Consumer complaint received 2022-01-03
Company: SYNCHRONY FINANCIAL
State: SC
Product: Credit card or prepaid card
Sub-product: Store credit card
Issue: Problem when making payments
Sub-issue: Problem during payment process

Complaint:
Synchrony Bank ( SB ), issues, underwrites and services a branded merchant card : LOWES ADVANTAGE CREDIT CARD ACCOUNT. 

Background : I have a closed-end revolving credit card for XXXX XXXX XXXX which was issued and is serviced by SB. 
{$5000.00} credit limit. Account in good standing ( 0x30, 0x60 etc ), over 25 months old ( XX/XX/XXXX - present ) ; {$1200.00} balance outstanding. The last telephone bill payment { I.e., electronic payment } was made few days late on XX/XX/XXXX - an oversight. On XX/XX/XXXX, my credit card was denied for a {$2800.00} refrigerator ( 2 attempts by associate ). 

On XX/XX/XXXX, subsequent to that denial, missing a sale price, and unable to complete my purchase, I called SB and spoke to their customer service representative, XXXX, she confirmed that my XX/XX/XXXX, payment reflects in process that I need to wait 24-hours. 
So SB is suspending the entire available credit limit of the account, in this case {$3700.00}, until they receive the funds which, here amounted to {$110.00} for a first time few-days late payment!!! Thats an absolute UDAAP breach. 

Also, this practice is in direct contravention to regulation Z ( XXXX Payments ; staff interpretations section 2 ) and their own poorly-worded, threatening and deceptive credit card account agreement. And the card application explicitly threatens that crediting non-electronic payments could be delayed of up to five days.

1 ) From application : See item # 2 of the IMPORTANT TERMS FOR ELECTRONIC STATEMENTS : Payment Information. When you elect to stop paper. Please note, if you do not pay us electronically, the crediting of your payment may be delayed by up to five days after receipt.

2 ) Regulation Z ( XXXX Payments ; { a } { Official interpretation of 10 ( a ) General Rule ( 2 ) : II ) Date of receipt. The date of receipt is the date that the payment instrument or other means of completing the payment reaches the creditor. For example : Payment by check is received when the creditor gets it, not when the funds are collected. 

3 ) from SECTION III : STANDARD PROVISIONS of their LOWES ADVANTAGE CREDIT CARD ACCOUNT AGREEMENT HOW AND WHEN TO MAKE PAYMENTS When Payments Are Due. You must pay at least the total minimum payment due on your account by XXXX XXXX. ( ET ) on the due date of each billing cycle. Payments received after XXXX XXXX. ( ET ) will be credited as of the next day. ( THEY ARE NOT PRACTICING THIS ) ..We may delay making credit available on your account in the amount of your payment ( THEY ARE NOT PRACTICING THIS ) even though we will credit your payment when we receive it. ( THEY ARE NOT PRACTICING THIS ). 

So Ive clearly demonstrated with my little account example at least three major non-compliant acts, processes and practices ongoing at SB! 

Id like to know what the CFBP and all the other applicable regulatory and supervisory offices will do to stop this brazen, corrupt and abusive practices, but SB is running a rodeo. 

Deceptive, unfair, abusive practices -and my account was never x30, x60 ; I can only imagine the suffering that results from these abusive practices they freely and proudly employ on their customers ( elderly and perhaps other protected classes ).

Reg Z violation for how and when they actually ( delay and stall ) crediting payments to accounts. How all the extra time contributes to pad interest fee charges across a multi-billion dollar portfolio would be interesting to add up?? 
Then force them to return it all. 

And last but not least, they are actively violating the Fair Credit Reporting Act ( FCRA ). 

From the Important information about your account section, see the following, which omits at least ( 10 ) ten requirements/disclosures under FCRAE.g., right to free copy, right to dispute, timeframes, how to contact each credit bureau, full address, phone number etc, hmmm do they have any substantiative Red Flag Program, do they measure how effective they clear identity theft alerts, and that performance evaluated against any documented requirements, standards, policies? 

Credit Bureau Reporting. We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be shown in your credit report. Tell us if you think we reported wrong information about you to a credit bureau. Write to us at XXXX XXXX XXXX, XXXX, FL XXXX. Tell us what information is wrong and why you think it is wrong. If you have a copy of the credit report that includes the wrong information, send us a copy. 


Their governing agreements fail to define the following key terms : Payment received- Payment in process- Payment credited- When each form of payment is received by SB ( ach, check, electronic payment etc ) When, how and based on what specific account characteristics will SB suspend every available penny versus what their agreement describes, just the equivalent amount of the minimum payment amount due?

How are all of these high-risk processes measured?

I hope the regulators seriously perform their duty-bound due diligence at SB ; there simply isnt any tolerance for thisfrom a shoe store, let alone a financial center.

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation