Product: Checking or savings account

A. What Happened : I am a XXXXXXXX XXXX  and resident in XXXX XXXX, Connecticut. I am seventy-five years old. I have been an account holder of the Bank of America XXXX ( BOFA, XXXX XXXX XXXX XXXX, XXXX, NC XXXX ) including its predecessor Nations Bank for 29 years. I am writing to you to file an official complaint against the BOFA for its negligence in customer development, maintenance of the accuracy of customers information, and monetary transfers. Because of the negligence of the bank, XXXX scammers and associates of fraudulent trading platform XXXX became account holders of the BOFA likely because false information was used for opening the bank accounts, and XXXX of these account holders received a significant amount of money transferred from my bank accounts, mostly from my BOFA account. I lost all my life savings, home equity and other loans. 

In XX/XX/XXXX to XX/XX/XXXX, I was scammed by fraudulent trading platforms in investments and trading for XXXX and international currency with a monetary loss of {>= $1,000,000}. All the money I lost was transferred from my bank accounts in the United States, mostly from my BOFA account, through thirty-one monetary transfers to recipients designated by the fraudulent trading platforms. These platforms eventually disappeared. 

Among the total of thirty-one monetary transfers, XXXX transfers ( a total of {$880000.00} ) were all domestic transfers to XXXX recipients and account holders of the BOFA, and they were all requested by the fraudulent trading platform XXXX ( https : //www.civersex.com ). Each of these BOFA account holders was designated as an acceptor by the trading platform for the monetary transfer, and each account holder had a contact address in the XXXX of California or New York. Please see Attachment XXXX : List of XXXX Monetary Transfers to XXXX Recipients and Account Holders of the Bank of America XXXX by Trading Platform Coiniverse, and Attachment XXXX : XXXX XXXX XXXX XXXX XXXX XXXX XXXX Account XXXX XXXX Bank of America XXXX by Trading Platform Coiniverse. 

As shown in Attachments XXXX and XXXX, these BOFA account holders are XXXX XXXX XXXX XXXX ( XXXX transfer for {$5000.00} ), XXXX XXXX XXXX ( XXXX transfer for {$22000.00} ), XXXX XXXX XXXX ( XXXX transfers for {$760000.00} ), XXXX XXXX XXXX XXXX XXXX ( XXXX transfers for {$62000.00} ), XXXX XXXX XXXX XXXX ( XXXX transfer for {$6000.00} ), and XXXX XXXX ( XXXX transfer for {$30000.00} ). 

In addition, the fraudulent trading platform Coiniverse did designate another BOFA account holder as an acceptor and requested that I send money to pay income tax if I withdrew money from the platform. No money was sent with this request. The information of this account holder follows. Company Name : XXXX Dots XXXX XXXX ; Account Number : XXXX XXXX XXXX ; ACH Routing Number : XXXX ; Company Address : XXXX XXXX XXXX, XXXX, NY XXXX ; Domestic Wire Number : XXXX ; XXXX XXXX : XXXX ; Bank Address : XXXX XXXX Ave., XXXX, NY XXXX ; Phone Number : XXXX. Please see Attachment XXXX : A printout of WhatsApp messages of Coiniverse-May, the Customer Service XXXX XXXX Trading Platform Coiniverse. 
Among the total of thirty-one transfers, the XXXX transfers ( for a total of {>= $1,000,000} ) included XXXX domestic transfers and XXXX international transfers. Please see Attachment XXXX : List of XXXX XXXX XXXX to Recipients Requested by Fraudulent Trading Platforms, and Attachment XXXX : XXXX XXXX XXXX XXXX XXXX to Recipients Designated by Fraudulent Trading Platforms. 

The recipients of the XXXX domestic transfers are : XXXX XXXX XXXX ( XXXX XXXX ), XXXX XXXX XXXX XXXX ( XXXX XXXX ), and XXXX XXXX ( XXXX XXXX, XXXX, XXXX, XXXX and XXXX ). The recipients of the XXXX international transfers are all located in XXXX XXXX and they are : XXXX XXXX ( XXXX XXXX ), XXXX XXXX ( XXXX XXXX ), XXXX XXXX XXXX ( XXXX XXXX ), FL XXXX XXXX XXXX ( XXXX XXXX ), XXXX XXXX XXXX, Limited ( Sn XXXX ), XXXX XXXX XXXX XXXX ( XXXX XXXX ), XXXX Mo XXXX XXXX XXXX ( XXXX XXXX ), XXXX XXXX XXXX ( XXXX XXXX ), Law Oi XXXX ( XXXX XXXX ), and XXXX XXXX XXXX, XXXX ( XXXX XXXX and XXXX ). 

The purpose of money transfers to XXXX was to purchase a cryptocurrency and the cryptocurrency was then sent to a trading platform. XXXX XXXX XXXX, the rest of domestic and recipients of the XXXX transfers were designated by fraudulent trading platforms. Like the recipients and account holders of the XXXX, they are likely scammers and associates of the fraudulent trading platforms. 
In viewing the original transfer records shown in Attachments A and B, numerous errors and/or discrepancies can be seen easily for information of the BOFA account XXXX. For example, the BOFA account XXXX XXXX XXXX XXXX has XXXX zip codes : NY XXXX ( transfers SN XXXX to XXXX ) and NY XXXX ( transfer SN XXXX ) for its address in XXXX, NY. This account holder has XXXX routing numbers for its BOFA account XXXX : XXXX ( transfers SN XXXX and XXXX ) and XXXX ( transfers SN XXXX, XXXX & XXXX ). This account holder with the same account number and same routing number has XXXX XXXX XXXX addresses for the BOAF : XXXX XXXX, New York, NY XXXX ( SN XXXX ) and XXXX XXXX Ave., New York, NY XXXX ( SN XXXX ). 

