Product: Credit card or prepaid card

Section 1036 ( a ) ( 1 ) ( B ) of the CFPA prohibits unfair acts or practices. 12 U.S.C. 5536 ( a ) ( 1 ) ( B ). 22. An act or practice is unfair under the CFPA if it : ( a ) causes or is likely to cause consumers substantial injury ; ( b ) such injury is not reasonably avoidable by consumers ; and ( c ) such injury is not outweighed by countervailing benefits to consumers or to competition. 12 U.S.C. 5531 ( c ).

In response to 211117-7635684, American Express acknowledges it accelerated the outsanding balance on a charge card account because it was allegedly forty-two ( 42 ) days past-due. Moreover, American Express acknowledges hiring an outside company, XXXX XXXX on XXXX XX/XX/XXXX " to assist in collection efforts '' on an account that was allegedly past-due. Moreover, American Express acknowledged that my account " is not eligible for paperless billing statements. '' Thus, the statements would have required mailing to my address on-file. 

In XXXX, American Express then alleges that since I was not eligible for paperless billing statements, statements were allegedly mailed by American Express to the address on-file. The expectation was then that ANY payment to be made would be made through the outside agency. American Express also expected me to direct any inquiries regarding my account to the outside agency. No information nor ability to pay would be provided to me through the American Express web portal : " since your account is with an outside collection agency, we mailed your statements and directed you to the outside collection agency for information about your account instead of directing you to your online account to view statements and or make payments. '' In response to CFPB XXXX XXXX, American Express acknowledged that they were notified electronically by XXXX that I was not receiving statements. American Express did NOT conduct an investigation or verify the address on-file as a result. Rather, American Express concluded that it could not possibly be a billing error with their mailing procedures and process. Consequentially, American Express acknowledged believed it was sufficient for XXXX to verify my address over the phone. 
In CFPB XXXX XXXX, American Express acknowledges that it sent my account to another collection agency On XXXX XX/XX/XXXX, XXXX XXXX 

As of XXXX XX/XX/XXXX, my credit reports no show the American Express account is one-hundred twenty ( 120 ) days past-due, with an alleged delinquency beginning XXXX of XXXX -- the month when the collection agency changed from XXXX to XXXX. 

Blocking someone from being able to receive paperless billing statements when it is known a consumer is not receiving their paper statements for whatever the reason is patently unfair. Having a collection agency direct a consumer to use a link to pay that requires knowing the FULL account number for the account in question is patently unfair. Providing PAST billing statements in response to complaints AFTER the account becomes past-due is patently unfair. As a matter of fact, Regulation Z requires American Express to provide periodic billing statments ton a regular basis. 

The issue at-hand is whether the data furnished to the CRAs regarding an alleged delinquecy on my account is fair. If I have notified American Express electronically, through a collection agent of their choosing that then files a billing error notice, and American Express refuses to conduct an investigatino pursuant to 12 CFR 1026.13, then it is unfair to supply adverse payment information to the CRAs for that account. If American Express then changes the collection agency and I have no contact with them especially before the next due-date, in this case transerred on XXXX XX/XX/XXXX with the next due date XXXX XX/XX/XXXX, then it is not fair. Each of these actions taken by American Express reflects tactics that it knows, or should know, causes significant injury to a consumer 's credit files. Moreover, American Express knows, or should know, that such actions taken in concert with an inability for a consumer to access paperless billing statements, would leave the principal payment and interest charges for any subsequent billing period unknown to the consumer. 

American Express set up a system of procedures and process specifically to damage consumers if it could not get its way. The initiation of the scheme is acceleration of a full balance on an account due to alleged serious deliquency, in this case an alleged forty-two ( 42 ) days past-due. It is worth mentioning that it is customary of accounts to be sent to outside collection agencies for recovery when meeting a threshold of multiple months in the arrears, for eaxmple, ninety ( 90 ), one-hundred twenty ( 120 ), or even one-hundred fifty ( 150 ) days past-due.The collective actions taken by American Express are set up to specifically place certain groups of cardmembers ( consumers ) in a position of being held XXXX, where the only relief is to authorize American Express unfettered access to one ( 1 ) or more of the consumer 's bank accounts and " trust, '' orally that what an agent of American Express says is " owed '' is indeed accurate without being able to inspect a billing statement. This construction specfically denies a consumer the ability to check a statement itself for errors, overall depriving a consmer the right to dispute the validity of charges, errors, and payment history that is supplied to consumer reporting agencies on a routine basis. The outcome of not " trustig '' what in this case " can not be seen or inspected, '' is injury to a consumer by reporting delinqency statuses to consumer reporting agencies that then damages the credit-worthiness of a consumer with other current or potential creditors. The negative history itself can stay in a consumer file for up to seven ( 7 ) years. None of these processes and procedures were established for the benefit of the consumer, nor do they benefit competition. Rather they were established explicitly for American Express to be able to hold cardmembers XXXX that its analytics systems and practices determined to be of " higher risk '' relative to the risk appetite in the current economic and health environment.