCFPB XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XX/XX/XXXX XXXX ) The deception finding turned on how a company structured its product so consumers were inevitably misled despite the existence of detailed terms elsewhere. \n\nSoFis use of Earn up to 4.30 % APY in bold, large fonts while burying the SoFi XXXX condition below the fold fits the exact pattern these cases condemn. \n\nXXXX. Reasonable consumer standard headline APY dominates The CFPB applies a reasonable consumer standard, not a sophisticated financial-professional standard. \n\nThe big bold headline Supercharge your savings and earn up to 4.30 % APY defines the reasonable consumers understanding. \n\nHigh Yield Savings Account - Op Courts have repeatedly ruled that : Consumers read headlines, not footnotes Fine-print or Terms apply language does not cure a misleading headline See : FTC XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX ) underlying district court findings emphasized that consumers initial takeaway controls. \n\nIn re XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( FTC ) disclaimers can not take back the promise made upfront. \n\nA reasonable consumer opening an account after reading earn up to 4.30 % APY would not assume they must pay a subscription fee everyXX/XX/XXXX days to maintain the rate. \n\nXXXX. Materiality APY is a core financial term APY is XXXX of the most material terms in retail banking. \n\nUnder XXXX ( XXXX XXXX XXXX ) and CFPB official commentary : Interest rate disclosures must be clear and conspicuous at the time of advertising. \n\nMaterial conditions affecting APY must be disclosed in close proximity to the APY statement Advertisements may not present a higher APY without immediately and clearly disclosing conditions required to obtain that APY SoFis presentation separates : Headline : Supercharge your savings and earn up to 4.30 % APY Hidden condition : Enroll in SoFi XX/XX/XXXXPay the SoFi XX/XX/XXXX subscription fee every XX/XX/XXXX days These conditions are nowhere near the headline, violating the proximity requirement recognized in XXXX XXXX XXXX ( b ). \n\nXXXX. The net impression test the nail in the coffin Both the FTC and CFPB rely on the net impression test, reaffirmed in : FTC XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) CFPB XXXX XXXX, XXXX XXXX XXXX ( XXXX XX/XX/XXXXXXXX ) CFPB XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XX/XX/XXXXXXXX. XXXX ) Even if all SoFis terms existed somewhere on the page, what matters is the impression created in the consumers mind by the marketing. \n\nThe net impression of the SoFi page is that opening the account allows consumers to earn the 4.30 percent APY. The fact that the rate is actually contingent on : paying a subscription fee or repeatedly hitting deposit rules or maintaining direct deposits changes the substance of the offer. \n\nCourts uniformly treat this mismatch as deceptive. \n\nXXXX. Paywalling an APY is itself unusual and material Courts have held that when a financial institution conditions a benefit on non-standard or surprising requirements, those requirements must be clearly and prominently disclosed. \n\nSee : CFPB XXXX XXXX XXXX Bank, XXXX XXXX XXXX ( XXXX XXXX XXXX ) undisclosed non-standard conditions on financial benefits were ruled deceptive and unfair. \n\nA bank requiring a subscription fee to obtain an interest rate is non-standard in retail banking and requires unmistakable disclosure. \n\nXXXX. Misleading by omission buried conditions are treated as deception The law recognizes deceptive omission when a company fails to disclose material restrictions that would affect a consumers decision. \n\nThis was reaffirmed in : FTC XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) CFPB XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XX/XX/XXXXXXXX ) SoFis failure to place its APY conditions clearly alongside the APY statement is an omission that directly impacts a consumers financial decision precisely the type regulators target. \n\nConclusion ( for the CFPB reviewer ) SoFis advertising meets every element of a deceptive financial practice under the CFPA, violates the clear and conspicuous requirements of the Truth in Savings Act, and creates a misleading net impression under binding federal case law. Conditioning an advertised APY on a hidden subscription fee or recurring direct-deposit requirements is not standard industry practice and must be disclosed prominently at the point where the APY is advertised.","date_sent_to_company":"2025-11-21T02:12:24.000Z","issue":"Opening an account","sub_product":"Savings account","zip_code":"21060","tags":"Servicemember","has_narrative":true,"complaint_id":"17760799","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"SOFI TECHNOLOGIES, INC.","date_received":"2025-11-21T01:27:30.000Z","state":"MD","company_public_response":null,"sub_issue":"Didn't receive terms that were advertised"},"highlight":{"complaint_what_happened":["I am <em>withdrawing</em> my <em>funds</em> from SoFi as a result and request that the CFPB review SoFis APY advertising and onboarding disclosures for compliance with federal truth-in-savings and unfair or <em>deceptive</em> practices standards."],"product":["Checking or savings <em>account</em>"],"issue":["Opening an <em>account</em>"],"sub_product":["Savings <em>account</em>"]},"sort":[10.74898,"17760799"]},{"_index":"complaint-public-v1","_id":"18405340","_score":10.629744,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  XXXX Phone XXXX XXXX XXXX XXXX XXXX Email XXXX XXXX XXXX XXXX Date : * * [ Insert Date ] * * Via Certified Mail and Electronic Submission * * * * To : XXXX XXXX XXXX XXXX President & Chief Executive Officer PayPal Holdings , Inc. ( including XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Cc : * * Executive Relations/ Customer Advocacy Human Resources & Compliance PayPal Holdings , Inc. \n\n* * * # # # Mandate, Notice of Dispute, and Impact Statement * * Re : XXXX  Account Suspension, Frozen Funds, and Mishandling of Unauthorized Activity * * I, XXXX XXXX XXXX XXXX XXXX XXXX XXXX am the verified owner of a XXXX  account under the name XXXX XXXX XXXX XXXX XXXX XXXX, username XXXX XXXX XXXX XXXX XXXX, associated with email * * XXXX * * and phone * * ( XXXX ) XXXX * *, and residing at XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX My XXXX  app currently shows a banner stating Your XXXX  account has been suspended while simultaneously displaying an available balance of * * {$38.00} * * that I can not access, transfer, or close out. When I attempt to close the account, I receive the message We cant close your account at the moment Your account requires further assistance. Contact our support team for more details. Screenshots documenting these facts are available and will be produced as evidence. \n\n* * * # # # I. Factual Background 1. On or about [ insert approximate date ], my XXXX  debit card and/or linked account were used without my authorization.\n\n2. Upon discovering these unauthorized transactions, I promptly reported the misuse to XXXX  in good faith and complied with all security and verification steps requested of me.\n\n3. In response, XXXX  suspended my account and disabled my card rather than simply removing the fraudulent transactions and preserving my access to the undisputed balance.\n\n4. Since that time, my account has remained in suspended status ; my card is unusable ; I am unable to withdraw or transfer my legitimate balance of {$38.00} ; and I am prevented from closing the account. \n5. Repeated attempts to obtain a clear, written explanation and timely resolution through XXXXPayPals customerservice channels have been unsuccessful, and no lawful justification for indefinite retention of my funds has been provided. \n\nThese actions convert a consumers fraud report into a pretext for effectively seizing funds that do not belong to XXXXPayPal and constitute an ongoing harm. \n\n* * * # # # II. Legal Framework ( Summary ) Without limiting any additional claims, the conduct described above appears inconsistent with, and potentially in violation of : 1. * * Federal protections for unauthorized electronic fund transfers * *, which require prompt and goodfaith investigation of reported unauthorized activity, limitation of consumer liability where notice is timely, and restoration or provisional credit of funds when warranted.\n\n2. * * Federal prohibitions on unfair or deceptive acts or practices * * in connection with consumerfinancial products and services, including misleading representations about access to funds and failure to follow stated disputeresolution procedures.\n\n3. * * XXXX consumerprotection and contractlaw principles * *, which prohibit unfair practices and badfaith interference with a customers access to their own money and recognize an implied covenant of good faith and fair dealing in every contract.\n\nXXXX  and PayPal publicly present their services as secure and consumerprotective. Freezing my account and effectively seizing my remaining balance after a goodfaith fraud report, while refusing to provide a clear and timely explanation, is incompatible with those representations and the above legal framework. \n\n* * * # # # III. Impact Statement As a direct and foreseeable result of XXXXPayPals actions and omissions : 1. * * Financial Hardship * * The sudden and continuing loss of access to my funds has interfered with my ability to pay for necessities, including food, transportation, and basic living expenses. I have had to rearrange payments and scramble for alternatives to cover ordinary obligations that these funds were intended to support.\n\n2. * * Emotional and Physical Stress * * Knowing that my account was compromised and that the institution responsible for protecting my funds responded by trapping the remaining balance has caused sustained stress, XXXX, and loss of sleep. Each failed attempt to secure an explanation or remedy has intensified this distress and significantly eroded my confidence in XXXXPayPal. \n\n3. * * Time and Opportunity Costs * * I have expended substantial time documenting the situation, contacting support, researching my rights, and preparing formal complaints. This time has been taken away from professional responsibilities and personal obligations and is solely attributable to XXXXPayPals mishandling of my account.\n\n4. * * Risk of Ongoing and Future Harm * * Because XXXX/PayPal has not clearly distinguished me, as a fraud victim, from the unauthorized activity itself, I face the risk that my name or account will be improperly tagged as highrisk or otherwise impaired in internal systems or with other financial institutions. Prolonged inaction increases the risk of reputational damage and future denial of services. \n\nThis is not a minor inconvenience. It is a continuing deprivation of my lawful property and a breakdown of the trust necessary for any consumerfinancial relationship. \n\n* * * # # # IV. Mandate and Demands In light of the foregoing, I hereby issue the following mandate and formal demands. These are made without prejudice to any additional rights and remedies available to me in law or equity. \n\n1. * * Immediate Financial Remediation ( within XXXX hours of confirmed receipt ) * * a. Restore full access to my XXXX  account and card; * * or * * b. Immediately transfer my entire nondisputed balance, including the {$38.00} currently frozen, to my linked bank account or remit those funds by check to my mailing address ; and c. Reverse and reimburse all unauthorized transactions and any related fees.\n\n2. * * Compensation for Harm and Inconvenience * * Tender a payment of * * {$2500.00} * * as compensation for financial hardship, time, stress, and disruption directly caused by XXXX/PayPals mishandling of my fraud report and the prolonged freeze and effective seizure of my funds.\n\n3. * * Written Explanation and Internal Accountability * * Provide a signed, written explanation that : - Identifies the precise reasons and internal codes used to justify my account suspension and the freezing of funds ; - Specifies the policies and procedures your staff relied upon in handling my case ; and - Describes in detail the steps taken by XXXXPayPal personnel to investigate this matter and why my access has not been restored.\n\nAdditionally, confirm that this incident has been escalated to Human Resources, Compliance, and relevant riskmanagement leadership and that appropriate corrective, disciplinary, or remedial measures will be taken if violations of policy or law are identified.\n\n4. * * Assurance Against Further Harm * * Provide written assurance that : - No negative or misleading information related to this incident will be reported to any consumer reporting agency ; and- I will not be designated as highrisk or otherwise penalized within XXXXPayPal systems solely because I reported fraud in good faith.\n\n* * * # # # V. Notice of Intended Legal and Regulatory Action If XXXX/PayPal does not fully comply with this mandate within * * ten ( 10 ) calendar days * * of confirmed receipt of this letter, I will, without additional notice : 1. File comprehensive complaints with the appropriate state and federal authorities, including the United States Attorney General, the Missouri Attorney General, the Consumer Financial Protection Bureau, and any other relevant regulators or enforcement agencies, detailing the facts and enclosing supporting evidence.