Product: Credit card

XXXX XXXX XX/XX/year> Notice to an agent is notice to the principal. 


Dear Goldman Sachs Bank USA Compliance Department, I write in response to your investigation summary regarding the CFPB complaint involving the Apple Card. Your conclusion that " no error occurred '' is unsupported, as your response does not provide verifiable proof that disclosures and billing statements were delivered in compliance with 15 U.S.C. 1666b and 15 U.S.C. 1637 ( b ) of the Truth in Lending Act.

Under 15 U.S.C. 1666b ( a ) - Timing of Payments : " A creditor may not treat a payment on a credit card account under an open-end consumer credit plan as late for any purpose, unless the creditor has adopted reasonable procedures designed to ensure that each periodic statement including the information required by section 1637 ( b ) of this title is mailed or delivered to the consumer not later than 21 days before the payment due date. '' You mentioned that The Bank does not provide the additional documentation the Customer has requested ( such as tracking number, receipt of delivery etc. ) but this is the only information that can be used to prove if the disclosures were mailed or delivered not later than 21 days before the payment due date. 

Your response fails to provide evidence that reasonable procedures were followed to ensure the timely delivery of periodic statements. 


15 USC 1637 ( b ) mandates that creditors transmit a periodic statement to the account holder for each billing cycle in which there is an outstanding balance or finance charge. The statement must include, among other items : The outstanding balance, The minimum payment required, The due date for payment, and Any finance charges imposed during the billing cycle.

The absence of verifiable proof of timely delivery for these periodic statements directly violates the statutory requirements of 15 U.S.C. 1637 ( b ). 

My initial complaint requested specific evidence, such as : A tracking number, A receipt of delivery, or Other verifiable documentation confirming that disclosures and statements were delivered at least 21 days before the payment due date. 

Your response failed to provide this evidence, and instead referenced general notification practices that do not meet the statutory standard. Your response does not include details of the procedures employed to ensure compliance with 15 U.S.C. 1666b. Without such information, the Bank can not substantiate its claim that " no error occurred. '' Pursuant to 15 U.S.C. 1681i ( a ) ( 6 ) ( B ) ( iii ) and 15 U.S.C. 1681i ( a ) ( 7 ), you are required to provide a detailed explanation of the methods and evidence used in your investigation and how you used it to determine the validity of the reported late payments. These details are missing from your response.

To resolve this matter, I request the following : Verifiable evidence that billing statements were mailed or delivered at least 21 days before the payment due date, as required by 15 U.S.C. 1666b.

Include documentation such as tracking numbers, delivery confirmations, or other forms of proof.

A detailed explanation of the procedures and systems used to ensure compliance with 15 U.S.C. 1666b and 15 U.S.C. 1637 ( b ).

Your response must address the legal requirements raised. Any unrelated or irrelevant information will be interpreted as an attempt to evade compliance and will be noted for potential escalation.

Failure to provide the requested documentation will nullify your conclusion that " no error occurred '' and may constitute a willful violation of 15 U.S.C. 1666b, 15 U.S.C. 1637 ( b ), and 15 U.S.C. 1681n. I request a complete and substantiated response within 10 business days. 

Sincerely, XXXX XXXX