{"took":236,"timed_out":false,"_shards":{"total":5,"successful":5,"skipped":0,"failed":0},"hits":{"total":{"value":2,"relation":"eq"},"max_score":null,"hits":[{"_index":"complaint-public-v1","_id":"19243722","_score":23.86105,"_source":{"product":"Credit card","complaint_what_happened":"CFPB COMPLAINT UNLAWFUL RETALIATION & WRONGFUL CREDIT ACCOUNT CLOSURES Company : Synchrony Bank Products Affected : PayPal XXXX XXXX Credit Card Issue : Account closed / credit line reduced Retaliation for exercising consumer rights Unfair and deceptive acts or practices Complaint Narrative I am filing this complaint to report unlawful retaliatory conduct by Synchrony Bank in violation of federal consumer-protection law. \nOn or about last week, I filed a consumer complaint disputing the denial of my XXXX XXXX XXXX. That complaint constitutes protected activity under federal law. \nWithin days of filing that complaint, Synchrony Bank abruptly closed XXXX separate, unrelated, and previously well-managed credit accounts : My PayPal XXXX XXXX XXXX credit card These closures occurred without any adverse change whatsoever in my credit profile, risk posture, or account conduct. Specifically : My payment history on both accounts was perfect No balances were delinquent No fraud, misuse, or policy violations were alleged No material change in income, credit score, utilization, or debt occurred No prior warnings or legitimate risk explanations were provided The only intervening event was my protected consumer complaint regarding the XXXX XXXX XXXX denial. \n\nThe timing, selective nature, and lack of justification for these closures demonstrate clear retaliation for exercising my consumer rights. \n\nLegal Violations Synchrony Banks actions constitute violations of, at minimum : Equal Credit Opportunity Act ( ECOA ), 15 U.S.C. 1691 ( a ) Retaliation against a consumer for exercising rights under federal credit laws is prohibited.\n\nFair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq.\n\nAdverse action taken without a valid or lawful basis, resulting in credit harm.\n\nUnfair, Deceptive, or Abusive Acts or Practices ( UDAAP ) Punitive account closures used to deter or punish consumer complaints undermine the integrity of the consumer-complaint process. \nThese actions also violate basic principles of good-faith account administration and consumer-protection policy. \n\nHarm to Consumer As a direct result of Synchrony Banks retaliatory conduct, I have suffered : Immediate and material credit harm due to loss of available credit Artificially increased utilization ratios Suppression of credit scores through no fault of my own Financial and reputational injury Emotional distress caused by arbitrary punitive action This harm is ongoing. \n\nResolution Sought I am requesting CFPB assistance to require Synchrony Bank to : Immediately reinstate my PayPal XXXX and XXXX accounts with original terms and limits ; Remove any adverse internal or external reporting associated with the closures ; Provide written confirmation that my consumer complaint was not used as a basis for adverse action ; Ensure no retaliatory flags or risk markers remain on my consumer profile. \n\nAdditional Information This complaint is submitted in good faith. If this matter is not resolved promptly, I am prepared to pursue further regulatory escalation and legal remedies.","date_sent_to_company":"2026-02-04T16:50:35.000Z","issue":"Trouble using your card","sub_product":"General-purpose credit card or charge card","zip_code":"908XX","tags":null,"has_narrative":true,"complaint_id":"19243722","timely":"Yes","company_response":"Closed with explanation","submitted_via":"Web","company":"SYNCHRONY FINANCIAL","date_received":"2026-02-04T16:47:33.000Z","state":"CA","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":"Can't use card to make purchases"},"highlight":{"complaint_what_happened":["Specifically : My payment history on both accounts was perfect No balances <em>were</em> delinquent No fraud, misuse, or policy violations <em>were</em> alleged No material change in income, credit score, utilization, or debt occurred No prior <em>warnings</em> or <em>legitimate</em> <em>risk</em> <em>explanations</em> <em>were</em> <em>provided</em> The <em>only</em> <em>intervening</em> event was my protected consumer complaint regarding the XXXX XXXX XXXX denial."]},"sort":[23.86105,"19243722"]},{"_index":"complaint-public-v1","_id":"9561046","_score":10.939165,"_source":{"product":"Money transfer, virtual currency, or money service","complaint_what_happened":"I wish to practice my right as a customer of Bank of America to use your organisation's service, seeking a\nformal, impartial investigation to amicably settle my dispute with Bank of America.\nIn order to clear up the myriad of letters and correspondences I have hitherto sent to Bank of America\nrespecting my complaint, I believe it will substantially strengthen both my case and your understanding, by\ntaking a deeper 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 fraudulent\ncriminals. 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 Bank of America to be commensurate with their legal role and responsibility to their customers. They\nsell a service to look after their customers, protect their money and are a financial institution that maintains\na traditional relationship and way of working with its customers.