\n\n2. Initiate formal proceedings under XXXX/PayPals own disputeresolution and arbitration provisions, seeking release of my funds, statutory and actual damages, costs, and any other relief available.\n\n3. Pursue additional civil claims in the proper forum, including but not limited to breach of contract, breach of the implied covenant of good faith and fair dealing, conversion, and unfair or deceptive practices.\n\n4. Cooperate fully with any lawenforcement or regulatory investigation into whether XXXXPayPals conduct, individually or as part of a broader pattern, warrants civil and/or criminal enforcement. \n\nI prefer to resolve this matter swiftly and amicably if XXXXPayPal acts in good faith, complies with applicable law, and honors the mandates set forth above. \n\nRespectfully, _____________________________ XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Email XXXX XXXX Phone XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX # # Forwarding Cover Letter to Attorney General ( Attachment : Mandate Above ) You can paste this into a second Word document and attach the signed mandate as an enclosure. \n\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Phone XXXX XXXX XXXX XXXX XXXX Email XXXX XXXX XXXX XXXX Date : * * [ Insert Date ] * * Via Certified Mail * * * * To : * * XXXX XXXX United States Attorney General [ Office Address ] * * Re : Request for Review and Enforcement XXXX/PayPal Handling of Consumer Funds and Unauthorized Activity * * Attorney General XXXX, Enclosed please find my * * Mandate, Notice of Dispute, and Impact Statement * * addressed to XXXX  and its parent company, PayPal Holdings , Inc. , concerning the suspension of my XXXX  account, the freezing of my funds, and the mishandling of my report of unauthorized activity. \n\nI respectfully request that your office review the enclosed document and evidence, evaluate whether the conduct described violates federal consumerprotection, banking, electronicfundtransfer, or fraud statutes, and, where appropriate, initiate or refer civil and/or criminal enforcement actions. \n\nI am prepared to provide sworn testimony, complete transaction records, and any further documentation your office may require. Please direct any written response to my mailing address above, with a copy by email if possible. \n\nRespectfully, _____________________________ * * XXXX XXXX XXXX * * Enclosure : Mandate, Notice of Dispute, and Impact Statement addressed to PayPal/XXXX  CEO Citations : [ XXXX ] XXXXXXXX XXXX XXXX XXXXXXXX [ XXXX ] XXXX XXXX XXXX XXXXXXXX [ XXXX ] XXXXXXXX XXXX XXXX XXXXXXXX","date_sent_to_company":"2026-01-12T22:44:45.000Z","issue":"Unauthorized transactions or other transaction problem","sub_product":"Mobile or digital wallet","zip_code":"645XX","tags":"Servicemember","has_narrative":true,"complaint_id":"18405340","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Paypal Holdings, Inc","date_received":"2026-01-01T17:57:11.000Z","state":"MO","company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["Legal Framework ( Summary ) <em>Without</em> limiting any additional claims, the conduct described above <em>appears</em> inconsistent with, and potentially in violation of : 1. * * Federal protections for unauthorized electronic fund transfers * *, which require prompt and goodfaith investigation of reported unauthorized activity, limitation of consumer liability where notice is timely, and restoration or provisional credit of <em>funds</em> when warranted.\n\n2. * * Federal prohibitions on unfair or <em>deceptive</em> acts or practices"]},"sort":[10.629744,"18405340"]},{"_index":"complaint-public-v1","_id":"10216365","_score":10.063486,"_source":{"product":"Checking or savings account","complaint_what_happened":"Update on this: \nI am now demanding my money from chase. You cannot indefinitely hold my funds as Federal Regulation will always supersede Chase policies. \n\nPlease refer to the following Federal Regulations; According to Regulation CC (Expedited Funds Availability Act), banks are generally required to make funds from deposited checks available to customers within a specified timeframe. If a bank is unable to verify a third-party check through their own investigation, they are still obligated to follow the guidelines outlined in Regulation CC regarding funds availability. If a bank is unable to verify a third-party check but has no reason to suspect fraud, they may release the funds according to the standard funds availability schedule outlined in Regulation CC. The maximum number of days a bank can withhold funds is determined by federal regulations outlined in Regulation CC (Expedited Funds Availability Act).\nUnder Regulation CC, banks generally must make funds from deposited checks available to customers within specific timeframes. If a bank's investigation does not uncover any wrongdoing, they are generally expected to release the funds back to the consumer promptly. Failure to do so could potentially violate Regulation E and result in regulatory action.\n\nThis being said, I will be opening a lawsuit, and have contacted my state attorney general. \n\nHere is my original inquiry:\n\nHello, My name is XXXX XXXX. I had an opened case with Chase and the CFPB in regards to a XXXX check deposited into my account, that was not only improperly deposited by the branch manager, but also marked as fraudulent. It was a life insurance claim written over to me by my father, from my passing mother. In the response I received from Chase, I was told to open up an Estate account, after visiting a branch to do so, I was infomed by not only executive offices, but the fraud team that despite this being an option provided to me, neither could guarantee that my funds would be released to me. As my father isnt the one who is dead, but my mother is. The check is not made payable to my mother. I have also provided evidence that the phone number i have provided multiple times is by no mistake, registered to my father, Through the XXXX system. I have attached documentation and photos proving that. XXXX has been assigned my case and has not been helpful at all. It does not feel as if she even knows what should be done, or what the definitive answer is despite the response being told to my be Chase themselves. My case XXXX with XXXX  is XXXX as well as XXXX My Savings Account XXXX  ends in XXXX  My Checking Account XXXX ends in XXXX.\n\nI have recently contacted XXXX  and her assistance has been abysmal. Not only was I interrupted multiple times, the lack of communication for the past month and lack of a proper solution has blown me. I was told they will be attempting sending back the funds despite closing both my checking and savings accounts, debiting from my direct deposit, and holding my money in suspension. The check has not even been properly deposited (lack of stamp) and i was not informed by ANYONE that all i needed to do was sign my name as well. for such a simple mistake, i shouldnt be waiting MONTHS for a solution, and refuse to.\n\nChase and the CFPB have closed my case again, stating the following: \n\nThank you for expressing your concerns to the Consumer Financial Protection Bureau. We appreciate you allowing us the opportunity to research this matter. We completed our review and the details of our response are below.  We appreciate you taking the time to tell us about our service. Your feedback helps us serve you better. Our goal is to provide you with exceptional service, and we are sorry if we fell short with your request to release funds from your third-party check deposit.  You may open an estate account as previously advised, a joint account with the third-party or the third-party may open an account with you as the Power of Attorney (POA). Estate and POA documents would need to be approved. All accounts are subject to secondary review through our new account screening process.  A new account does not guarantee the third-party deposit for XXXX being held form your closed account will be credited to a new account.  The condition still must be met for a verbal confirmation on a verified number that satisfies our internal risk tools to verify that you had permission to deposit the check into your account from the third-party.  We are not able to accept the documentation you provided showing ownership of the phone number for the third-party.  We provided the option to send the funds back to the maker; you declined to send the funds back.  The funds will remain on hold until the third-party authorization is resolved.  The agreement we have with each other is that we may remove funds from your account to hold them pending investigation. You can find this in the Deposit Account Agreement. You were provided a copy of the agreement when you opened the account. You can see the current agreement on chase.com.\n\nNowhere does chase state their official Deposit Agreement policies in regards to this that I must open an estate account to cash a third party check, nor does it list anywhere that its subject to secondary review. The words secondary review are not even listed a single time in the deposit account agreement. attached is that same agreement and a search of the same agreement to determine that. Chase has stated making an exception, yet i have not been informed of what this exception is. \n\nMisleading and deceptive business practices are occurring in the sense that in the very last response I received from chase I was given the option to open an Estate account, despite the funds not being written off to, or paid out to an estate. XXXX  is not dead, my Mother is. I was also given the option to open up a joint account, but why have I been told those are options to recieve my funds back then immediately be told afterwards that there is no guarantee that the money on hold will be credited to your account. why? this implies even the original payee that theyre trying so hard to verify cannot even use their own account with me to receive the funds from the check written out to them if we even got that far. So why offer it as an option? Option means we can use it as a means to get access to my money.\n\nI have expressed concerns about being paired up with XXXX  in regards to my case, and immediately got assigned to her AGAIN when the case was reopened. I grew tired of working with XXXX, and requested to work with someone else, and got in contact with XXXX. XXXX, the alleged managerdid not assign my case to a new representative, and instead closed the case, providing the same misleading and bogus reasoning listed to me before. Previous statement is also attached.\n\nOn Chases Deposit account agreement, it lists \nXXXX. A power of attorney is a document you sign that authorizes someone else, called the agent, to act on your behalf. If you sign a power of attorney, the agent can sign on your behalf and do anything you could do regarding the account, including withdrawing or spending all of the money in the account. Do not sign a power of attorney unless you trust the agent to act in your best interest. If you choose to add an agent, you must provide a power of attorney form that we agree to accept. We may rely on a copy of an original power of attorney. We are not required to investigate the facts relating to any power of attorney provided to us on your behalf, including whether your signature on the power of attorney is authentic or whether the agent continues to have authority. We may follow or refuse to follow the agent's instructions at any time, including if we suspect fraud or abuse on your account, unless state law requires otherwise. We may also refuse an agent's request to become a joint owner or a beneficiary of an account, but we have no liability to anyone if we do so. We have no liability when we follow or refuse to follow any instructions from an agent, for example, if your agent misuses the authority you have given them. An agent's power of attorney on an account is terminated when the account owner dies.\n\nIn my XXXX  document, I have been given financial authority in all forms to the person the check was originally signed to, and according to Chases agreement, I should have been given right to deposit the check and access the funds written to me not only because I am power of attorney, but also because the check was written over to me. I do not need permission to manage funds or cash checks I am legally authorized to do so. If Chase would like to argue the contrary, I live in Virginia. I would love the law that lists otherwise to be stated to me. \n\nThere is nothing in chases policies directly listed publicly in regard to that information that proves the contrary, and if there is, I would like to see EXACTLY where it is listed that I cannot do so. Links and all. Secondary Review is not publicly listed nor actively enforced when checks are deposited at the branch, nor online, and is only in prospects of potential fraud, which does not apply since the check has cleared. It has not bounced; and if the check was fraudulent at all, Chase would not attempt to verify the original payee at all, which equally makes no sense considering the maker of the check is not an individual, it is an insurance company. The XXXX XXXX XXXX XXXX is not the maker of the check. Pending investigation equally makes no sense considering Chase cannot even verify nor find an original point of contact for Hartford Group or Brian on their own. No investigation is occurring and I request innate detail and evidence of what investigations have occurred. \n\nThe check would not have been written nor shipped to me if not proven and verified that I was power of Attorney. In my original complaint, I have attached how the check has been mailed out to me and provided to me because I am the power of Attorney, which is proven by my contacts with XXXX XXXX, the claims representative at XXXX. \n\nChase Endorsement Policies are listed as follows:\n\n2. Endorsements\nAn endorsement is a signature, stamp or other mark made on a check to transter the check to another person. If a check you deposited doesn't have your endorsement, we may endorse it for you or treat the check as if we had endorsed it. Either way, the effect will be as if you had endorsed the check. Also, any deposited check that appears to contain your stamped or facsimile endorsement will be treated as if you had actually endorsed it. We are not bound by any conditional or restrictive endorsements on a check you cash or deposit, or by any endorsement \"without recourse.\"\n\nI was told previously by chase executive offices, by I believe either XXXX  or XXXX, that I needed to sign the back of the check as well in order for it to not be placed on hold. So on top of the improper deposit of the check, Chase has stated it will treat any missing signatures as an endorsement on my behalf, meaning I did not need to sign the back of the check in order for it to also include my endorsement. Nowhere in the semantics of the policy does it state the contrary, or anything more needs to be required. The check should have deposited after the third party endorsement. \n\nThe Endorsement requirements are as follows:\n\nXXXX Endorsement requirements\nTo help ensure that checks you deposit or cash will be processed timely, your endorsement (and any other endorsement supplied by a co-payee) must be in the XXXX inch area that starts on the right side as viewed from the back. Payee or customer information must not be on any other part of the back of the check.\nIf you don't endorse your check properly and it causes us a loss, cost or expense, you have to pay that amount to us.\n\nAttached is the original check. As well as the deposit receipt for it. The check cleared and the funds of XXXX have cleared into my savings and have equally been debited out of them as a XXXX charge. The deposit has not netted a loss for Chase at all. There was no Fraud, and Chase does not list anywhere in their policies that they can take from a verified deposit. Again, if the policies list the contrary, give me more information than you can find the account agreement on chase.com because the account agreement isnt on chase.com either, its at: XXXX\n\nYou actually have to dig for the policy in order to find it.\n\nIn Chases rights and responsibilities for deposits, it states: \n\nXXXX Our rights and responsibilities for deposits\n\nIf you deposit or cash a check, or we send one for collection, we act only on your behalf. Our only responsibility is to exercise reasonable care. If we lose a check, you agree to use reasonable efforts to help us locate or replace it.\nWe will not be liable for the lack of care of any bank or third party we use to collect checks, or for checks lost during shipping. We may send checks to any bank or to the entity on which the check was written in our customary manner. We may have agreements with other banks regarding times and methods for collecting or returning items.\nWe may refuse a deposit, or part of a deposit, at any time. We also may refuse a deposit after initially accepting it. We can reverse any amount we have added to your balance for a deposited check and send the check on a collection basis even after we have taken physical possession of the check. We will not be liable to you for refusing a deposit, even if it causes us to decline any transactions you have already made.\nIf we refuse a deposit, we may take a check on a \"collection basis,\" which means we will not add funds to your balance until we have actually been paid for the check. If we process any check deposit on a \"collection basis,\" we will not add funds to your balance until we have actually been paid for the check by the other bank.\nIf the other bank charges us a collections or processing fee for any item, we will deduct that from your account or the amount credited to you. These charges or fees will be assessed even if the other bank does not pay us for the check or the funds have already been deposited to your account.\n\nReasonable care is not elaborated upon. I request the CFPB investigate as well what Chase specifically means by that terminology. The deposit made was done improperly, and reasonable care was not enforced. At no point was the deposit refused. The funds have not been sent back to the maker. They were illegally debited from my account for fraud and pending investigation and neither has occurred, and if any has, I would have been unable to open another checking account with chase, which I have done. Chase would equally have attempted to do their research and have failed to each time. Because no fraud is occurring. \n\nChases Policies for Overdrafts are listed as follows:\n\nXXXX  Overdraft Fees\nWe will charge an Overdraft Fee during nightly processing for any paid transaction posted on a business day when your account is overdrawn. If we return a transaction, we will not charge a fee. We will charge an Overdraft Fee for a transaction that may have been previously returned unpaid if it is later paid against an overdrawn balance. Special rules for everyday debit card transactions are described in the Electronic Funds Transfer Service Terms.\nRefer to your product information and Fee Schedule for information about what fees apply and how fees are calculated for your account. We may limit the number of Overdraft Fees we charge for a business day. For business accounts, we may charge interest on any amount you are overdrawn that you haven't repaid promptly.\n\n4. Overdraft Protection\nOverdraft Protection allows you to link one of your accounts as your backup account to your checking account to help pay an overdraft. If your checking account does not have enough money, we will use the available funds from your backup account to authorize or pay transactions.\n\nNone of this applies to pending ACH transfers, and after contacting my company, the ACH trace ID marked as: XXXX  was considered rejected by chase, but was never sent back to sender. Instead, Chase rescinded their rejection, took my direct deposit, debited my negative balance, and sent me back the remainder of my money. Despite their electronic transfer policy, which lists: \n\nXXXX Payments\n\nA. General Terms Applicable to Payments\ni. Your responsibilities: You authorize us to remove funds from your designated Pay From account for all Payments that *you initiate* and you agree to have sufficient available funds on the Send On date or Payment date for each such Payment you schedule.\nPlease note that if you have Chase Overdraft Protection for your Pay From account, available funds in the account that you use for overdraft protection are included in the determination of available funds for the Service. If there are insufficient available funds to cover a Current Day payment, we will not retry the payment and it will be immediately rejected. If sufficient funds are not in your account to cover a Current Day payment, we will not retry the transaction and the payment will be immediately rejected. In the case of Future Dated Payments, if sufficient funds are not in your account on the Send On or Payment date we may reject the request, or accept the request and process the payment for delivery (even if such payment processing causes you to exceed your credit limit or overdraw your account). In the alternative, if sufficient available credit or funds are not in your account on the Send On date or Payment date, we will automatically try to debit your account up to XXXX XXXX  more times on each of the XXXXXXXX XXXX succeeding Business Days. For these attempts, a status of \"Funds Needed\" will appear online. After the final attempt, the payment request will be Cancelled. A status of\n\"Funding Failed\" will appear. We will send you a message advising you of each failed attempt to debit your Pay From account. You agree that we may, at our option, follow your Instructions to make payments to a Payee, even though a charge to or a debit from your Pay From account may cause you to exceed your credit limit, or bring about or increase an overdraft. In the event of an overdraft to your Pay From account, we may charge any other of your accounts for the amount of the overdraft. For questions about your preauthorized Payments, you may contact us at the telephone number on your account statement or the front of our deposit account agreement.\nII. WE ARE NOT RESPONSIBLE FOR ANY CHARGES IMPOSED, OR ANY OTHER ACTION, BY A PAYEE RESULTING FROM A LATE PAYMENT, INCLUDING ANY APPLICABLE FINANCE CHARGES AND/OR LATE FEES UNLESS WE CAUSE PROCESSING DELAYS THAT CAUSE YOUR PAYMENT TO BE LATE.\n\nMy account was restricted, which meant I could not recieve any deposits. Chase cannot debit an amount they have no authority to recieve since I was not the one who initiated the transaction. My job was. Ironically enough, my account was maliciously closed immediately after they received my payment, despite this same policy stating they absolutely must notify me of that happening in my next statement. A statement I did not recieve, and equally was denied access to since my account was closed, and thus any access to my mobile banking. \n\nAnother discrepancy is listed in the account agreement here:\n\nb. Electronic transfers using your account number\nYou may authorize a third party to transfer funds to or from your account by providing your account number and your routing number or your debit card number. These transfers may use various payment networks and may take various forms, such as:\n* ??Employer payroll, government benefits or other direct deposits;\n* ??One-time or recurring charges to your account to pay bills or make a purchase;\n* ??Transfers between external accounts and your Chase accounts; or\n* ??A \"check conversion\" transfer, where a merchant or other payee creates an electronic transfer from your paper check. The merchant may keep your check or return it to you.\n\nIf that is the case, it also applies to a third party check, thus proving even more i am allowed to cash and use the funds made payable to me. Chase also provides a personal guide which me and the payee used when making sure the check was endorsed properly by third party means. \n\nThe guide is listed here: XXXX  \nThe instructions have been followed to a T. They have been listed as: XXXX Determine the recipient\nAssuming the check is written out to you, the recipient can be an individual, group of people or company. First, determine whether the recipient is willing to accept the signed-over check and exactly how the name should be written. XXXX Confirm the recipient's bank will accept the check\nBefore you start marking up the check, confirm that the financial institution (or other service) will accept a signed-over check. While many banks do, some do not, in order to manage risks.\n\nThe financial institution is chase. this is from YOUR website. \n\nXXXX  Sign the back of the check\nThe next step is signing (endorsing) your name on the back of the check in blue or black ink. On the back of the check, you'll see a signature line at the top where you sign your name as it appears in the payee field.\n\nThis has also been followed, and even if it wasnt, considering the vague language, any deposit would consider my depositing of the check as an endorsement alone if it was accepted by a branch. \n\nXXXX Include \"pay to the order of\" and write the recipient's name\nThis is the critical step that changes the payee written on the check from you to a new recipient.\nIn the check's current state, your name is in the payee field on the front of the check. In the endorsement area on the back of the check, at the top, use blue or black ink to write \"Pay to the order of\" followed by the new recipient's name.\nThis step tells the bank you are officially endorsing the transfer of funds to the new recipient. Your signature from the previous step serves as your authorization.\n\nYour signature from the previous step serves as your authorization. Chase has asked me to read the policies on their site. Im reading it. The signing from Brian himself is an authorization.\n\nXXXX Give the recipient the check to cash\nOnce the physical check is signed over, you can pass it to the recipient. If you have the opportunity, you can accompany the recipient to a branch location. This can offer everyone, including the financial institution, some extra assurance.\nOtherwise, if their bank allows it, the new check recipient can use mobile deposit.\n\nI equally followed this and was told by the Branch manager that as long as the address on the check as well as my account match, it will not be marked as fraudulent. Chase cannot continue to make up rules and arbitrations to hold their consumers money.\n\nI am no longer asking, but demanding my funds be returned to me by check, not only due to Chases deceptive practices, lack of customer service, and mishandling of my checking and savings account for fraudulent activity that was never fraudulent nor suspicious. \n\nI am also asking for another XXXX from chase themselves to avoid turning this into a lawsuit.