Product: Debt collection

AAFES is the undisputed original creditor of my Military Star account. They operate and own the card program directly. However, I received a letter from AAFES Collections after they had already begun garnishing my federal retirement pay without ever providing the legally required warnings, options, or due process protections. And did so at a time I was medically legally determined by the federal government mentally incompetent. 

I did recieve a letter after several involuntary garnishments. 

The letter was labeled as coming from " Collections '' on official AAFES letterhead. Yet it contained none of the disclosures required by law for debt collection notices. There was no FDCPA warning such as This is an attempt to collect a debt, no 30-day dispute window, and no explanation of how I could exercise my legal rights.

The Debtor Rights they included were, in fact, not legally valid protections. Each one falls short of the protections guaranteed by federal law : 1. Right to Request a Hearing But Only After referral has occurred, and in my case I never was notified of these rights, and Involuntary Garrnishment Has Begun. See attached ERAS Under 31 U.S.C. 3716 ( a ) and 31 C.F.R. 285.11, I am legally entitled to a pre-offset hearing, not a post-garnishment appeal.

AAFES withheld this right and began garnishing my federal retirement funds before informing me of my hearing right. 

This violates my procedural due process under federal law I was punished before being allowed to defend myself. 

2. Right to Validate the Debt But Only If They Deem It Valid. 

The letter says I can request validation, but that AAFES will review and determine if it is valid. 

Under FDCPA 809 ( b ) ( if acting as a collector ), or standard debt dispute procedures ( if acting as a creditor using federal offset ), they must suspend collection and provide documentation not just review internally. I am allowed to request several documents by law for review of validity such as original contract, statements, etc. However, AAFES offers my " right '' which is to request no documentation and they will be the determinor of validity themselves.

This is a closed-loop system : I am not told what to submit, not allowed to see their records, and they get to decide the outcome with no appeal. 
-- - 3. Right to Inspect Records But Only What They Deem Relevant. 

I was told I could inspect only what AAFES determines is relevant to the debt. 

This violates basic discovery standards. You can not prepare a legal defense when the opposing party decides what evidence you're allowed to see. 

It renders due process meaningless they become the collector, judge, and gatekeeper of the evidence. 

4. Right to Request Debt Cancellation or Refund With No Clear Standard AAFES claims I can ask for debt cancellation or a refund for overcollection, if appropriate. Again, AAFES determines what's appropriate evidence they will allow me to have, to give back, for them to review, to determine appropriatness. I am simply a forwarding address for their process. With no rights to request what I Deem necessary to build a case, nor a legal authority determining if due process or the accounting is inaccurate. I Can not even hire my own CPA to review my files as I can't get what they think isn't necessary. And even then, as the creditor they decide ( with unknown qualifications ) - unregulated if they think it's appropriate. 

No criteria are given, no legal references cited, and no procedural steps outlined. 

This falsely presents a form of relief that is entirely discretionary, not enforceable. 
-- - Summary : AAFES is the creditor but labels its communications Collections, which are legally structured and presented like debt collector notices without any of the required FDCPA disclosures. 

They began garnishing my retirement before informing me of any hearing rights or providing a chance to inspect or dispute the debt. 

Their supposed Debtor Rights are not rights at all they are internal procedures that fall well short of federal legal requirements. 

I was fined, penalized, and garnished before any trial, hearing, or formal opportunity to challenge the debt, and AAFES controls the evidence I can use to defend myself. 


This is not just deceptive its functionally a denial of fair process and consumer rights under federal law.