Product: Checking or savings account

I am writing to formally demand the reinstatement of my full membership privileges at Navy Federal Credit Union ( NFCU ), including access to a debit card and loan products. Despite their previous response to my CFPB complaint ( Case # XXXX ) claimed my restrictions were lifted, yet I am still unable to obtain a debit card or apply for loans. Stating that my account restriction was removed, I am still being denied financial services without justification. The fact that you still own the debt but transferred it for collection does not give you the right to deny me a debit card or loans. Navy Federal " two-year policy restricting members after a charge-off is an internal rule, NOT a law This practice violates federal consumer protection laws and the 2016 CFPB enforcement order ( XXXX XXXX. XXXX ) against Navy Federal, in which the Consumer Financial Protection Bureau ( CFPB ) fined NFCU {$28.00} XXXX for using unfair debt collection tactics and wrongfully restricting member accounts. 

Unlawful Practices in Violation of Federal Law 1. Navy Federals Continued Membership Restrictions Violate CFPBs 2016 Order The CFPBs 2016 enforcement action found that Navy Federal : Used false threats to collect debts. 
Wrongfully restricted access to financial services to pressure members into paying past-due accounts. 
Placed unfair restrictions on debit cards, loans, and account access, even after debts were transferred to third-party collectors. 
Was ordered to stop these practices and paid {$28.00} XXXX in fines for these violations. 

Since my charged-off account was transferred to XXXX for collection, Navy Federal should no longer be restricting my financial access based on an outdated internal rule. Your actions are in direct violation of this CFPB ruling. 

2. Navy Federals Internal " Two-Year Restriction Policy '' is NOT a Law Navy Federal has cited a two-year membership restriction policy following a charge-off. This is an internal rule, NOT a federal law. 

There is NO federal regulation allowing a two-year restriction on banking privileges. 
If this policy violates federal consumer protection laws, it is unenforceable and should not be used to deny me financial services. 
Since the CFPB already ruled that restricting accounts based on past-due debts is unlawful, your continued enforcement of this two-year restriction is a clear attempt to continue illegal practices. 
3. Violation of the Fair Credit Reporting Act ( FCRA ) 15 U.S.C. 1681s-2 ( b ) Under FCRA ( 15 U.S.C. 1681s-2 ( b ) ), Navy Federal , as a furnisher of financial data, is required to : Provide accurate information and correct any inaccuracies in a timely manner. 
Cease reporting negative information that is unverifiable or no longer accurate. 
Ensure that any internal records used for credit and loan decisions are fair, accurate, and updated. 

By continuing to restrict my access to loans and debit cards based on an outdated internal record, NFCU is failing to maintain accurate internal reporting and is engaging in deceptive practices under the FCRA. 

4. Violation of the Dodd-Frank Act Unfair, Deceptive, or Abusive Acts and Practices ( UDAAP ) Under the Dodd-Frank Wall Street Reform and Consumer Protection Act, financial institutions are prohibited from engaging in Unfair, Deceptive, or Abusive Acts or Practices ( UDAAP ) ( 12 U.S.C. 5531 ). 

Blocking access to loans and debit cards while falsely stating that my account restriction was removed is an unfair and deceptive practice. 
Using an internal rule ( two-year restriction ) to justify restricting financial access when CFPB ruled against this practice is abusive. 

This ongoing misconduct is grounds for regulatory enforcement under federal banking laws. 

5. Navy Federals Reporting to XXXX XXXX XXXXXXXX XXXX XXXX  ) Possible FCRA Violation In your previous response, you stated that Navy Federal reported my checking account history to XXXX XXXX XXXX XXXX XXXX XXXX 
If this report contains inaccurate, outdated, or misleading information, NFCU may be violating the FCRA by failing to ensure data accuracy. 
If EWS is being used as an excuse to restrict my access to loans, you must disclose exactly what is preventing me from obtaining financial services. 

Their actions violate the following federal laws : Fair Credit Reporting Act ( FCRA ) 15 U.S.C. 1681s-2 ( failure to update and correct internal membership records ).

Dodd-Frank Act ( UDAAP ) 12 U.S.C. 5531 ( unfair and deceptive banking practices ).

Equal Credit Opportunity Act ( ECOA ) 15 U.S.C. 1691 ( failure to provide a formal credit denial notice ). 
XXXXlectronic Fund Transfer Act ( EFTA ) 15 U.S.C. 1693 ( wrongfully restricting debit card access ).

Fair Debt Collection Practices Act ( FDCPA ) 15 U.S.C. 1692e & 15 U.S.C. 1692f ( deceptive and unfair debt collection tactics ).

Navy Federals continued use of an unlawful " two-year restriction policy '' directly contradicts the CFPBs 2016 enforcement order ( XXXX XXXX. XXXX ), which prohibited them from restricting financial services due to past-due accounts. 

Additionally, legal precedent in XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( XXXX XXXX XXXXXXXX XXXX XXXX XXXX  ) ruled that financial institutions must provide verifiable proof when restricting financial access. 


I am demanding the following within 10 business days : Full reinstatement of my membership privileges, including eligibility for a debit card and loan products. 
A formal written response confirming the removal of ALL internal restrictions. 
A clear explanation of why my membership remains restricted despite your claim that the restriction was lifted.