\n\nUnder the Homeland Security Act and Patriot Act, banks have authority and duty to investigate suspicious payments.However, they CANNOT keep the money in your account and if they choose to close the account they must return the money in the account to you unless it is proven to be proceeds of money laundering and it is turned over to Homeland Security.\n\nNo fraud has been proven in any capacity whatsoever. Because no Fraud has occurred. \n\nI want my money back in full.","date_sent_to_company":"2024-09-24T07:15:20.000Z","issue":"Closing an account","sub_product":"Checking account","zip_code":"23060","tags":null,"has_narrative":true,"complaint_id":"10216365","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"JPMORGAN CHASE & CO.","date_received":"2024-09-24T07:10:30.000Z","state":"VA","company_public_response":null,"sub_issue":"Funds not received from closed account"},"highlight":{"complaint_what_happened":["In the alternative, if sufficient available credit or <em>funds</em> are not in your <em>account</em> on the Send On date or Payment date, we will automatically try to debit your <em>account</em> up to XXXX XXXX  more times on each of the XXXXXXXX XXXX succeeding Business Days. For these attempts, a status of \"<em>Funds</em> Needed\" will <em>appear</em> online. After the final attempt, the payment request will be Cancelled. A status of\n\"Funding Failed\" will <em>appear</em>."],"product":["Checking or savings <em>account</em>"],"issue":["Closing an <em>account</em>"],"sub_product":["Checking <em>account</em>"],"sub_issue":["<em>Funds</em> not received from closed <em>account</em>"]},"sort":[10.063486,"10216365"]},{"_index":"complaint-public-v1","_id":"19441791","_score":9.398778,"_source":{"product":"Vehicle loan or lease","complaint_what_happened":"To whom it may concern, I am submitting this formal complaint regarding Chase Autos handling of my refinance application ( XXXX ) submitted on or about XX/XX/XXXX. I am also filing a complaint with the Consumer Financial Protection Bureau ( CFPB ). \nThe facts outlined below demonstrate conduct that appears to violate the Dodd-Frank Acts prohibition against Unfair, Deceptive, or Abusive Acts or Practices ( UDAAP ), as well as applicable provisions of Regulation Z and the Equal Credit Opportunity Act ( ECOA ). \n\nChase repeatedly represented that I was approved for refinancing, provided specific loan terms, and communicated a clear validity window ( initially described as 60 days and later reflected as expiring XX/XX/XXXX ). I relied on those representations. To then deny the loan today on the basis that my vehicle aged or that mileage increased during the very timeframe Chase established is inherently contradictory. \n\nIf vehicle aging or mileage fluctuation during the offer period was a material underwriting risk, that risk should have been accounted for when the approval window was set or clearly disclosed as a condition that could void the approval. A lender can not extend a defined acceptance period, repeatedly confirm approval, and then rescind based on predictable passage of time within that same period. That is the functional equivalent of a bait-and-switch : representing that credit is approved and available through a stated deadline, while internally reserving the ability to withdraw it for foreseeable and undisclosed reasons. \n\nTimeline of events : XX/XX/XXXX I applied for a Chase auto refinance and submitted all required personal and credit information, including my Social Security number and vehicle details. \n\nXX/XX/XXXX I received written communication stating that my refinancing was approved ( See attachments ). The communications contained no clear conditional language indicating that the approval was preliminary or contingent upon future underwriting factors beyond standard documentation. \n\nDuring this process, I executed and mailed Power of Attorney documents via XXXX at Chases direction. \n\nIn XXXX, I was informed via phone call that the approved refinance amount was capped at {$15000.00}. Because my loan balance exceeded that amount, I was instructed that I would need to reduce the balance to qualify. In reliance on Chases repeated approval representations, I made over {$1500.00} in payments from personal funds to bring the balance below the approved threshold. \n\nXX/XX/XXXX at XXXX XXXX  I submitted a payoff letter showing a balance of {$15000.00}. ( See attachments ) XX/XX/XXXX I received XXXX separate emails ( see attachments ) within one hour ( XXXX XXXX, XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX ) stating : Congratulations, XXXX XXXX Youre approved for refinancing! Let us know if youre ready to move forward before these terms expire. \n\nALL of the emails specified : Approved Amount : {$15000.00} XXXX : 7.84 % Term : 60 months Expiration Date : XX/XX/XXXX Additionally, Chase representatives confirmed by phone that the next step was an e-signature and that a payoff check would be issued to my existing lender. This phone call took place early XXXX, a few days ago actually, after I kept getting those repeated emails for the next steps, but when I logged in there were no next steps other than waiting for an signature. The rep even advised I should be getting a link from a 3rd party for the signature. \n\nXX/XX/XXXX I received another email stating there was still time to take advantage of my approved refinancing. The online portal reflected that the next step was e-signature. ( See attachments ) XX/XX/XXXX at approximately XXXX XXXX  I received a call requesting updated mileage. Within approximately ten minutes of that call, I received -! Email that my application was denied ( see attachments ) When I called to inquire on XX/XX/XXXX, one representative stated that the denial was due to mileage increasing. A second representative later stated that mileage was not the sole factor and referenced vehicle aging and general underwriting considerations. The first agent I assume hung up on me because she was trying to explain something that didnt make sense. \n\nOn XX/XX/XXXX at approximately XXXX XXXX  EST, I received that call from a Chase representative requesting my vehicles updated mileage. I was not physically near the vehicle at that moment and provided my best estimate based on a recent oil change. \nWithin approximately ten minutes of that call, I received an email stating that my refinance application had been declined. \n\nThis sequence is deeply concerning. For months, Chase : Repeatedly sent written communications stating I was approved Displayed approved loan terms in the customer portal Listed the next step as e-signature Confirmed by phone that the next step was execution of documents and payoff processing Provided a clear expiration date extending into XX/XX/XXXX At no point was I clearly informed that a minor mileage increase or the routine passage of time during the stated validity period could void the approval. \n\nAt approximately XXXX XXXX, I contacted Chase and spoke with a representative for 26 minutes. After placing me on hold to consult internally, she stated that the application was denied due to the mileage increase. The call was disconnected when I challenged that statement - asking if Chase expected me to not use my primary vehicle during the application process ( entirely unreasonable ) and that Ive been advised Ive been approved and even a previous phone call stated I am just waiting for the Docusign? \n\nAt approximately XXXX XXXX, I called again and spoke with a second representative. He contradicted the prior explanation, stating that mileage was not the sole factor and referenced vehicle aging and general underwriting considerations such as my credit score. I then challenged him, saying that theyve had all my information, the age of the vehicle, all my personal info since they approved me but this one answer to a mileage question changed everything? He was stumped and said XXXX, whats done is done - a response from someone who clearly knows this isnt right but doesnt want to own the issue and escalate.\n\nThese inconsistent explanations raise serious concerns under the Equal Credit Opportunity Act ( 12 C.F.R. 1002.9 ), which requires creditors to provide specific and accurate reasons for adverse action.\n\nMore fundamentally, this situation raises concerns under the XXXX  Acts prohibition against Unfair, Deceptive, or Abusive Acts or Practices ( 12 U.S.C. 5531 ).\n\n5531 ). \n\nChase : Knew my vehicles age and mileage at the time of application. \nConducted a full credit review using my Social Security number.\n\nRequired and accepted executed Power of Attorney documentation.\n\nIssued multiple written approvals specifying amount, APR, term, and expiration date. \nEncouraged completion of remaining steps prior to the stated deadline. \n\nVehicle aging and mileage increase are entirely predictable during a multi-month approval window established by the lender itself. If those factors were material conditions that could void the approval during the stated validity period, that condition should have been clearly and conspicuously disclosed. \n\nInstead, I was repeatedly led to believe that my loan was approved and that execution was the only remaining step. In reliance on those representations, I paid over {$1500.00} from personal emergency funds to reduce my balance below the stated approved threshold. \n\nTo represent that credit is approved through a defined expiration date, while internally reserving the ability to rescind based on normal vehicle use during that same period, is materially misleading. A consumer can not reasonably be expected to refrain from driving their vehicle in order to preserve an approval that the lender represented as valid for months. \n\nThe denial only occurred immediately after updated mileage was requested despite months of prior approval communications containing identical vehicle and credit information. That sequence strongly suggests that material underwriting conditions were either not finalized at the time approval representations were made, or were not properly disclosed. \n\nAs a result of these actions, I have suffered financial harm and lost funds that were paid in direct reliance on Chases representations. \n\nGiven the facts outlined above, I am formally requesting that Chase honor the refinance approval under the originally stated terms ( approved amount of {$15000.00} at 7.84 % APR for 60 months, valid through the communicated expiration date ). \n\nIf Chase is unwilling to reinstate and fund the refinance under those terms, I expect full reimbursement of the funds I paidspecifically, $ XXXXto reduce my loan balance in direct reliance on Chases repeated written and verbal representations that my application was approved and a deletion of the inquiry off my credit report. \n\nThose payments were made solely to meet the stated approved threshold. Absent Chases approval representations, I would not have diverted those personal emergency funds. \n\nIf this matter is not resolved promptly and in good faith, I will continue pursuing all available legal and regulatory remedies, including escalation through the CFPB, state regulators, and consultation regarding civil claims arising from deceptive practices and detrimental reliance. \n\nI would prefer to resolve this without litigation, but I am fully prepared to proceed if necessary.","date_sent_to_company":"2026-02-12T05:15:11.000Z","issue":"Getting a loan or lease","sub_product":"Loan","zip_code":"333XX","tags":"Servicemember","has_narrative":true,"complaint_id":"19441791","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"JPMORGAN CHASE & CO.","date_received":"2026-02-12T04:57:01.000Z","state":"FL","company_public_response":null,"sub_issue":"Changes in terms mid-deal or after closing"},"highlight":{"complaint_what_happened":["Absent Chases approval representations, I would not have diverted those personal emergency <em>funds</em>. \n\nIf this matter is not resolved promptly and in good faith, I will continue pursuing all available legal and regulatory remedies, including escalation through the CFPB, state regulators, and consultation regarding civil claims arising from <em>deceptive</em> practices and detrimental reliance. \n\nI would prefer to resolve this <em>without</em> litigation, but I am fully prepared to proceed if necessary."]