Product: Payday loan, title loan, personal loan, or advance loan

AFFIDAVIT OF COMPLAINT STATE OF NEW YORK COUNTY OF KINGS I, XXXX XXXX, being duly sworn, depose and state as follows : 1. I am of legal age and competent to make this affidavit. I have personal knowledge of the facts stated herein. 

2. I filed an application with Optum Temporary Funding Assistance for their financial assistance program. Optum processed my application but ultimately issued me no value or funding.

3. Since that time, Optum has engaged in several questionable actions, including : a. Fabricating false and misleading statements in their response to the Consumer Financial Protection Bureau ( CFPB ) regarding my application, in violation of the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., and the Federal Trade Commission Act ( FTC Act ), 15 U.S.C. 41 et seq.

b. Egregiously violating my rights under applicable laws, including the FCRA, the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692 et seq., the Truth in Lending Act ( TILA ), 15 U.S.C. 1601 et seq., and the Code of Federal Regulations ( CFR ), Title 12, Part 1022 ( Regulation V ).

c. Failing to lawfully provide me with a copy of their prospectus report, as required by the Uniform Commercial Code ( UCC ), Article 9, and the United States Code ( USC ), Title 15, Chapter 41.

d. Failing to return my application security deposit, despite my repeated written demands and verbal requests, in violation of the UCC and USC.

e. Providing no written information or explanation as to the denial of my account application, as required by the FCRA and TILA.

f. Falsely claiming they do not accept my billing method, while accepting the same billing method from other applicants, in an act of discrimination against my medical condition.

g. Engaging in a company-organized effort to deny my lawful requests, hide their actions against me, and evade communication with me, in violation of the FDCPA and the Privacy Act of 1974, 5 U.S.C. 552a.

4. Optum 's actions have caused me significant distress and adversely impacted my financial well-being. I have made numerous attempts to resolve this matter directly with Optum, but they have continued to disregard my rights and engage in unlawful conduct.

5. I am therefore filing this formal affidavit of complaint with the Consumer Financial Protection Bureau ( CFPB ) to request a thorough investigation into Optum 's actions and the following remedies : a. A full accounting and return of my application security deposit, as required by the UCC and USC.

b. Compensation for the harm caused by Optum 's unlawful actions, including any fees or penalties allowed by the FCRA, FDCPA, TILA, and other applicable laws.

c. Correction of any negative information reported to consumer reporting agencies, as required by the FCRA.

d. A cease and desist order to prohibit Optum from further violations of my rights, as allowed by the FDCPA and the Privacy Act of 1974.

e. Any other relief deemed appropriate by the CFPB to address Optum 's egregious conduct and ensure compliance with all applicable laws.

I swear under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief.

( This has no impact on current rental agreement with Optum Temporary funding Assistance ) Sincerely, XXXX XXXX