Product: Credit card

TO WHOM IT MAY CONCERN, I am submitting this informal complaint to the Consumer Financial Protection Bureau ( CFPB ) regarding Comenity Capital Banks ( Hereafter, Comenity ) improper handling of consumer credit data, failure to ensure accurate identity verification, and potential systemic deficiencies in the transmission and use of financial data. This complaint will be forwarded to Comenity for response as part of the CFPBs informal complaint process. However, if Comenity fails to resolve the issue appropriately, I will escalate to reporting the matter to the FTC and Comenity Banks state and federal regulatory authorities as well as pursue legal action.

SUMMARY OF THE ISSUE.

Comenity wrongfully denied my credit application based on an incorrect XXXXXXXX XXXX XXXX of XXXX score that does not belong to me. I applied for a XXXX XXXX Credit Card and received an adverse determination letter, dated XX/XX/year> ( Application # XXXX ), and upon investigation, XXXX confirmed with me directly that my actual risk score is XXXX, not XXXX. Further, XXXX confirmed that Comenity never accessed my credit file before issuing its adverse action letter. 
This raises serious concerns that : Comenity misused or misattributed consumer credit data in its decision-making process. 
XXXXomenity failed to verify my identity properly, potentially leading to fraudulent or inaccurate credit denials.

Comenity may have systemic deficiencies in its data transmission and verification processes, which could be affecting a broader range of consumers.

LEGAL BASIS FOR COMPLAINT.

Comenitys actions may constitute violations of the Fair Credit Reporting Act ( FCRA ), including : 15 U.S.C. 1681s-2 ( a ) ( 1 ) ( B ) : Duty of furnishers ( Comenity ) to report accurate consumer information.

15 U.S.C. 1681 ( b ) : Credit reports may only be used for permissible purposes.

15 U.S.C. 1681 ( i ) : Consumers have the right to dispute inaccurate information and receive a timely resolution.

KEY FACTS SUPPORTING MY COMPLAINT. 
Incorrect XXXX XXXX Used in My Credit Denial. 
My adverse action letter from Comenity, dated XX/XX/year>, states that my XXXXXXXX XXXX XXXX was XXXX. 
XXXX has confirmed that my actual score is XXXX, which means Comenity either used incorrect information or failed to verify my identity properly. 
XXXX Confirms Comenity Never Pulled My Report. 
After receiving the denial letter, I contacted XXXX directly, and they confirmed that Comenity never accessed my credit file. 
This suggests that Comenity used unverified or inaccurate third-party data when evaluating my application.

Failure of Comenity Representatives to Address or Remedy the Issue. 
On XX/XX/year>, I spoke with multiple Comenity representatives, including XXXX from Account XXXX, who refused to investigate the issue despite clear evidence of an error. He falsely denied knowledge of my risk scoreeven after I read it to him from Comenitys own adverse action letterand dismissed my concerns, instructing me to 'just apply again ' rather than addressing the improper use of inaccurate data.

This lack of accountability and failure to correct an obvious error demonstrates that Comenity may be violating FCRA regulations and failing to properly manage financial data in compliance with consumer protection standards. 

NOTICE OF INTENT TO ESCALATE. 
If Comenity fails to correct this issue within 30 days, I will : File a formal complaint with the Federal Trade Commission ( FTC ) to initiate an investigation into Comenitys credit reporting practices.

Submit official complaints to state regulators in Delaware and Utah, where Comenity operates.

Pursue legal action under the FCRA, seeking statutory damages, punitive damages, and attorneys fees for willful violations. 
CLARIFICATION REGARDING THE CFPB 'S ROLE. 
I acknowledge that during the informal complaint process, the CFPB does not take direct action on individual complaints. However, I am submitting this complaint to ensure that : Comenity receives and responds to this complaint in accordance with consumer protection guidelines.

The CFPB documents this issue for potential future enforcement actions, as Comenitys handling of credit evaluations may reflect a broader pattern of misconduct.

CONCLUSION This issue extends beyond an isolated credit denial. It reflects a broader concern about how Comenity manages, transmits, and verifies consumer financial data, potentially impacting thousands of consumers. The CFPB plays a key role in ensuring that financial institutions uphold consumer data integrity, proper identity verification, and accurate information transmission in financial and telecommunications networks. 

I request that Comenity respond directly to this informal complaint with a full explanation and corrective action within 30 days. Please send all correspondence to the address listed above. 

Thank you for your time and attention to this matter. I look forward to your response. 

Sincerely, XXXX XXXX