Product: Vehicle loan or lease

To Whom It May Concern, I am filing a formal complaint against USAA regarding its handling of my auto loan applications, which I believe violates federal regulations, including the Equal Credit Opportunity Act ( ECOA ) under 12 C.F.R. 1002.9 ( a ) ( 1 ) and provisions under the Fair Credit Reporting Act ( FCRA ) and Regulation Z ( 12 C.F.R. 1026.9 ( c ) ).

Background 1. Initial Application and Counteroffer On [ XX/XX/year> ], I applied for an auto loan with USAA for {$45000.00}. USAA issued a counteroffer for {$25000.00}, which I accepted. 
2. Second Application Due to Internal Process Issues Shortly after, I was informed by a USAA representative that the original application could not be modified from a private dealer purchase to a dealer purchase. I was instructed to reapply. A second application was submitted by the representative for {$45000.00} instead of the {$25000.00} counteroffer, leading to a denial. 
XXXX. Third Application and Application Marked as Stopped When I called again to address the issue, I was again told to reapply, as USAA could not amend the prior applications. A third application was submitted by the representative, this time reflecting the {$25000.00} counteroffer. However, I was later informed that this application was stopped a decision I never authorized or requested. 
4. Inconsistent and Invalid Denial Reasons For the second application, USAA stated the denial was due to insufficient credit history and insufficient or lack of income. However, this reasoning is inconsistent and invalid, as : My financial circumstances had not changed between the initial approval for {$25000.00} and the subsequent applications. 
USAA used the same credit report and information to approve the initial application, so claiming insufficient credit history or income on identical data is baseless. 
XXXX. Impact of USAAs Errors The repeated denials and resubmissions caused unnecessary harm to my credit due to multiple hard inquiries. 
My ability to secure financing was delayed and obstructed due to USAAs internal inefficiencies and mismanagement of my applications. 

Violations USAAs actions constitute violations of the following : 1. Failure to Provide Consistent and Specific Reasons for Denial Under ECOA ( 12 C.F.R. 1002.9 ( a ) ( 1 ) ), lenders must provide specific, consistent, and accurate reasons for credit denials. The cited reasons ( insufficient credit history and insufficient income ) directly contradict the fact that my creditworthiness had already been established in the initial application, where I was approved for {$25000.00}. 
USAAs inconsistent application of these reasons violates my rights under ECOA.

2. Improper Handling of Credit Applications Under Regulation Z ( 12 C.F.R. 1026.9 ( c ) ), creditors are required to administer credit offers fairly and transparently. The mishandling of my counteroffer and multiple denials, including marking an application as stopped without my consent, is neither fair nor transparent. 
XXXX. Excessive and Harmful Credit Inquiries Under the Fair Credit Reporting Act ( FCRA ), excessive hard credit inquiries that are unnecessary or duplicative are prohibited. 
USAA conducted XXXX hard credit pulls within a matter of days for what was effectively the same loan request, causing avoidable harm to my credit score.

4. Unfair and Deceptive Practices Repeatedly requiring me to reapply and then denying my applications based on internal errors amounts to unfair and deceptive practices, violating federal consumer protection laws.

Harm and Impact As a result of USAAs actions : 1. My credit score has been negatively impacted by multiple unnecessary hard inquiries.

2. I have experienced financial harm, as I was unable to secure the approved financing for the vehicle. 
XXXX. I suffered significant emotional distress and lost time due to USAAs repeated errors and mishandling of my applications. 

Requested Resolution I am requesting the following corrective actions : 1. Removal of all but one hard inquiry related to these applications from my credit report to mitigate the harm caused to my credit score.

2. A detailed explanation and documentation of why my second and third applications were denied, including how USAA determined insufficient income and insufficient credit history despite approving the initial application.

3. A review of the internal processes that led to this mishandling of my applications, including how one of my applications was marked as stopped without my authorization.

4. Reconsideration of my original application terms, including the counteroffer for {$25000.00}.

If these matters are not resolved promptly, I intend to pursue further actions, including filing complaints with other regulatory agencies and exploring legal remedies. 

Thank you for your attention to this matter. 

Sincerely, XXXX XXXX