\nDuring the complaints process with Bank of America, I found their communication ineffective, which\nfurther hides their conduct to management and diminishes the service offering to their clients. They are\nstruggling to adapt their business offering in the ever-changing world of IT development. The internet is\npresenting a real problem which they choose to manage in a way which is not in line with rules and\nregulations of CFPB as well as their own internal policy and procedures sold to their clients.\nGeneral Obligation:\nCommencing on or abouXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX fell victim to a multi-layered scam\noperation run by XXXX XXXX XXXX XXXX which involved me making deposits for a total amount of XXXX XXXX from my Bank of America account to fraudulent investment firm.\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) whether Bank of America did not take notice of any rule,\nlaw, or regulation, and/or possibly missed any material elements of the relevant bylaws or codes of conduct,\nthat may have prevented them from protecting my financial safety; (ii) whether by virtue of Bank of\nAmericas custodianship over my funds or by its control over them, they owed a fiduciary duty to the me\nand if so, whether that duty was breached; (iii) whether Bank of America promoted the transaction(s) in\nquestion despite being aware of the nature of the transaction(s) in question (iv) whether Bank of America\nwas in compliance with its own policies and procedures; (v) whether Bank of America owed duties to\nmyself, what the scope of those duties was, and whether Bank of America did not uphold those duties; (vi)\nwhether Bank of Americas conduct was unfair; and (vii) whether Bank of America has within its power\nthe ability to, and should, compensate 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 turn\na blind eye to known facts pointing to a real possibility that their customer is being scammed. In other\nwords, Bank of America 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 sense\nin which the standard of care of the reasonable person involves in its application a subjective element.\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 the\nevidence suggests that Bank of America did not foresee the fraud and disregarded even the most obvious\ndangers in 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.\nBank of Americas Position:\nBank of America wrote in a letter The amounts totaling of XXXX  in question that you listed in your\ncomplaint is an accumulation of several transactions that were sent to the three previously mentioned\nmerchants that were confirmed valid and not made in error. Please note, the transactions posted correctly\nto your account as instructed in XXXX XXXX. While we are sensitive to the effect this matter has had on\nyou, we are unable to dispute any agreements that you may have had with the recipient of the funds.\nWe can only recommend that you contact the recipient directly for further assistance with your disputes.\nRefuting Bank of Americas arguments from a purely logical perspective:\nBank of Americas position is that the features of the situation at hand do not generate a genuine obligation\nto protect innocent and helpless victims; they are essentially arguing that common-sense-based approaches\nare doomed 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 Bank of Americas view, it is implied that we should not home in (and consequently rely) on unwritten\nlaws, practicality, good judgement, reasonableness, sharpness, sensibleness, past outcomes, and insight,\nwhen taking 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 Bank of America morally obligated\nto do something is having it written down somewhere. Pursuant to this view, if Bank of America encounter\nthe suffering of totally naive victims, they are only obligated to intervene in or remedy the situation, to the\ndegree required by written material. This is unbecoming for a reputable establishment such as Bank of\nAmerica.\nI have reviewed the material hereto sent by Bank of America carefully, and it unfortunately provides no\nresponse to my fundamental argument concerning the degree of care. Given its size, influence, and the\nresources at its disposal, this establishment clearly had a far greater capacity than an individual such as\nmyself had, to determine the level and likelihood of risk that a client such as myself is subjected to and had\na duty to intervene as they now do to query in particular out-of-pattern transactions of this kind.\nIt is perfectly obvious that Bank of America, inadvertently, employs a subtle approach in addressing some\nof the key questions in a manner which neither provides me with adequate support nor protects anything\nother than its own interests.\nIt is Bank of America here, who has the burden of proof, to show that it has exercised the duty of care, that\nis to say, that Bank of America adhered to a standard of reasonable care in relation to the matter at issue\ngiven its extensive experience compared to mine. It is Bank of America that claims that the damages which\nI have suffered in connection to this matter have not been reasonably foreseeable, and that my proposed\ndegree of care is not, and has not been, commensurate with XXXX XXXX  capacity, experience,\nexpertise, or scope of services in any way. To reemphasize, Bank of Americas indisputable overriding\npurpose is by no means to purely execute transactions in a blind and blank fashion, but rather to strike a\nbalance between executing those transactions and capitalising on its undeniably vast capabilities to protect\nconsumers thereby enhancing market integrity.\nApropos of the fluidity of the concept of reasonableness, all Bank of America has done in this regard is set\nup a dichotomy 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.