},"sort":[9.398778,"19441791"]},{"_index":"complaint-public-v1","_id":"20879785","_score":7.989517,"_source":{"product":"Checking or savings account","complaint_what_happened":"I. INTRODUCTION AND PURPOSE OF THIS COMPLAINT This complaint is filed as a new, comprehensive formal complaint against Navy Federal Credit Union ( NFCU ) following the inadequate and factually inaccurate response Navy Federal provided to CFPB Case No. XXXX. The prior complaint was closed on XX/XX/XXXX after I disputed Navy Federal 's response, indicating that their response did not address my issues, I did not understand their response, and they did not do what they said they would do. \nThis complaint addresses multiple serious federal violations including unauthorized electronic fund transfers, systemic internal accounting errors, retaliatory conduct, denial of legally required documentation, and the improper closure of my accounts during an active dispute period. The total financial harm I have suffered is substantial and has resulted in the depletion of inherited funds, returned payments, inability to pay essential bills, and significant financial instability. \n\nXXXX. BACKGROUND AND TIMELINE I established membership with Navy Federal Credit Union on XX/XX/XXXX. Beginning in XX/XX/XXXX, I noticed unauthorized and fraudulent transactions on my accounts. The following is a summary of key events : XX/XX/XXXX : Membership established with NFCU XXXX XXXX : Unauthorized transactions begin appearing on accounts XX/XX/XXXX : First fraud claims filed XX/XX/XXXX : Inheritance funds of {$98000.00} deposited via bank wire into savings account XXXX XXXX XXXX : Unauthorized transfers from savings to checking account begin, exposing inheritance funds to fraudulent debit card activity XX/XX/XXXX : {$2700.00} money order deposit NFCU text message confirmed available balance of {$2900.00} ; however, statement shows a completely different balance, constituting a documented three-way discrepancy between text notification, ATM receipt, and statement XX/XX/XXXX : AppFolio/Salesloft data breach discovered, exposing XXXX XXXX XXXX address, date of birth, and Social Security number to unauthorized actors XX/XX/XXXX : Additional fraud claims filed XX/XX/XXXX : Additional fraud claims filed XX/XX/XXXX : Navy Federal sends threatening letter warning me that continued fraud claims could result in XXXX suspension of debit card privileges sent while I was a confirmed data breach victim XX/XX/XXXX : XXXX formal data breach notification letter received XX/XX/XXXX : Granite School District data breach also exposed my personal information XX/XX/XXXX : I submitted formal Second Appeal with full evidence packet by email to multiple Navy Federal departments including Legal, Compliance, Executive Relations , and Fraud Operations XX/XX/XXXX : Navy Federal responds to prior CFPB complaint response is factually incomplete and fails to address core issues XX/XX/XXXX : I disputed Navy Federal 's CFPB response, marking all three questions as 'No ' XX/XX/XXXX : CFPB complaint closed without resolution III. SPECIFIC VIOLATIONS AND EVIDENCE A. Regulation XXXX Violations Failure to Conduct Lawful Investigation Under 12 C.F.R. 1005.11, Navy Federal is required to investigate error notices within XXXX business days, provide provisional credit where applicable, and furnish written explanation of findings including the documents relied upon. Navy Federal has violated each of these requirements : Navy Federal closed my dispute in approximately XXXX days without conducting a good-faith review or requesting additional information from me Navy Federal claimed I did not answer 'XXXX  questions ' but no such form or questionnaire was ever provided to me Navy Federal 's denial letters stated 'you have the right to request the documentation used in making this determination ' I requested this documentation in writing and it was never provided, in direct violation of Regulation E Navy Federal 's stated reasons for denial 'you benefited financially ' and 'you authorized and/or participated \" are conclusory allegations with no factual support or documentation provided The use of 'and/or ' in the denial language demonstrates that Navy Federal did not conduct a specific investigation but rather applied a generic template denial B. Documented Balance Discrepancies Internal Accounting Failures The following discrepancies are documented with physical ATM receipts, NFCU text message notifications, and bank statements. These discrepancies exist independent of any fraud claims and demonstrate a systemic internal accounting failure within Navy Federal 's ledger and statement generation systems : Discrepancy 1 XX/XX/XXXX ( Statement XXXX ) : ATM receipt ledger balance : {$52000.00} ATM receipt available balance : {$51000.00} Statement Page XXXX, Line XXXX balance : {$50000.00} Statement Page XXXX, Line XXXX balance : {$50000.00} XXXX different figures for the same account on the same date unexplained difference of over {$2100.00} Discrepancy XXXX XX/XX/XXXX : ATM receipt shows : {$1300.00} Statement Page XXXX, Line XXXX : {$2900.00} Statement Page XXXX, Line XXXX : {$2900.00} Statement Page XXXX, Line XXXX : {$2700.00} Balance changing across XXXX consecutive lines with no corresponding posted transactions Discrepancy XXXX XX/XX/XXXX : ATM receipt shows : {$4900.00} Statement Page XXXX, Line XXXX : {$3600.00} Unexplained difference of {$1200.00} Discrepancy XXXX XX/XX/XXXX ( Statement XXXX ) : XXXX XXXX XXXX ATM receipt dated XX/XX/XXXX XXXX XXXX XXXX, account ending XXXX : Receipt Ledger Balance : {$48000.00} Receipt Available Balance : {$46000.00} Statement Page XXXX, Line XXXX : {$47000.00} XXXX different figures {$1900.00} gap between ledger and available on the same receipt Discrepancy XXXX XX/XX/XXXX ( {$2700.00} deposit ) : NFCU text message ( from short code XXXX, XX/XX/XXXX at XXXXXXXX XXXX XXXX ) : \" {$2700.00} was deposited into your acct end. in XXXX. As of XX/XX/XXXX at XXXX XXXX  XXXX the avail. bal. is {$2900.00} ' ATM receipt available balance : {$2900.00} Statement Page XXXX, Line XXXX : {$4600.00} Statement Page XXXX, Line XXXX : {$1200.00} Navy Federal 's own text message contradicts their own statement this is documented in their system In their CFPB response, Navy Federal attempted to explain balance discrepancies by referencing their transaction posting order policy. This explanation is wholly inadequate and factually inapplicable because posting order does not explain why the ledger balance and available balance differ on the same receipt at the same moment, nor why the receipt balance differs from the statement balance for the same account on the same date. \n\nC. Unauthorized Transfers From Savings Account Following the deposit of my inheritance funds of {$98000.00} on XX/XX/XXXX, multiple large transfers were made from my savings account ( XXXX ) to my checking account that I did not initiate or authorize. These unauthorized transfers systematically moved my inherited funds from savings into checking where they were then exposed to fraudulent debit card activity. The pattern of transfers occurring in rapid succession in large round amounts is consistent with unauthorized account access rather than legitimate member-initiated transfers. \n\nXXXX XXXX Transactions My bank statements contain multiple instances of identical transactions posting on the same date for the same amount, which I have documented and flagged. Examples include duplicate XXXX XXXX Balance charges on the same day, duplicate XXXX XXXX charges, and duplicate XXXX charges. Navy Federal 's own text fraud alert system flagged card ending in XXXX for suspicious transactions including XXXX XXXX XXXX ( {$390.00} ) on XX/XX/XXXX and XXXX  ( {$3.00} ) on XX/XX/XXXX, yet these same transactions were used as evidence against me in the denial.\n\nE. Multiple Unauthorized Card Numbers and Account Access During the dispute period my Navy Federal profile had unauthorized phone numbers and accounts linked to it that I did not add. Multiple debit card numbers were active simultaneously including cards XXXX, XXXX, XXXX, XXXX, XXXX, XXXX, and XXXX appearing across statements in the same period. I received notifications of my card numbers being linked to XXXX accounts that are not mine. I was also informed that someone bypassed Navy Federal 's voice recognition system to gain access to my account, which Navy Federal 's security protocols should have prevented.\n\nF. Account Restriction During Active Dispute Navy Federal restricted my access to my account, statements, and transaction details during the period when fraudulent charges were occurring. This restriction directly prevented me from properly identifying, documenting, and disputing the unauthorized charges. This is particularly egregious because Navy Federal then used my inability to provide detailed documentation as justification for denying my claims. \n\nG. Retaliatory Threat Letter On XX/XX/XXXX, while I was a confirmed victim of XXXX separate data breaches and while my fraud claims were actively pending, XXXX XXXX sent me a threatening letter warning that I could have my debit card privileges suspended for up to XXXX years for filing 'suspicious claims. ' This letter was sent to both of my known addresses on the same date. This conduct is retaliatory, coercive, and constitutes an unfair, deceptive, and abusive act or practice under CFPB UDAAP authority, as it was designed to discourage me from exercising my federally protected right to dispute unauthorized transactions. \n\nH. Data Breaches and Compromised Identity I was the victim of XXXX documented data breaches during the period of fraudulent activity : XXXX XXXX XXXX data breach XX/XX/XXXX, exposing personal identifiable information AppFolio/Salesloft data breach discovered XX/XX/XXXX, formally notified XX/XX/XXXX ; breach exposed my name, address, date of birth, and Social Security number Navy Federal 's investigation made no attempt to consider whether my compromised identity from these data breaches contributed to the unauthorized account access. A proper Regulation E investigation would have considered this context. \n\nI. Merchant Refunds Not Credited XXXX formally processed a payment dispute for Full Self-Driving ( Supervised ) charges and confirmed in writing that the bank is responsible for refunding the original payment. Navy Federal has not processed or credited this refund to my account. \n\nJ. Account Closure During Active Dispute Navy Federal closed my accounts during the period of active dispute and regulatory complaint, leaving both my checking and savings accounts at XXXX. The final statement for period XXXX shows both accounts ending at {$0.00} with a notation that accounts were closed. This closure occurred while my disputes were unresolved and while I had an active regulatory complaint pending, leaving me without access to any funds. \n\nIV. FINANCIAL HARM As a direct result of Navy Federal 's failures, I have suffered the following documented financial harm : Depletion of inherited funds from a starting balance of approximately {$98000.00} through unauthorized transfers and fraudulent transactions Returned payments due to insufficient funds caused by account discrepancies Inability to pay essential bills during the dispute period Loss of account access preventing me from managing my finances Ongoing financial instability Professional risk I hold a state-issued professional license and any appearance of financial misconduct could jeopardize my career V. DEMANDS FOR RELIEF I respectfully request that the CFPB require Navy Federal Credit Union to : 1. Conduct a full forensic accounting reconciliation of all transactions across all affected accounts for the period XX/XX/XXXX through XX/XX/XXXX 2. Provide complete written documentation of all investigation findings for every denied claim, as required under Regulation E 3. Reimburse all unauthorized and fraudulent charges in accordance with the Electronic Fund Transfer Act ( 15 U.S.C. 1693 et seq. ) and Regulation E 4. Reimburse all funds lost through unauthorized transfers from savings account XXXX XXXX. Process the pending XXXX merchant refund 6. Explain and reconcile all documented balance discrepancies between ATM receipts, text message notifications, and bank statements 7. Withdraw and retract the retaliatory XX/XX/XXXX threat letter 8. Remove any adverse notations related to fraud claim activity from my member account record 9. Provide a full accounting of all account numbers, phone numbers, and devices that were linked to my membership profile during the dispute period VI. SUPPORTING EVIDENCE The following documents and evidence support this complaint and are available upon request : Physical ATM receipts showing balance discrepancies ( XXXX XXXX XXXX, XX/XX/XXXX ) Navy Federal deposit receipt showing {$2700.00} deposit ( XX/XX/XXXX ) NFCU text message notifications showing balances that contradict statements Navy Federal bank statements for periods XXXX with annotated discrepancies XXXX Federal XXXX XXXX text messages on card XXXX ( XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX ) Navy Federal security code warning texts ( XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX ) Navy Federal denial emails for debit card XXXX ( {$1000.00} and {$4400.00} ) Navy Federal threatening letter dated XX/XX/XXXX ( received XXXX copies ) XXXX payment dispute confirmation email AppFolio/Salesloft data breach notification letter dated XX/XX/XXXX XXXX XXXX XXXX data breach notification dated XX/XX/XXXX All formal appeal letters and legal notice emails sent to Navy Federal XX/XX/XXXX Prior CFPB complaint and Navy Federal response ( Case No. XXXX ) Call recordings of interactions with Navy Federal representatives VII. CONCLUSION Navy Federal Credit Union has repeatedly failed to conduct lawful investigations, has withheld documentation I am legally entitled to, has restricted my account during an active dispute, has retaliated against me for exercising my rights, and has provided responses to regulators that are factually incomplete and misleading. I am a victim of identity theft through XXXX documented data breaches, and Navy Federal 's failure to investigate properly has resulted in the loss of substantial inherited funds and ongoing financial harm. \nI respectfully request that the CFPB conduct a thorough investigation of this matter, impose appropriate penalties, and require Navy Federal to make me whole. \n\nRespectfully submitted,","date_sent_to_company":"2026-04-02T12:29:03.000Z","issue":"Managing an account","sub_product":"Checking account","zip_code":"758XX","tags":null,"has_narrative":true,"complaint_id":"20879785","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"NAVY FEDERAL CREDIT UNION","date_received":"2026-04-02T12:23:39.000Z","state":"TX","company_public_response":"Company believes it acted appropriately as authorized by contract or law","sub_issue":"Banking errors"},"highlight":{"complaint_what_happened":["This closure occurred while my disputes were unresolved and while I had an active regulatory complaint pending, leaving me <em>without</em> access to any <em>funds</em>. \n\nIV."],"product":["Checking or savings <em>account</em>"],"issue":["Managing an <em>account</em>"],"sub_product":["Checking <em>account</em>"]},"sort":[7.989517,"20879785"]},{"_index":"complaint-public-v1","_id":"10981005","_score":6.955957,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"XXXX XXXX XXXX XXXX XXXX XXXX\nConsumer Financial Protection Bureau (CFPB)\nXXXX XXXX XXXX XXXX XXXX, DC XXXX\nThis is to complain against RIA XXXX: HIGH\nIMPORTANCE: HIGH\n[WITHOUT PREJUDICE]\nI wish to practice my right as a customer of RIA to use your organisation's service, seeking a formal,\nimpartial investigation to amicably settle my dispute with RIA.