Product: Checking or savings account

1. I have had Bank of America checking and savings accounts here in XXXX XXXX, Florida since XXXX of XXXX. 
2. Since XXXX, I have routinely used XXXXBoA 's ATM at XXXX XXXX XXXX, in XXXX XXXXXXXX XXXX XXXX XXXX as do many of the 5-6 million tourists who visit our town a annually, thousands college students at XXXX XXXX XXXX and locals in this walkable, livable XXXX XXXX in America, where many of us don't own cars. 
3. On XX/XX/XXXX, after speaking at an event in nearby XXXX, XXXX XXXX XXXX XXXX XXXX, founded in XXXX, I took a cab home. We stopped at the XXXX XXXX XXXX ATM location to deposit a check. The cab driver and I were shocked to see a newly plastered wall in place of BoA 's ATM. No sign. No explanation. 
4. Repeated telephone calls and sincere efforts to resolve the problem with BoA have been unavailing. BoA closed its only downtown XXXX XXXX ATM location without first arranging a substitute, thereby apparently violating ADA, Civil Rights and Federal Banking Laws. 
5. On XX/XX/XXXX, I called and filed a serially numbered complaint with BoA 's call center, which later advised me to call its local managers. 
6. The call center advised me that BoA has apparently deleted all records that it ever had an ATM at XXXX XXXX. The call center had no explanation to offer, which is why they eventually referred me to BoA 's local managers. None took personal responsibility for the closing fo the ATM, or provided the name of any decisionmaker, or even the name of BoA '' s Americans with Disabilities Act Coordinator. 
7. On XX/XX/XXXX, an unfriendly manager at the BoA location south of the City told me I should just " hop '' to another location. His attitude was ignorant and frivolous. Many people use that ATM, which is an integral part of commerce in our walkable, accessible town, where some local businesses are cash-only ( including restaurants ). 
8. I explained to this manager that I am not going to " hop '' anywhere. 
9. I explained that have XXXX, do not drive, and am recently recovering from cXXXX XXXX XXXX XXXX XXXX XXXXXXXX at the XXXX XXXX XXXX 
10. The two ( 2 ) other locations to which h he wanted me to " hop '' are inconvenient and inordinately distant for someone walking. We have badly gridlocked roads ; XXXX XXXX XXXX is one of the fastest-developing areas in the United States XXXX 
11. The unhelpful manager seemed utterly unfamiliar our area, stating of one branch on XXXX XXXX that " they apparently call it the island. '' 12. I requested the manager transfer me to, or provide me with the name and contact information, for BoA 's ADA Coordinator. 
13. The manager refused to provide the information.

14. By way of dramatic non sequitur and diversion, the unctuous uncouth manager ululated about how his " mother is XXXX " ( with XXXX XXXX 25 years ) and that her would not discriminate against the XXXX. 
15. The manager still resisted sharing the easily accessible information and identity of BoA 'S ADA Coordinator. 
16. While he was admittedly never consulted by BoA on the ATM closing decision, the impertinent BoA manager concluded that BoA closing the ATM was a " business decision. '' 17. " How trite, '' as my mother might say, 18. The ATM in quo is frequently used and in a safe location. 
19. The manger did not articulate any legal or rational basis for BoA '' s erroneous, discriminatory " business decision. '' 20. I explained that every discriminatory decision in world history was a " business decision. '' 21. Then the unctuous, uninformed BoA manager curtly and dismissively gave me the number of BoA 's main incoming trunk line, and hung up the telephone. 
22. Neither that local BoA manager, or any other BoA manager anywhere, at any time, has put me in touch with BoA 's ADA Coordinator. 
23. Other local BoA managers were immediately made aware of the first local manager 's behavior.

24. BoA has, a fortnight after I learned of its ATM closing at XXXX XXXX XXXX, has still not resolved the problems that its discriminatory and unexplained " business decision '' created for tourists, low-income residents, students, XXXX  and others. 
25. BoA has offered no written for verbal explanation for its illegal shutdown of its only ATM in our XXXX XXXX XXXX XXXX 
26. BoA has made.no explanation for its maladroit, mendacious manager 's hateful response to consumer concerns.