\nBank of America is obliged to take some action if it is sufficiently aware of a real possibility that a fraud\nmay be being perpetuated. If you don't question its customers instructions or raise the possibility of a scam\nwith the customer 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 might\noccur as a result of fraud or financial abuse; and gives guidance on how to recognise customers who might\nbe at risk, how to assess the potential risks to the individual and how to take the necessary actions to prevent\nor 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 sets\nout systems and tools for the prevention and detection of fraud and financial abuse. As a general point,\nit says organisations should ensure that all systems are developed using technologies and methodologies\nthat are effective in the prevention of fraud and financial abuse, through authorised and unauthorised\npayments, thereby minimising the risk of financial harm to customers. As regards to the detection of\nfraud 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 transactions\nwhose amount, characteristics and frequency bear no relation to the economic activity\nof the customer, exceed normal market parameters or have no apparent legal\njustification.\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 customer\nto verify the financial activity, challenge its authenticity, explain the nature of the suspected or\ndetected fraud and discuss an appropriate plan of action.\nBank of America are yet to show, or otherwise provide me with, a compelling argument that their wideranging\nexperience and wealth of specialist knowledge in detecting transactional anomalies were not\nsufficient to avert the fraud at issue. By contrast, I have provided a multitude of sound and powerful reasons\nby which requiring their involvement has not only been pressingly relevant but also eminently reasonable\nand well-justified.\nRather than empathising with and undertaking substantial efforts to convey their knowledge of the existence\nof such regulations abroad and thereafter use it to protect and proactively relieve the plight of consumers\nwho have been cheated out of their money and whose role in society is properly fulfilled, positively\ncontributing to local economic growth, development and sustainability  Bank of America 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 Bank of America in relation to this matter. I have also thoroughly\ndetailed why they cannot simply dismiss this problem by strictly adhering to legal technicalities which,\nafter careful reflection, struck me as being nothing more than self-interest. Indeed, it seems to me utterly\nunfair to disregard fragile, sensitive, and vulnerable consumers who are afflicted by such allegedly\nmalevolent acts, thereby keeping an unjust status-quo that is corrupting our society at its core.\nI would also like to highlight the stark difference in how complaints are handled between Bank of America\nand XXXX XXXX Bank of America's handling of the situation was notably inadequate. They failed to properly\nacknowledge the issues I faced and did not provide the necessary support to recover my funds. In contrast,\nPNC Bank managed the situation with exemplary care. They not only acknowledged everything I had been\nthrough but also took proactive steps to assist me in recovering my funds. This level of customer service\nand attention to detail speaks volumes about XXXX XXXX commitment to their clients and their ability to\neffectively address and resolve issues.\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 endeavors undertaken in this\nconnection, 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 Bank of Americas business conduct\nwas insufficient 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. Bank of Americas non-observance of the fundamental principles of justice \nthat is, to completely overlook and not even remotely try to mitigate the suffering of vulnerable consumers\nis inexcusable given the size of the establishment and the vast resources at its disposal as the direct result\nof the 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 Bank of America pushes quite hard for me to believe all three of these\nthingsdespite evidence to the contrary.\nIn summary, I respectfully ask your organization 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.\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  Bank of America\nBank of America Corporate Center, XXXX XXXX XXXX XXXX\nWITHOUT PREJUDICE\nSubjectXXXX XXXX XXXX complaint to XXXX XXXX XXXX: Bank of Americas complaints dept.\nDear Sir / Madam,\nI have now reviewed your response dated XXXX XXXX XXXX  Based on my review, I do not believe you have acted fairly, let alone reasonably.\nThe investigatory processes appear to disfavour the victim, and there is a lack of knowledge of good industry practice as well as a lack of\ncare/compassion towards me as the customer.\nYour response is, to say the least, extremely inadequate. It is based on a blatantly incorrect understanding of what I have maintained.\nWhat amazes me is just how difficult it has been to find soundness in it. Your analysis, for instance, does not engage with the actual\nhistory of my account and a significant portion of related data that may contradict your position has been conveniently ignored.\nSeemingly, in arriving at a decision in relation to the issue I raised, no consideration was given to a) Duty of care in relation to the fact\nthat I am the victim of a financial crime and b) The responsibility that your institution hold to protect its clients from such crimes.