\nIn order to clear up the myriad of letters and correspondences I have hitherto sent to RIA respecting my\ncomplaint, I believe it will substantially strengthen both my case and your understanding, by taking a\ndeeper look at the happenings of my case, and analysing the relevant facts in an objective and\ncomprehensive fashion.\nIt is crucial to note that I have been manipulated, socially-engineered and coerced to engage these\nfraudulent criminals. Much to my embarrassment, I recognise that I am the victim of an investment scam.\nMy complaint to the CFPB has arisen as I do not consider, by any stretch of the imagination, the conduct\nof RIA to be commensurate with their legal role and responsibility to their customers. They sell a service\nto look after their customers, protect their money and are a financial institution that maintains a traditional\nrelationship and way of working with its customers.\nDuring the complaints process with RIA, I found their communication ineffective, which further hides\ntheir conduct to management and diminishes the service offering to their clients. They are struggling to\nadapt their business offering in the ever-changing world of IT development. The internet is presenting a\nreal problem which they choose to manage in a way which is not in line with rules and regulations of\nCFPB as well as their own internal policy and procedures sold to their clients.\nGeneral Obligation:\nCommencing on XXXX XXXX, I fell victim to a multilayered scam operation orchestrated by XXXX XXXX (the Fraudsters or Company).\nMoney was transferred from my account in the total amount of XXXX XXXX.\nWhen determining whats reasonable and fair, we should focus on the issue of liability; common queries\ninclude, but are not limited to, the following (i)\nwhether RIA did not take notice of any rule, law, or regulation, and/or possibly missed any material\nelements of the relevant bylaws or codes of conduct, that may have prevented them from protecting my\nfinancial safety; (ii) whether by virtue of RIAs custodianship over my funds or by its control over them,\nthey owed a fiduciary duty to the me and if so, whether that duty was breached; (iii) whether RIA\npromoted the transaction(s) in question despite being aware of the nature of the transaction(s) in question\n(iv) whether RIA was in compliance with its own policies and procedures; (v) whether RIA owed duties\nto myself, what the scope of those duties was, and whether RIA did not uphold those duties; (vi) whether\nRIAs conduct was unfair; and (vii) whether RIA has within its power the ability to, and should,\ncompensate me for the harm that has befallen me.\nUpon identification of such unusual or suspicious activity, it is crucial that the relevant staff member\nadequately describe the factors making an activity or transaction suspicious, thoroughly depict the extent\nand nature of this activity and properly communicate to the customer that such activity meets the relevant\ncriteria of fraud.\nIn providing its services to a customer, a financial institution is required by law to exercise the care and\nskill of a diligent, prudent banker. In this case, this means that the payment service provider should not\nturn a blind eye to known facts pointing to a real possibility that their customer is being scammed. In\nother words, RIA must have had special knowledge of what was occurring or been alerted to a real\npossibility of fraud taking place. The financial institution must have known or reasonably ought to have\nknown that I was dealing with a scammer.\nGranted, there is room for diversity of view insofar as reasonableness is concerned. Indeed, there is a\nsense in which the standard of care of the reasonable person involves in its application a subjective\nelement.\nHowever, it must be remembered that the correct test is always reasonable care in all circumstances, not\naverage care. The fact that most people behave in a certain way may be good evidence that the conduct is\nreasonable, but this is not necessarily the case. Although reasonableness is a very fluid concept, all of\nthe evidence suggests that RIA did not foresee the fraud and disregarded even the most obvious dangers\nin this respect.\nSituations do tend to repeat themselves and it is advisable to examine previous outcomes to see how the\nstandard of the reasonable person should be applied, and that lessons can be learnt from the errors of the\npast.\nRIAs Position:\nPlease find attached all relevant evidence below.\nRIA conspicuously touts their security as a reason to use their service. Specifically, RIA writes on\ntheir website:\nWe work hard to protect you from fraud. That's why we:\n Apply best-in-class security technologies expertise to protect you 24/7, all year round.\n Secure every method of banking we offer including online, mobile, ATM and telephone\nbanking.\n Offer free security software from our trusted tech partners to download on to your devices.\n Frequently train our employees on the latest practices in cyber and physical security.\n Give you the security tips and resources you need to protect yourself from potential threats.\nRefuting RIAs arguments from a purely logical perspective:\nRIAs position is that the features of the situation at hand do not generate a genuine obligation to protect\ninnocent and helpless victims; they are essentially arguing that common-sense-based approaches are\ndoomed to fail, leaving their exclusively technical account of the subject matter as the only meaningful\nchoice. For reasons which are unclear, this extremely serious situation barely gets the attention it deserves\neven though ample evidence has been offered in support of this complaint.\nIn RIAs view, it is implied that we should not home in (and consequently rely) on unwritten laws,\npracticality, good judgement, reasonableness, sharpness, sensibleness, past outcomes, and insight, when\ntaking appropriate precautions. To underscore, once again, such views are at odds with common sense\nand are wildly irresponsible.\nImagine a view according to which the one and only thing that can make RIA morally obligated to do\nsomething is having it written down somewhere. Pursuant to this view, if RIA encounter the suffering of\ntotally naive victims, they are only obligated to intervene in or remedy the situation, to the degree\nrequired by written material. This is unbecoming for a reputable establishment such as RIA.\nI have reviewed the material hereto sent by RIA carefully, and it unfortunately provides no response to\nmy fundamental argument concerning the degree of care. Given its size, influence, and the resources at its\ndisposal, this establishment clearly had a far greater capacity than an individual such as myself had, to\ndetermine the level and likelihood of risk that a client such as myself is subjected to and had a duty to\nintervene as they now do to query in particular out-of-pattern transactions of this kind.\nIt is perfectly obvious that RIA, inadvertently, employs a subtle approach in addressing some of the key\nquestions in a manner which neither provides me with adequate support nor protects anything other than\nits own interests.\nIt is RIA here, who has the burden of proof, to show that it has exercised the duty of care, that is to say,\nthat RIA adhered to a standard of reasonable care in relation to the matter at issue given its extensive\nexperience compared to mine. It is RIA that claims that the damages which I have suffered in connection\nto this matter have not been reasonably foreseeable, and that my proposed degree of care is not, and has\nnot been, commensurate with RIAs capacity, experience, expertise, or scope of services in any way. To\nreemphasize, RIAs indisputable overriding purpose is by no means to purely execute transactions in a\nblind and blank fashion, but rather to strike a balance between executing those transactions and\ncapitalising on its undeniably vast capabilities to protect consumers thereby enhancing market integrity.\nApropos of the fluidity of the concept of reasonableness, all RIA has done in this regard is set up a\ndichotomy of having or not having the legal obligation under consideration, however, that does not go\none-inch toward explaining why various regulatory authorities, has maintained that financial institutions\ncan, and should, protect consumers using their systems, advanced technologies, and rich experience.\nRIA is obliged to take some action if it is sufficiently aware of a real possibility that a fraud may be being\nperpetuated. If you don't question its customers instructions or raise the possibility of a scam with the\ncustomer in these circumstances, it may be liable if the red flags indicate the customer is:\n particularly vulnerable, or\n if the possibility of fraud was serious or real, not just suspected.\nThere are some recommendations to organisations for protecting customers from financial harm that\nmight occur as a result of fraud or financial abuse; and gives guidance on how to recognise customers\nwho might be at risk, how to assess the potential risks to the individual and how to take the necessary\nactions to prevent or minimise financial harm.\nThese recommendations are established as a general principle, the organisation should deliver a\nservice that:\n1) Takes a proactive approach to minimising risks, impact and incidences of financial harm and it\nsets out systems and tools for the prevention and detection of fraud and financial abuse. As a general\npoint, it says organisations should ensure that all systems are developed using technologies and\nmethodologies that are effective in the prevention of fraud and financial abuse, through authorised\nand unauthorised payments, thereby minimising the risk of financial harm to customers. As regards to\nthe detection of fraud and financial abuse, it says the organisation:\nA) should have measures in place across all payment channels and products to detect suspicious\ntransactions or activities that might indicate fraud or financial abuse. It then lists the following\nexamples of suspicious activity on customer accounts:\na. multiple cheque books;\nb. sudden increased spending;\nc. transfers to other accounts;\nd. multiple password attempts;\ne. logins from new devices, multiple geographical locations;\nf. sudden changes to the operation of the account; Unusual transactions are\ntransactions whose amount, characteristics and frequency bear no relation to the\neconomic activity of the customer, exceed normal market parameters or have no\napparent legal justification.\ng. a withdrawal or payment for a large amount;\nh. a payment or series of payments to a new payee;\ni. financial activity that matches a known method of fraud or financial abuse.\nB) organisations should have a process in place to ensure that staff make contact with the\ncustomer to verify the financial activity, challenge its authenticity, explain the nature of the\nsuspected or detected fraud and discuss an appropriate plan of action.\nRIA are yet to show, or otherwise provide me with, a compelling argument that their wide-ranging\nexperience and wealth of specialist knowledge in detecting transactional anomalies were not sufficient to\navert the fraud at issue. By contrast, I have provided a multitude of sound and powerful reasons by which\nrequiring their involvement has not only been pressingly relevant but also eminently reasonable and welljustified.\nRather than empathising with and undertaking substantial efforts to convey their knowledge of the\nexistence of such regulations abroad and thereafter use it to protect and proactively relieve the plight of\nconsumers who have been cheated out of their money and whose role in society is properly fulfilled,\npositively contributing to local economic growth, development and sustainability  RIA adopts a rather\ninsouciant attitude toward my financial predicament portrayed herein.\nI am deeply convinced that the disastrous results that I have previously elaborated upon will continue to\nensue if no responsibility is adopted by RIA in relation to this matter. I have also thoroughly detailed why\nthey cannot simply dismiss this problem by strictly adhering to legal technicalities which, after careful\nreflection, struck me as being nothing more than self-interest. Indeed, it seems to me utterly unfair to\ndisregard fragile, sensitive, and vulnerable consumers who are afflicted by such allegedly malevolent acts,\nthereby keeping an unjust status-quo that is corrupting our society at its core.