Product: Vehicle loan or lease

I am submitting this formal complaint to the Consumer Financial Protection Bureau ( CFPB ) regarding ACIMAs deceptive practices and violations of the Truth in Lending Act ( TILA ). ACIMA has engaged in conduct that misrepresents the nature of their financial agreements, undermines my consumer rights, and fails to comply with federal consumer protection laws. 

Nature of the Complaint ACIMA advertises on its website that they provide " shopping power '' ranging from {$300.00} to {$5000.00}, allowing consumers to acquire products upfront and defer payments. However, they simultaneously claim that their agreements are " unlike a credit transaction '' and that consumers are " not committing to owning a product at the start. '' This contradiction is deceptive and misleading, as the functionality of " shopping power '' aligns with the legal definition of credit under TILA.

Furthermore, ACIMA fails to provide the necessary disclosures required by TILA, including the annual percentage rate ( APR ), finance charges, and other key terms associated with the extension of credit. Instead, they obscure the nature of the transaction, presenting it as something other than what it is. 

When entering into this agreement, I believed I was engaging in a straightforward lease transaction. However, upon further examination, it became clear that the terms of the agreement equated to an extension of credit, which ACIMA did not clearly disclose. This lack of transparency has caused confusion, financial harm, and a violation of my rights under federal law. 

Supporting Case Law The deceptive practices of ACIMA are strikingly similar to the violations highlighted in XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. 1977 ). In XXXX, the court held that when a financial agreement functions as an extension of credit, it must comply with TILAs disclosure requirements, even if the creditor attempts to present it differently. Specifically, the court ruled that failure to accurately disclose the terms of credit constitutes a violation of TILA, as such omissions prevent consumers from making informed decisions. 

ACIMAs actions parallel those of the defendant in XXXX. By offering " shopping power '' and structuring their agreements to defer payment while denying that the arrangement constitutes credit, ACIMA effectively obscures the transaction 's true nature. This misrepresentation deprives consumers of the clear, conspicuous disclosures required under XXXX, rendering their agreements unlawful. 

Violations of the Truth in Lending Act ACIMA has violated the following provisions under TILA : 1. 15 U.S.C. 1635 ( Right of Rescission ) : I was not provided with the necessary disclosures to understand the true nature of the transaction, thereby triggering my right to rescind the agreement.

2. 15 U.S.C. 1667d ( Civil Liability ) : ACIMAs failure to provide clear and accurate disclosures regarding the credit terms renders them liable for civil penalties under TILA.

3. 15 U.S.C. 1667a ( Required Disclosures ) : ACIMA did not provide an accurate statement of the finance charges, annual percentage rate, or payment schedule, as required for credit transactions.

Consumer Impact and Relief Requested ACIMAs deceptive practices have caused financial confusion and harm. Their failure to disclose the true terms of the agreement prevented me from making an informed decision and violated my rights under federal law.