\nI find your rejection incredibly offensive and perplexing. In all honesty, if you could provide me with any kind of a logical coherent\naccount that could reconcile the evident fact of the multiple warning signals as well as my susceptibility relating to this matter with the\nexistence of a sound anti-fraud program, then I would absolutely appreciate your point of view.\nGiven the variety of similar cases involving various types of scams, you should be acutely aware of this problem for society, but your\nsuperficial (and perhaps convenient) answer to it, simply put, is that blameless victims must be held accountable for their misfortune.\nBecause your argument presumably aims at self-protection rather than the truth, we can have no confidence that your rejection is\nultimately just, fair, or reasonable. It is time to adopt a more realistic, long-term attitude towards unavoidable scenarios of this kind,\nstarting from the justifiable assumption that such injured parties did not in the least contribute to (and thus certainly should not bear\nresponsibility for) their own victimisation.\nMisplaced Accountability:\nScam victims have relatively little freedom of reactivity; under such circumstances, they respond immediately, instinctively, and\ninvariably to the specific demands of the perpetrator. Being able to consciously refrain from reacting in such a way is extremely difficult\nand sometimes impossible. Unwittingly giving off signals that mark us as easy targets, is by no means the same as being grossly\nnegligent, in view of the increasingly sophisticated scams, which continue to be a pervasive problem in society.\nDue to personal circumstances, I was particularly vulnerable during the victimisation period; I was also relatively financially illiterate\nand very inexperienced in the finance sector which made me a prime target for criminal enterprises in this field.\nSince this time, having lost all of my savings to these fraudulent companies, I have learnt an enormous amount about the scope of these\ncriminal endeavours and also about how the financial services sector operates internationally.\nFinancial institutions are well aware of the scope and nature of such crimes and the risks that these pose to their clients, who, in contrast,\nmostly have limited knowledge of these dangers.\nTo be clear, people who have been scammed such as myself, are not individuals who have made poor investment decisions. They are\npeople who have been tricked, lied to, deceived and emotionally manipulated. Sophisticated, aggressive sales techniques end up trapping\nthe uninformed and unsuspecting victim who once in the clutches of the scammer cannot get out until most or all of the funds have been\nlost (stolen) by the scammers. A good comparison is a perpetrator who grooms his victim whilst at the same time assaults him/her and\nprevents them from escaping.\nThis complex issue has caused substantial harm to me, and if not appropriately addressed, will cause substantial harm to others, we must\ntherefore conduct an in-depth and comprehensive review of all of the contributing factors that have led to an outcome as horrendous as\nthe one described herein.\nThe grounds upon which you refute my claim:\nScrutiny shows that your claims are defective as an endeavour to thoroughly investigate the accessible facts; let alone as an attempt to\nportray an accurate image respecting the role of banks in fighting financial crime and fraud, your organisations scope of services, and\nvarious other details in connection with the duties that emerge out of our relationship, particularly in the context of the broader historical\ncircumstances. The emphasis that you have placed on the incredibly insufficient diligence checks as well as the inconsequential\nreferences and the unidimensional thinking, not only gives a skewed picture of my fundamental rights as your customer, but also\npresents a poor blueprint for understanding the issue discussed in a well-reasoned and objective manner, and an even poorer guide to\ndictate whether there has been, as suggested, wrongdoing on your part.\nThe amounts totaling of XXXX in question that you listed in your complaint is an accumulation of several transactions that\nwere sent to the three previously mentioned merchants that were confirmed valid and not made in error. Please note, the\ntransactions posted correctly to your account as instructed in XXXX XXXX. While we are sensitive to the effect this matter has had on\nyou, we are unable to dispute any agreements that you may have had with the recipient of the funds. We can only recommend that you\ncontact the recipient directly for further assistance with your disputes.\nConcerning the \"authorisation\" argument, it can be cast as an incompatibility between statements such as \"the transaction has been\nauthorised\" and \"the duty of care has been breached\". However, you have not shown that both statements are logically incompatible or\nimprobable with respect to each other. They are not mutually exclusive in the broader context.\nThe view that I have authorised the transaction and therefore fully liable is dangerously reductive--various aspects relating to the breach\nof the duty of care have been marginalised. Clearly there are more facts to be taken into account than at first appears.