The original transfer records also showed that the BOFA account XXXX XXXX XXXX XXXX XXXX XXXX has XXXX routing numbers at the BOFA : XXXX ( SN XXXX to XXXX ) and XXXX ( SN XXXX ). This account holder with the same account number in the BOFA has XXXX XXXX XXXX addresses for the bank : XXXX XXXX, New York, NY XXXX ( SN XXXX & XXXX ), XXXX XXXX XXXX XXXX, XXXX XXXX, New York, NY XXXX ( SN XXXX ), and XXXX XXXX Ave., XXXX, NY XXXX ( SN XXXX ). 

The above examples of errors and/or discrepancies in transfer records demonstrate the work quality of the BOFA. 

For each of the XXXX money transfers presented in the Attachments XXXX and XXXX, the trading platform XXXX designated a BOFA account holder as the acceptor, provided detailed bank account information, and instructed that when transfer is conducted, leave it blank in the remarks and do not put any text in the remarks. Please see pages XXXX, XXXX, XXXX, XXXX, XXXX, XXXX, XXXX, XXXX and XXXX of the Attachment XXXX. The printout of the transfer instructions was presented to the bank before each transfer was conducted. A cautious banker would have been alerted to the potential scam by seeing the printout of the instructions and have prevented the transfer. No one at the bank, however, had any questions on the instructions, and each transfer was conducted without hesitancy. XXXX of XXXX transfers were conducted at the BOFA between my BOFA account and the BOFA accounts of the scammers, as presented in Attachments XXXX and XXXX. 

The section XXXX of Funds Transfer Agreement of the BOFA says : For certain transfers of funds made out of the Bank accounts, we will provide a confirmation to you by mail at the address indicated in our records or through Online Banking if you selected paperless delivery through Online Banking for your deposit account documents. The confirmation will note the date and the amount of the transfer and the bank institution to which the transfers was made. In fact, twenty-six out of the thirty-one transfers listed in Attachment XXXX and XXXX were conducted by the BOFA and I never XXXX such a confirmation. 

I reported the case to XXXX XXXX Department XXXX Police XXXX, Connecticut and the Federal Bureau of Investigation ( FBI ) of the XXXX Department of Justice in XX/XX/XXXX. I was interviewed by the FBI, XXXX XXXX XXXX, Connecticut in XX/XX/XXXX. Since then, the FBI has conducted investigations on the case. The FBI recently informed me of a difficulty in physically getting the XXXX BOAF account holders in the United States likely because false information was used for opening the bank accounts. I expressed my desire to have a complaint or civil lawsuit against the XXXX. The FBI XXXX responsible for the case showed his support and indicated that I can provide his contact information whenever needed and he will provide related information and support. 

B. My Claims : I have been an account holder of the BOFA including its predecessor for 29 years and the bank owed me a duty of care because of the relationship between the customer and the bank. Based on facts, I formally allege that the BOFA had significant negligence in customer development, maintenance of the accuracy of customers information, and monetary transfers. 

Claim XXXX : The BOFA had significant negligence in customer development for failing to practice restricted policies and procedures in opening accounts for customers and in verifying the authenticity of customers information. This led to the fact that XXXX scammers and associates of the fraudulent trading platform XXXX became BOFA account holders likely because false information was used for opening the bank accounts, and XXXX of them received a total of {$880000.00} transferred from my bank accounts. 

Supporting Facts : The total of {$880000.00} was transferred to XXXX BOFA account holders. Each of these account holders was designated as an acceptor by the fraudulent trading platform XXXX, and each had a mailing address in the XXXX. The money transfers were conducted as domestic transfers from my bank accounts to the BOFA account holders. In addition, the fraudulent trading platform did designate another BOFA account holder XXXX XXXX XXXX XXXX as the recipient of a money transfer, but no money was transferred to this account. All these BOFA account holders are clearly scammers and associates of the trading platform. 

The FBI started an investigation on this case in XXXX, and recently informed me of a difficulty in physically getting the XXXX BOAF account holders in the United States likely because false information was used for opening the bank accounts. I believe that the FBI must have contacted the BOFA for the case, and that the BOFA should have frozen the XXXX scammers accounts. It should be a responsibility of the BOFA to assist the FBI to bring the suspected criminals to justice. 

Claim XXXX : The BOFA had significant negligence for failing to ensure the accuracy of customers information and to conduct monetary transfers with required work quality and cautions. This contributed to the fact that a significant amount of money was transferred from my XXXX account to recipients designated by fraudulent trading platforms. 

Supporting Facts : Records of XXXX monetary transfers to the XXXX BOFA account holders ( Attachments XXXX and XXXX ) showed numerus errors and/or discrepancies. For example, a single scammers BOFA account holder has multiple zip codes for its mailing address and multiple routing numbers for the account. The same account holder with the same account number and same routing number has XXXX XXXX addresses for the XXXX. 

For each of the XXXX transfers listed in Attachment XXXX, the fraudulent trading platform XXXX provided unusual transfer instructions : leave it blank in the remarks and do not put any text in the remarks. The printout of the transfer instructions was presented to the bank before each transfer was conducted. A cautious banker would have been alerted to the potential scam by reading the instructions and have prevented the transfer. No one at the bank, however, had any questions on the instructions, and each transfer was conducted without hesitancy. XXXX of XXXX transfers were conducted at the BOFA. 

Of the total of thirty-one transfers, twenty-six were conducted by the BOFA and I never XXXX a transfer confirmation as specified in the Funds Transfer Agreement of the bank. 

Because of the limit of uploaded file size, Attachment XXXX was not uploaded and will be provided upon request.