\nConclusion:\nBased on my analysis, and as confirmed by various authorities concerned with such matters, there is\nabundant evidence that forward-thinking financial institutions ought to take reasonable steps to forestall\nfraud, or at least mitigate its risk by using an effective risk management system, demonstrating their\nundisputed ability to responsibly and pre-emptively respond to questionable transactions in the digital\narena. The use of such systems, largely based on newly adopted technologies aimed at effectively\nnavigating the evolving threat landscape, is only one of a number of possible endeavours undertaken in\nthis connection, alongside the application of past knowledge and experience related to popular fraudulent\npractices.\nAstonishingly, I am pondering how it is that, despite being shown that RIAs business conduct was\ninsufficient insofar as background checks are concerned, they keep refuting their indisputable role and\nresponsibility in connection with the matter herein discussed. The points that I have hitherto made are too\ncrucial to be taken lightly. RIAs non-observance of the fundamental principles of justice  that is, to\ncompletely overlook and not even remotely try to mitigate the suffering of vulnerable consumers is\ninexcusable given the size of the establishment and the vast resources at its disposal as the direct result of\nthe patronage of clients like myself.\nIf it was, indeed, solely my responsibility, we must then believe at least one of the following clauses: a)\nfinancial institutions have absolutely no role whatsoever in preventing and detecting fraud, b) the fraud in\nquestion was not reasonably foreseeable, or c) the transactions in question were not sufficiently alarming.\nIt is extremely unfortunate that RIA pushes quite hard for me to believe all three of these thingsdespite\nevidence to the contrary.\nIn summary, I respectively ask your organisation to consider my points, given your personal and\ncompanywide obligation to provide a fair and reasonable investigation into the complaint.\nI look forward to your input and would gladly cooperate to reach a fair and reasonable outcome.\nThank you. XXXX XXXX XXXX\nXXXX  THE REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK\nXXXX XXXX XXXX\nTo: RIA\nXXXX XXXX, California , United States\nVia Email\n[Without Prejudice]\nAttn: Complaints/Fraud Dept.\nDear Sir or Madam,\nRe: Demand Letter  Fraud\nI hope this letter has correctly found itself within your complaints/fraud department as it is essential to me that\nyou become aware of the ordeal I have had to go through.\nCommencing on XXXX XXXX I fell victim to a multilayered scam operation orchestrated by XXXX XXXX (the Fraudsters or Company) with the design, development, manufacturing, promoting,\nmarketing, distributing, labeling, and/or sale of illegal and outright fraudulent investment services, all of\nwhich aim at contributing to the goal of robbing and defrauding clients through a predetermined cycle of the\nclient losses to gains.\nMoney was transferred from my account in the total amount of XXXX XXXX utilizing your services.\nOVERVIEW\n This letter shall thrust into the spotlight, inter alia, the increasingly important role those financial\ninstitutions play in the fight against financial crime and fraud, and the pressing need for enhanced\nsupervision and vigilance within your organization.\n Heres an indisputable fact: had you looked at the wider circumstances surrounding the abovereferenced\ntransaction(s), this illicit transfer of wealth could have been prevented.\n Obviously, there is no consensus with respect to the degree and scope to which regulated and licensed\nfinancial institutions must intervene and block suspicious transactions, and indeed, in so doing,\nfinancial institutions may often cause payments to be slowed down unnecessarily or even some\nlegitimate payments may be rejected, however, please be noted that additional frictions such as slower\npayments (such as delaying payments or freezing funds to investigate) is beneficial to and welcomed\nby vulnerable customers and is widely considered to be a positive practice that is necessary in order to\nmaintain their financial safety, particularly for large-value and/or out of pattern.\n Executing transactions without proper authority is not only a severe regulatory offense but also an\nirresponsible and reckless disregard of the customers financial safety.\n Against this background, and without derogating any of my rights, I hereby hold you liable for\nfinancial and emotional harm as well as medical problems relating to this victimization and insist that\nyou reimburse my account in full within 14 days from the date of this letter.\nINTRODUCTION\nFinancial crimes and fraud investigations often involve a high degree of sophistication, complexity, and\nsensitiveness to detail. Accordingly, this letter aims to address the issue at hand as profoundly and fairly as\npossible, by taking into consideration contextual regulations, laws, and bylaws, as well as guidance, standards\nand rules promoted by supervisory authorities, relevant codes of practice and (where suitable) what was good\nindustry practice (GIP) at all times relevant hereto. The allegations contained herein are predicated either\nupon knowledge with respect to myself and my own experience, or upon facts obtained through investigations\nconducted by qualified third parties. I strongly believe that substantive evidence in support of the allegations\nset forth herein will be found after an appropriate opportunity for discovery. Key facts supporting the\nallegations contained herein are known only to the Company and/or are exclusively within their control.\nThe Company cleverly orchestrated a prevalent scheme of deception to lead people to invest significant sums\nwhile knowing that those would-be investors would ultimately lose the money, they had entrusted to it. The\noverall purpose of the scheme, in other words, was to target and defraud people who are often inexperienced\nand naive, in pursuance of illicit wealth through various fraudulent representations.\nI did not know, and through the exercise of reasonable diligence could not have discovered, the fraud\nthat was being perpetrated upon me by the Company. Fraud is commonly conceptualized as withholding\nfrom the weaker party in a financial transaction (e.g., an investor) information which is necessary to make an\ninformed, rational or autonomous decision.\nIn this regard, even access to adequate information is insufficient to achieve complete autonomy. A\ncomplication here is that the weaker party, amateur/unseasoned investors in particular, might have trouble\nanalyzing the data at hand sufficiently well to identify fraudulent schemes. Unfortunately, because financial\nproducts are often abstract and complex, there is no easy solution to this problem. Therefore, full autonomy of\ninvestors might not only require access to sufficient information, but also access to relevant technologies,\nknow-how, processing capabilities, and resources to analyze the information. A reasonable solution is that\nfinancial institutions would be required to promote transparent communication in which they track the\nunderstanding of its customers.\nAccording to the Federal Trade Commissions interpretations of certain terms (like the words deceptive and\nunfair), the FTC has found that a deceptive act or practice encompasses a representation, omission or\npractice that is likely to mislead the consumer acting reasonably in the circumstances, to the consumers\ndetriment.\nThe federal courts have defined a deceptive trade practice [i] as any act or practice that has the tendency or\ncapacity to deceive consumers and have defined an unfair trade practice as any act or practice that offends\npublic policy and is immoral, unethical, oppressive, unscrupulous, or substantially injurious to consumers.\nThe false representations and omissions made by the Company have a tendency or capacity to deceive\nconsumers, such as myself, into unwittingly providing funds that fueled the Companys fraudulent scheme\nand are therefore, by their very nature, jointly immoral, unethical, oppressive, unscrupulous, and\nsubstantially injurious to consumers.\nAs a result of the Companys deceptive trade practices, I was deceived into transferring my funds for\ninvestment returns that were never delivered. I will certainly never receive any monetary value for the\ninvestments considering the way the Company had their scheme rigged, thus causing significant economic\ndamage to me. The false statements of material facts and omissions as described above; and the fraudulent\ntransaction(s) the Company perpetrated upon me; were unfair, unconscionable, and deceptive practices which\nwould have likely deceived any reasonable person under the circumstances.\nMERCHANTS FRAUD SCHEME  ALLEGATIONS\nThe Company hired, managed, and trained personnel, and collaborated with others as accomplices to\ntheir crimes to induce fraud that resulted in my financial and psychological damages. These include,\nbut are not limited to, the following allegations, all of which involve criminal, non-regulated, and\nmalicious activities:\n1. The Company directed and instructed others to work from shell companies that were operating\nfrom various unassociated locations across the globe.\n2. The Company opened bank accounts in multiple countries and used them through their\naccomplices and strawmen from around the world to conceal and disguise the identity of\nillegally obtained proceeds so that they appear to have originated from legitimate sources.\n3. The Company intentionally committed fraudulent misrepresentation, and falsified its agent names,\ncredentials, competencies, qualifications and location. The Companys name is merely a brand name,\nofficially owned by shell corporations located offshore. In reality, the entire operation is being\nconducted from elsewhere (supposed location is evidently fictitious), and on top of that the call center,\nmarketing, and decision making, are all being performed by completely anonymous and hidden\nentities. Concealing true identities and utilizing front companies as a vehicle for a wide spectrum\nof financial maneuvers is a notorious practice of criminal organizations.\n4. The Company has blatantly violated international laws, as it has been practicing without a\nlicense and funneling enormous sums of money, through countries and jurisdictions that require\nregistration to operate.\n5. The Company provided direct investment advice - not utilizing 3rd party recommendations (e.g.,\naccording to Bloomberg TV/Investing.com)\n6. The Company offered investment services/advice not related to real market/exchange data\n(manufacturing false charts etc.). The trading platform was purposely manipulated, in a way that\neach client would ineluctably and unknowingly lose money, as the trades were simply\nconcocted. Instead, the Companys staff and its accomplices simply pocketed the money, using\nit to purchase various luxurious, non-essential items.\n7. The Company prohibited my ability to withdraw my funds.\n8. The Company was guaranteeing returns/yields (unrealistic ones).\n9. The Company furnished me with bonuses - which are not allowed to be given.\n10. My money was not held in a segregated account.\n11. The Company did not advertise/disclose/was not transparent regarding the statistical data representing\nthe percentage of total client losses at the company.\n12. The Company did not mention the commission and overnight swaps.\n13. The Company did not read the risk disclosure prior to my deposit(s).\n14. The Company used high pressure tactics and outbursts, which took a severe toll on my health.\n15. Armed with my personal details, the Companys staff seduced me into transferring all of my\nsavings to them. They utilized their knowledge of my cultural context, which stressed square\nand honorable business dealings along with honesty, in order to maliciously take advantage of\nmy trusting nature.\nPlease take notice that my funds were transferred through means of coercion and under false pretenses.\nAttached, please find supportive statements, screenshots, and further evidence.\nEXPOSING YOUR ORGANIZATIONS MISCONDUCT\nI hereby allege that your organization has completely failed to adequately investigate the circumstances\nsurrounding the transaction(s) in question and willfully blinded itself to obvious red flags.\nMany suspicions should have arisen at your organization as an issue of great concern, with respect to the\nunusual activity taking place in my account. Despite the regulatory and statutory requirements your\norganization should abide by as a licensed and regulated financial institution  and instead of detecting\npatterns, drawing certain conclusions, and taking actions accordingly you at best, merely and insufficiently\nperformed some hasty and haphazard reviews of the transaction(s) or possibly asked only minimal generic\nquestions regarding the suspicious activities, and at worst, shut your eyes completely rather than being careful,\nmethodical, and vigilant. Had you bothered, you would probably have realized that the funds were associated\nwith fraud and financial crime, rather than some other legitimate revenue/activity.