\nI notice that your account of the subject matter depends crucially on the supposed lack of obligation which is perhaps the most obscure\npoint in your argument. But regardless, your views give us reason to contemplate as well whether your societal role (which arguably\nrenders you capable of preventing plausibly foreseeable damages such as the one set forth herein) should trigger the appropriate moral\nobligations rather than unscrupulous beliefs which are inherently unjust, flagrantly unfair and merely conducive to your own self-interest\nand welfare. Likewise, you unknowingly oppose the emergent notion that I was no luckier in blindly placing faith in your\nestablishments competence than I would have been in not doing so.\nYou have blithely ruled out your obligation herein by undermining reasoning strategies aimed at justice and fairness; remarkably, you\nhave deliberately avoided the uncomfortable yet inevitable conclusion that in this instance you are to be held accountable, by narrowly\nholding that a financial institution's role in society is merely to \"act upon the customer's instruction.\" This sort of reductionist view has\nlong since been exposed as inadequate among world-leading, key financial regulatory authorities.\nIt is intuitively clear that you have not reckoned with the remarkable range of indispensable functions, which your organisation should\nperform for the community in a manner that is both stable and sustainable. It is moreover blatantly apparent, that, instead of being\nattuned more than ever to the importance of apprehending the pernicious influences of your idleness and non-intervention amidst an\ninexorable rise of financial fraud, you are unwarrantably hiding behind specious arguments based on thin assumptions, inadequate\nresearch, poor evidence, and sloppy reasoning. It is a whole lot better and far more effective to do the right thing, rather than the most\nprofitable one thereby compromising the integrity of your enterprise. I suggest that by following adequate protocols aimed at mutual\nbenefits (rather than satisfaction of personal goals), disadvantaged consumers will thrive rather than suffer, with a plethora of positive\nfeedback propagating far and wide as a result.\nI demand an investigation to bring to light additional relevant evidence that I am persuaded will support my view. It is hereby proposed\nthat your motivations may adversely affect reasoning through overreliance on a biased set of processes. As a substitute for sub-optimally\nrelying on a set of gross oversimplifications (which frustratingly and inexorably lead us to draw erroneous conclusions), we should,\ninstead, systematically account for the totality of the evidence  howsoever unpalatable  by even-handedly relying on complex and\nmultifactorial reasoning. The demand for sound reasoning is essentially a demand for ultimate explanation, and is linked with a complete\nunderstanding of the pronounced role that you played in permitting my injuries herein\nIn light of the above, it is patently clear that your train of thought is fatally flawed and totally unsupported. You have failed to come up\nwith positive evidence to support your claims, that is, to show beyond any reasonable doubt that irrespective of your conduct, my\nvictimization was an inevitable outcome. On the other hand, I have provided substantial evidence to support the claim that you could\nhave done more to safeguard my funds. Not only have you let me down, but you have also failed to admit that you could and should\nhave done better.\nWhat can Bank of America do?\nPlease be noted that I will not in any way quietly tolerate the consequences of your actions (or more precisely, the lack thereof). Your\nresponse has limited the discussion narrowly to highly technical terms, and insufficient attention has been given to your organizational\ndysfunctions from a common-sense point of view. It is perfectly obvious that you could have, and should have, utilized various riskbased\nexamination procedures and techniques, all of which are within your purview and could have entirely prevented this disastrous\noutcome. It is wildly incorrect to assume that you have exercised your duties by doing the minimum necessary. You have not exercised\nyour duties at all, rather, many of your underlying assumptions have simply gone unquestioned. Instead of being receptive to\nconstructive criticism and improving yourself, you ultimately seek to blame your customers thus absolving yourself of any\nresponsibility.\nAs previously advised, you should have known, suspected, or had reason to suspect that the transactions (or pattern of transactions):\n involve funds the ultimate purpose of which was to fuel an illegal enterprise;\n is intended to disguise funds the ultimate purpose of which was to fuel an illegal enterprise, in an attempt to avoid and thus\nviolate regulations;\n is intentionally designed to defraud your customer;\n serves no legitimate or lawful purpose; and\n involve the use of your services to facilitate criminal activity\nThere are so many other ways in which measures related to fraud prevention and mitigation could have been useful. To the extent to\nwhich you were inconsistent therewith, you are liable for damages. Further factors that should have been taken into consideration\ninclude, but are not limited to, the following:\n The timing, volume, frequency, and nature of the transactions in question;\n The abnormality of such transactions against the background of your experience with me as a customer and other entities\nassociated with the transactions (if any);\n The suspicious nature of such transactions based on my overall risk profile including vulnerability, identification and research\nof high-risk services/products;\n Systemic filtering mechanisms, whether manual or automatic, for the identification of unusual activities; and\n Periodic evaluation of the usefulness, appropriateness and effectiveness of anti-fraud programs, and other associated policies\nand procedures.