Product: Vehicle loan or lease

Starting XX/XX/XXXX- XX/XX/XXXX. 

Subject : Formal Complaint Against Ally Financial and XXXX XXXX XXXX for Violations of Contractual Obligations, UCC, Consumer Protection Laws, and Negligence Dear Consumer Financial Protection Bureau, I am filing a formal complaint against Ally Financial and XXXX XXXX XXXX ( XXXX XXXX XXXX, New Jersey ) for their failure to fulfill contractual obligations, mishandling of my vehicle registration, negligence, and violations of federal and state laws. Their actions have caused significant financial, legal, and personal hardship. 


Key Violations and Legal Basis : 1. Failure to Comply with the Uniform Commercial Code ( UCC ) : Breach of Contract ( UCC 2-301 ) : Both Ally Financial and XXXX XXXX XXXX have failed to provide vehicle tags as stipulated in my finance agreement, thereby breaching the terms under UCC 2-301 . 

Failure to Perfect Security Interest ( UCC Article 9 ) : Ally Financial has failed to properly manage and address the revocation of their security interest and lienholder rights, constituting a violation of UCC Article 9. 

Unconscionable Practices ( UCC 2-302 ) : Ally Financial and XXXX XXXX XXXXXXXX have engaged in unconscionable practices by creating confusion regarding the creditor relationship, delaying vehicle registration, and failing to meet their contractual obligations. 



2. Violations of the Federal Truth in Lending Act ( TILA ) and Regulation Z : The Truth in Lending Act ( XXXX5 U.S.C. 1601 ) mandates clear and transparent disclosure of terms. The contract lists XXXX XXXX XXXX as the creditor, yet Ally Financial is attempting to collect the debt, creating a lack of transparency and violating TILAs provisions. 


3. Violations of the Magnuson-Moss Warranty Act ( 15 U.S.C. 2301 ) : XXXX XXXX XXXX failure to deliver a properly registered, roadworthy vehicle constitutes a breach of the implied warranty of merchantability under the Magnuson-Moss Warranty Act. 


4. Violations of the Federal Debt Collection Practices Act ( FDCPA ) ( 15 U.S.C. 1692 ) : Ally Financials attempts to collect the debt, despite not being the original creditor, may constitute improper debt collection practices under the FDCPA. 


5. Unfair and Deceptive Acts and Practices ( UDAP ) : Both Ally Financial and XXXX XXXX XXXX have violated state Unfair and Deceptive Acts and Practices ( UDAP ) laws by engaging in deceptive and unfair practices, including delaying registration, mismanaging paperwork, and failing to clarify their roles in the financing and collection process. 


6. Negligence and Financial Harm : Ally Financial and XXXX XXXX XXXX failed to exercise reasonable care in handling my vehicle registration and financial accounts, resulting in the impoundment of my vehicle, loss of employment, fines, and significant financial and emotional harm. 



Detailed Complaint : 1. Failure to Provide Vehicle Tags : My finance agreement explicitly states that taxes, tags, and registration would be covered. Over seven months later, I still do not have my vehicle tags. Despite repeated calls, correspondence, and proof of payment, Ally Financial and XXXX XXXX XXXX have failed to resolve this issue. 


2. Negligence by the Dealership : XXXX XXXX XXXX failed to submit the necessary paperwork for my vehicle registration in a timely manner, violating their obligation to ensure compliance with state registration laws. After receiving payment for the vehicle, they refused to assist further, citing that their hands were tied. 


3. Discrepancy in Creditor Relationship : The contract lists XXXX XXXX XXXX as the creditor, yet Ally Financial has been contacting me to collect the debt. This raises concerns about transparency and possible violations under TILA and state UDAP laws. 


4. Tendered Payment in Full : I provided full payment to satisfy my obligations under the contract and revoked Ally Financials security interest, power of attorney, and reporting rights. Despite submitting proof of delivery and proper documentation, Ally Financial has failed to act or acknowledge my revocation. 


5. Vehicle Impoundment Due to Negligence : Their failure to issue my tags led to my vehicle being impounded for being unregistered, resulting in towing fees, fines, and further financial losses. 


6. Request for Refund of All Paid Funds : Given that the vehicle has been paid in full, I am requesting the return of all funds I have paid. The payment of the vehicle should have settled all obligations, and the failure to deliver the tags and registration, alongside the mishandling of the paperwork, warrants a refund. 
*Impact on My Life : Employment Loss : The inability to legally operate my vehicle resulted in the loss of my job. 

Financial Strain : I have incurred significant costs, including impoundment fees, tickets, and lost income. 

Emotional and Mental Distress : This ongoing situation has taken a severe toll on my mental health and marriage. 

Legal Costs : I have been forced to seek legal counsel to address these issues.