\nIn light of the above, and after conducting a comprehensive review of our communication/interactions,\nit has become glaringly obvious to me that no adequate information and/or documentation were sought\nby your organization, at best, and at worst no appropriate safeguards were implemented.\nIf a financial institution executes a customer order to transfer money knowing it to be dishonestly given,\nshutting its eyes to the obvious fact of the dishonesty, or acting recklessly in failing to make such inquiries as\nan honest and reasonable individual would undergo, it would be in breach of its duty of care, even if the\npayment was made in accordance with the terms of the mandate, and the financial institution should still be\nliable for negligence resulting in damages.\nCompliance departments should ensure that staff members understand the legal requirements and where there\nare suspicions, these suspicions be communicated to all relevant personnel whilst being investigated.\nFor the avoidance of doubt, reasonable grounds should not necessarily be interpreted as proof. On the basis of\nvarious signs, you should have assumed that something suspicious was going on therefore should have\nsuspended transaction(s) until reasonable enquiries could be made to verify that the transaction(s)\nwas/were properly executed. In other words, I am a victim of your negligence for facilitating the\nmisappropriation of funds, and doing little to safeguard public financial interests. Any reasonable staff\nmember would have realized that there were many obvious, even glaring, signs that I was being defrauded.\n(XXXX XXXX XXXX (in liquidation) v XXXX XXXX XXXX XXXX XXXX [XXXX] XXXX XXXX) [ii]\nYou knew or should have known that the funds being transferred through your services did not rightfully\nbelong to the recipient fraudsters. Similarly, you knew or should have known that the funds being transferred\nthrough your services serve no legitimate or lawful purpose. You turned a blind eye to the crimes that you\nhave facilitated and thus provided an array of essential money transfer services, acting as a vehicle, with the\nawareness that it was enabling the fraudsters to commit crimes and enrich themselves with the funds of their\nvictims.\nYour services undoubtedly served as a crucial element in the fraudulent scheme detailed herein, and you were\neither unaware of your complicity in the fraud, or, more worryingly, completely aware and silent. Had you\nconducted an adequate account analysis, you would have discovered the nature of the recipient, and\nsubsequently, disclosed and reported the fraudsters activities to law enforcement authorities/agencies and\nregulators. Instead, to satisfy your financial interests, you conveniently closed your eyes, even though you\nundeniably had, at all material times, the necessary controls and resources to influence, whether directly or\nindirectly, those particular transactions.\nYou also had the duty to stop those crimes, yet you refused to do so because you were more interested in\nenriching yourself, even if it meant furthering those crimes and allowing them to cause massive financial\nlosses to plenty of victims  many of whom are probably your customers. Therefore, it is clear that you did\nnot have in place adequate security measures to properly safeguard my assets  hence, you have\nirreparably harmed me and, if not enjoined, will continue to irreparably harm other victims as well as\ntheir loved\nones and associates. You have irreparably harmed me and, if not enjoined, will continue to irreparably\nharm the general public, and our society deserves better.\nA financial institution which wrongly pays money away when it has no authority to do so will usually be\ntreated as if it had paid using its own funds, not those of its customer.\nWhen discussing the responsibilities that a financial institution might incur, it is crucial not to forget the fact\nthat a legitimate complaint by, or cause of action on the part of, a client might generate/give rise to further\nstatutory cause of action and/or additional liabilities beholden by a financial institution to the relevant\nregulatory authority. Obligations/duties beholden by a financial institution to a regulator are distinct from\nthose beholden to the customer. Moreover, you may be held liable to more than one regulator.\nAs a regulated and licensed financial institution, you have strict statutory and regulatory obligations to\nmonitor transactions and report any suspicious activities to law enforcement authorities. The importance of\nimplementing robust internal systems to detect and report money laundering and other suspicious activities\nhas been continuously emphasized in the industry in addition to having the appropriate policies, procedures\nand internal controls in place to ensure ongoing compliance in respect to the aforementioned systems. You\nshould have analysed and distinguished thereafter between that which may be normal activity and that which\ncould suggest an illegal activity. This is a well-known standard industry practice which plays a substantial role\nin preventing criminals from liquidating and laundering funds.\nFRAUD\nActual fraud can be described, inter alia, as suppression of that which is true, by one having knowledge or\nbelief of the fact. Therefore, due to your actual knowledge that such scams are so prevalent, you are liable for\ndamages. Similarly, due to the fact that you knew or were grossly negligent in not kn","date_sent_to_company":"2024-11-30T09:15:06.000Z","issue":"Fraud or scam","sub_product":"International money transfer","zip_code":"XXXXX","tags":null,"has_narrative":true,"complaint_id":"10981005","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"Ria Envia, LLC","date_received":"2024-11-30T08:54:09.000Z","state":null,"company_public_response":null,"sub_issue":null},"highlight":{"complaint_what_happened":["The Company prohibited my ability to <em>withdraw</em> my <em>funds</em>.\n8. The Company was guaranteeing returns/yields (unrealistic ones).\n9. The Company furnished me with bonuses - which are not allowed to be given.\n10. My money was not held in a segregated <em>account</em>.\n11. The Company did not advertise/disclose/was not transparent regarding the statistical data representing\nthe percentage of total client losses at the company.\n12. The Company did not mention the commission and overnight swaps.\n13."]},"sort":[6.955957,"10981005"]}]},"aggregations":{"has_narrative":{"meta":{},"doc_count":26,"has_narrative":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":1,"key_as_string":"true","doc_count":26}]}},"product":{"doc_count":26,"product":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Checking or savings account","doc_count":9,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Checking account","doc_count":5},{"key":"Savings account","doc_count":4}]}},{"key":"Money transfer, virtual currency, or money service","doc_count":5,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Virtual currency","doc_count":3},{"key":"International money transfer","doc_count":1},{"key":"Mobile or digital wallet","doc_count":1}]}},{"key":"Credit reporting or other personal consumer reports","doc_count":3,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Credit reporting","doc_count":3}]}},{"key":"Debt or credit management","doc_count":3,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Debt settlement","doc_count":3}]}},{"key":"Bank account or service","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Checking account","doc_count":1}]}},{"key":"Credit card","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"General-purpose credit card or charge card","doc_count":1}]}},{"key":"Credit card or prepaid card","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"General-purpose prepaid card","doc_count":1}]}},{"key":"Debt collection","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Private student loan debt","doc_count":1}]}},{"key":"Payday loan, title loan, personal loan, or advance loan","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Installment loan","doc_count":1}]}},{"key":"Vehicle loan or lease","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Loan","doc_count":1}]}}]}},"issue":{"doc_count":26,"issue":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Managing an account","doc_count":6,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Banking errors","doc_count":2},{"key":"Funds not handled or disbursed as instructed","doc_count":2},{"key":"Deposits and withdrawals","doc_count":1},{"key":"Problem using a debit or ATM card","doc_count":1}]}},{"key":"Fraud or scam","doc_count":3,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}},{"key":"Problem with a company's investigation into an existing problem","doc_count":3,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Their investigation did not fix an error on your report","doc_count":3}]}},{"key":"Opening an account","doc_count":2,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Confusing or missing disclosures","doc_count":1},{"key":"Didn't receive terms that were advertised","doc_count":1}]}},{"key":"Account opening, closing, or management","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}},{"key":"Charged fees or interest you didn't expect","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}},{"key":"Closing an account","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Funds not received from closed account","doc_count":1}]}},{"key":"Confusing or misleading advertising or marketing","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}},{"key":"Didn't provide services promised","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}},{"key":"Getting a loan or lease","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Changes in terms mid-deal or after closing","doc_count":1}]}},{"key":"Other features, terms, or problems","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Other problem","doc_count":1}]}},{"key":"Other transaction problem","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}},{"key":"Unauthorized transactions or other transaction problem","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}},{"key":"Unauthorized withdrawals or charges","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}},{"key":"Unexpected or other fees","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}},{"key":"Written notification about debt","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Didn't receive notice of right to dispute","doc_count":1}]}}]}},"timely":{"doc_count":26,"timely":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Yes","doc_count":26}]}},"company_response":{"doc_count":26,"company_response":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Closed with explanation","doc_count":22},{"key":"Closed with monetary relief","doc_count":2},{"key":"Closed with non-monetary relief","doc_count":2}]}},"submitted_via":{"doc_count":26,"submitted_via":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Web","doc_count":26}]}},"company":{"doc_count":26,"company":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"JPMORGAN CHASE & CO.","doc_count":2},{"key":"NAVY FEDERAL CREDIT UNION","doc_count":2},{"key":"TD BANK US HOLDING COMPANY","doc_count":2},{"key":"Americor Funding, LLC","doc_count":1},{"key":"CAPITAL ONE FINANCIAL CORPORATION","doc_count":1},{"key":"CITIBANK, N.A.","doc_count":1},{"key":"Chime Financial Inc","doc_count":1},{"key":"Consumer Financial Services Solutions, Inc.","doc_count":1},{"key":"EQUIFAX, INC.","doc_count":1},{"key":"Experian Information Solutions Inc.","doc_count":1},{"key":"Foris DAX, Inc.","doc_count":1},{"key":"HUNTINGTON NATIONAL BANK, THE","doc_count":1},{"key":"NATIONAL DEBT RELIEF LLC","doc_count":1},{"key":"Paypal Holdings, Inc","doc_count":1},{"key":"REGIONS FINANCIAL CORPORATION","doc_count":1},{"key":"Ria Envia, LLC","doc_count":1},{"key":"SANTANDER HOLDINGS USA, INC.","doc_count":1},{"key":"SIMM Associates, Inc.","doc_count":1},{"key":"SOFI TECHNOLOGIES, INC.","doc_count":1},{"key":"TRANSUNION INTERMEDIATE HOLDINGS, INC.","doc_count":1},{"key":"TRUIST FINANCIAL CORPORATION","doc_count":1},{"key":"Westlake Services, LLC","doc_count":1},{"key":"Winklevoss Exchange LLC","doc_count":1}]}},"state":{"doc_count":26,"state":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"CA","doc_count":4},{"key":"FL","doc_count":3},{"key":"NJ","doc_count":3},{"key":"NY","doc_count":3},{"key":"TX","doc_count":3},{"key":"MO","doc_count":2},{"key":"AZ","doc_count":1},{"key":"MA","doc_count":1},{"key":"MD","doc_count":1},{"key":"NC","doc_count":1},{"key":"OH","doc_count":1},{"key":"SC","doc_count":1},{"key":"VA","doc_count":1}]}},"company_public_response":{"doc_count":26,"company_public_response":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","doc_count":5},{"key":"Company believes it acted appropriately as authorized by contract or law","doc_count":2},{"key":"Company chooses not to provide a public response","doc_count":1}]}},"tags":{"doc_count":26,"tags":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Servicemember","doc_count":8}]}}},"_meta":{"license":"CC0","last_updated":"2026-07-14T12:00:00-05:00","last_indexed":"2026-07-14T12:00:00-05:00","total_record_count":16441818,"is_data_stale":false,"has_data_issue":false,"break_points":{"2":[6.955957,"10981005"]}}}