\nIt is incumbent upon financial institutions to carefully assess all information available about their customers, including vulnerability,\nneeds and customer type. There is a wide range of transactions which, although legitimate, should raise a red flag simply because they\nare inconsistent with the customers typical and ordinary activity. What constitutes reasonable grounds to flag transactions varies\naccording to the facts and circumstances of the particular matter being investigated and the effectiveness of the anti-fraud processes.\nRelevant industry practices at the time of the victimisation:\nYour Organisation is obliged to take some action if it is sufficiently aware of a real possibility that a fraud may be being perpetuated. If\nyou don't question its customers instructions or raise the possibility of a scam with the customer in these circumstances, it may be liable\nif 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 might occur as a result of fraud or\nfinancial abuse; and gives guidance on how to recognise customers who might be at risk, how to assess the potential risks to the\nindividual and how to take the necessary actions to prevent or minimise financial harm, these recommendations are established as a\ngeneral principle, the organisation should deliver a service that:\n1) Takes a proactive approach to minimising risks, impact and incidences of financial harm and it sets out systems and tools for\nthe prevention and detection of fraud and financial abuse. As a general point, it says organisations should ensure that all systems\nare developed using technologies and methodologies that are effective in the prevention of fraud and financial abuse, through\nauthorised and unauthorised payments, thereby minimising the risk of financial harm to customers. As regards to the detection of\nfraud and financial abuse, it says the organisation:\nA) should have measures in place across all payment channels and products to detect suspicious transactions or activities that\nmight indicate fraud or financial abuse. It then lists the following examples 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 transactions whose amount,\ncharacteristics and frequency bear no relation to the economic activity of the customer, exceed normal\nmarket parameters or have no apparent 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 customer to verify the financial\nactivity, challenge its authenticity, explain the nature of the suspected or detected","date_sent_to_company":"2024-07-19T23:38:35.000Z","issue":"Fraud or scam","sub_product":"Virtual currency","zip_code":"08807","tags":null,"has_narrative":true,"complaint_id":"9561046","timely":"Yes","company_response":"Closed with non-monetary relief","submitted_via":"Web","company":"BANK OF AMERICA, NATIONAL ASSOCIATION","date_received":"2024-07-19T23:25:30.000Z","state":"NJ","company_public_response":"Company has responded to the consumer and the CFPB and chooses not to provide a public response","sub_issue":null},"highlight":{"complaint_what_happened":["Bank of America are yet to show, or otherwise provide me with, a compelling argument that their wideranging\nexperience and wealth of specialist knowledge in detecting transactional anomalies <em>were</em> not\nsufficient to avert the fraud at issue. By contrast, I have <em>provided</em> a multitude of sound and powerful reasons\nby which requiring their involvement has not <em>only</em> been pressingly relevant but also eminently reasonable\nand well-justified."]},"sort":[10.939165,"9561046"]}]},"aggregations":{"has_narrative":{"meta":{},"doc_count":2,"has_narrative":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":1,"key_as_string":"true","doc_count":2}]}},"product":{"doc_count":2,"product":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"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":"Money transfer, virtual currency, or money service","doc_count":1,"sub_product.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Virtual currency","doc_count":1}]}}]}},"issue":{"doc_count":2,"issue":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Fraud or scam","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}},{"key":"Trouble using your card","doc_count":1,"sub_issue.raw":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Can't use card to make purchases","doc_count":1}]}}]}},"timely":{"doc_count":2,"timely":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Yes","doc_count":2}]}},"company_response":{"doc_count":2,"company_response":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Closed with explanation","doc_count":1},{"key":"Closed with non-monetary relief","doc_count":1}]}},"submitted_via":{"doc_count":2,"submitted_via":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"Web","doc_count":2}]}},"company":{"doc_count":2,"company":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"BANK OF AMERICA, NATIONAL ASSOCIATION","doc_count":1},{"key":"SYNCHRONY FINANCIAL","doc_count":1}]}},"state":{"doc_count":2,"state":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[{"key":"CA","doc_count":1},{"key":"NJ","doc_count":1}]}},"company_public_response":{"doc_count":2,"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":2}]}},"tags":{"doc_count":2,"tags":{"doc_count_error_upper_bound":0,"sum_other_doc_count":0,"buckets":[]}}},"_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":{}}}