Product: Payday loan, title loan, personal loan, or advance loan

I am filing this complaint to warn this agency of the financial impact of this product that Ingo Money ( https : //ingomoney.com/ ). This check cashing application attempts to clear checks immediately upon submission of the check to the application. Some weeks, I used this service. Ingo Money uses XXXX XXXX XXXX XXXXXXXX. and XXXX XXXX XXXX to provide the banking services for the physical movement of its transactions. This complaint also focuses on these two banks as they are " covered persons '' under rules of the CFPB. The first time I used the application I was successful. But, I attempted to use the application a second time. This was between the weeks of XX/XX/XXXX - XX/XX/XXXX. Now, It was my understanding that the application would have verified the fund with the bank. I later found out that this is not the case. 

I submitted a picture of the check because my mother was having issues with submitting the check online with her phone that uses an XXXX based operating system. So on the date of XX/XX/XXXX, IngoMoney application was not servicing any clients with XXXX based phones, which alienated and every user with an XXXX based phone. This in itself presents a clear violation of the laws. The consumer protection laws ( CFPB ) make no distinction between banks and their agents. Based on this inability to service these customers, this application may have violated several laws relating to equity and fairness to US consumer protection laws in any state that the company has a NMLS license for. 

The second possible violation is simply that, this service guises itself as a check cashing app, when it in fact is predatory in nature. This application charges very high fees for it's services. As an example, I cashed a check for {$1500.00} and was charged a {$75.00} processing fee ( 4.98 % ). As explained earlier, Ingo does not verify the funds of the check. The application uses algorithms to " predict '' or " merely guessing '' the future collection of fund on the check. Consider the reasons below : Limitations of the Current Approach : Overreliance on Predictions : Models trained on historical data may fail to capture edge cases or new fraud techniques.

Predicting whether a check is valid without verifying funds introduces significant financial risk.

No Immediate Fund Verification : The absence of real-time bank verification to confirm account balances or check authenticity is a glaring gap. 
Predicted " good '' checks might bounce later, leading to financial losses and trust issues. 

False Positives and Negatives : False Positives : Fraudulent checks may be cashed because they appear " real '' based on past data patterns.

False Negatives : Legitimate checks might be flagged and rejected, leading to poor user experiences.

Limited Due Diligence : AI predictions don't replace actual financial checks like clearing processes or account verification. 
Reliance solely on predictions can result in lawsuits, regulatory scrutiny, or reputational damage.

Now, a standard brick and mortar check cashing establishment operates during normal banking hours and has the necessary tools and mechanisms ( LAN line, mobile phone, fax, email, etc ) to immediately verify the funds on the check. By definition the brick and mortar check cashing establishment is a " true '' check cashing apparatus and not Ingo Money. If IngoMoney can not verify the funds on the check which is the " core '' feature of this service as it states in it's recorded message at ( XXXX ), It is " falsely '' marketing itself as a check cashing service. This service is more aligned with pay-day lending over check cashing. The verification of funds " must '' be completed, whether it be by human or a computing system. 

At present, IngoMoney does not do business in New York State. This could be due to the aggressive and misleading nature of this service. The company states that it is merely check verifier which is not the case. And if that is the case, then those fees should be absorb by it's banking partners mentioned earlier in this complaint and not directly by the customer. IngoMoney is offered across several alternative banking verticals ( XXXX, XXXX, XXXX and others ). It also offers it as a stand alone service, meaning that you do not have to use a partner and you can utilize the service by itself. But again, IngoMoney, is misrepresenting itself as a check verifier and check casher because the application is designed to make a " guess '' or " prediction '' based on the algorithms ability to determine whether the funds will clear on any check presented to the application.

There is a grave systemic risk posed by this application to consumers, banking partners and its alternative banking partners. XXXX has XXXX XXXX users. XXXX has XXXX XXXX users which would include XXXX, because XXXX is the parent company of XXXX. IngoMoney needs to cease its offering of this check cashing product, until it can clearly demonstrate to this agency that it is " truly '' verifying every check with the originating issuer of the check and explain what it's exposure to risk it is currently experiencing, has experience and risk it XXXX experience in the future. 

This application has a " wide blast radius '' based on the clients and partners that it contracts with. IngoMoney has to prove to this agency that it can contain any risk presented as a result of it's potential systemic risk to consumer, its banking partners and its alternative banking partners. Similar to the stress testing imposed by regulators during the global financial crisis in XXXX. 

Lastly, there is also potential that Ingo is providing an unfair market advantage ( monopoly ) that would allow other entrants to enter this market. My belief is that Ingo doesn't have alot of competition due in part to it's high risk and speculative business model. 

The information covered in this complaint is based on my personal experience with IngoMoney, and my experience with machine learning models being an architect of these systems.