Product: Vehicle loan or lease

To : Consumer Financial Protection Bureau XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXXXXXX Date : XX/XX/year> RE : Multiple FCRA and ECOA Violations by XXXX XXXX XXXX XXXX XXXX : XXXX To whom it may concern : I am writing to report serious violations of the Fair Credit Reporting Act ( FCRA ) and Equal Credit Opportunity Act ( ECOA ) by American Credit Acceptance ( ACA ) regarding an adverse action notice dated XX/XX/scrub>XXXX XXXX 

Violations and Associated Penalties : 1. Failure to Provide Specific Reasons for Denial ( ECOA Regulation B, 12 CFR 1002.9 ) - The notice fails to provide specific reasons for denial in the initial communication - Instead, it requires the consumer to make an additional request within 60 days - This violates ECOA 's requirement for automatic disclosure of specific reasons - Penalty : Up to {$11000.00} per violation plus actual damages 2. Incomplete Adverse Action Information ( FCRA 615 ( a ) ) - The notice indicates they " can not open an account '' but simultaneously offers credit on unspecified terms- This contradictory information violates FCRA 's clear disclosure requirements- The terms of the counteroffer are not specified, only stating " PLEASE CONTACT DEALERSHIP FOR DETAILS '' - Penalty : Actual damages plus punitive damages for willful noncompliance 3. Missing Credit Score Information ( FCRA 615 ( h ) ) - While the credit score is disclosed ( 632 ), the notice fails to provide : * The key factors that adversely affected the credit score ( left blank in the notice ) * The source of the scoring model * A clear explanation of how the score was used in the decision - Penalty : Up to {$2500.00} per violation plus actual damages 4. Improper Notice Format ( ECOA Regulation B ) - The notice buries important consumer rights information on the second page- The format makes it difficult for consumers to understand their rights and take appropriate action- This violates the " clear and conspicuous '' requirement - Penalty : Statutory damages plus actual damages XXXX. Insufficient Counteroffer Disclosure ( Regulation B 1002.9 ( a ) ( 2 ) ) - The counteroffer lacks specific terms and conditions - Directing consumers to " contact dealership '' violates the requirement for clear written disclosure of counteroffer terms- Penalty : Statutory damages plus actual damages 6. Chain of Credit Decision Responsibility - The notice indicates the application was forwarded by XXXX XXXX but fails to clarify : * Whether XXXX  made an initial credit decision * The relationship between XXXX XXXX XXXX XXXX Which entity is ultimately responsible for the adverse action- This violates FCRA 's clear disclosure requirements Legal Basis for Penalties : 1. FCRA Statutory Damages : - Up to {$1000.00} per violation for negligent noncompliance - Actual damages plus punitive damages for willful noncompliance - Attorney fees and costs 2. ECOA Statutory Damages : - Up to {$11000.00} in individual actions - Actual damages- Punitive damages up to {$500000.00} or 1 % of the creditor 's net worth - Attorney fees and costs 3. Pattern or Practice Violations : - The format and multiple omissions suggest systematic violations - This could trigger additional civil penalties up to {>= $1,000,000} Requested Actions : 1. Investigation into ACA 's adverse action notice practices 2. Audit of all adverse action notices issued by ACA in the past 2 years 3. Civil monetary penalties for willful noncompliance 4. Required revision of their adverse action notice template 5. Mandatory staff training on FCRA and ECOA requirements 6. Restitution for affected consumers 7. Implementation of compliance monitoring systems The violations in this notice demonstrate a systematic failure to comply with fundamental consumer protection laws. These violations can cause significant harm by : - Denying consumers their right to understand credit decisions- Preventing consumers from taking informed actions to improve their creditworthiness - Creating confusion about available credit options- Obscuring consumer rights under federal law I request immediate investigation and enforcement action against American Credit Acceptance for these violations. 

Sincerely, XXXX XXXX Attachments : - Copy of adverse action notice dated XX/XX/year> - Application documentation - Related correspondence