Consumer complaint received 2020-10-25
Company: CITIBANK, N.A.
State: TX
Product: Credit card or prepaid card
Sub-product: General-purpose credit card or charge card
Issue: Problem with a purchase shown on your statement
Sub-issue: Credit card company isn't resolving a dispute about a purchase on your statement

Complaint:
I previously attempted to notify CITI via the CFPB of various violations and errors of federal and state statutes, the cardmember agreement, and the MasterCard Dispute Resolution Guide. The vast majority of the complaints and issues brought forth were ignored, however, as were all of the supporting documents I provided. To prevent this from occurring again, I will break the complaints up into smaller sections so as they can be individually addressed instead of being ignored. 

Recently the XXXX actions were based on CITIs unsafe or unsound banking practices and for its long-standing failure to establish effective risk management and data governance programs and internal controls. This failure also resulted in a violation of 12 CFR Part 30, Appendix D, OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches. The agency also issued a cease and desist order requiring the bank to take broad and comprehensive corrective actions to improve risk management, data governance, and internal controls. 
Additionally, since the year XXXX total penalties assessed to Citi are {>= $1,000,000} based on 120 recorded violations. This history of violations has become very well known and may explain why the vast majority of my complaints and issues raised for the most part are ignored and lack adequate responses or correction action which CITI is legally obligated to. 
Additionally, you should already be aware I am covered under the Military Lending Act, which provides additional consumer protections to me while placing additional legal requirements upon CITI. This includes additional notices and documents CITI must provide, as well as the additional timeline which CITI must abide. 

As previously mentioned, XXXX or the Fair Credit Billing Act ( FCBA ) protects consumers from unfair or prejudicial billing practices. This federal law allows credit cardholders a method to dispute incorrect credit card billings. If one follows the correct procedure, the cardholder can dispute the charges and temporarily withhold payments on the disputed amount without affecting ones credit score. Per FCBA, I initiated and notified Citi of multiple billing errors in XXXX. The FCBA also states Citi must acknowledge my complaints, in writing, within 30 days after receiving it. The dispute must be resolved within two billing cycles. If a billing error occurred as notified, Citi is required to explain in writing the corrections that will be made. In addition to crediting my account, Citi must remove all finance charges, late fees, or other charges related to the error. If Citis investigation determines the bill is correct, I must be told promptly notified how much I owe, why, and provide the relevant investigation documents. 
After being notified of several billing disputes CITI has routinely failed to investigate or provide the required notifications in writing as required by FCBA regulations. I am currently signed up for paperless documents through Citi online, where all my statements, notices, and documents are sent. I have made multiple calls to Citi, notifying them I am not receiving any documents as required. Most recently, on XX/XX/XXXX I spent several hours on the phone with several CITI agents, including the IT department. Your IT department verified, while I was signed up and enrolled for paperless documents I was not receiving any notices or documents at all. I made this known on at least a dozen prior conversations, as well as in multiple CFPB complaints and notices of billing disputes submitted in writing. While CITI is fully aware of this issue CITI has failed to adequately address or correct this repeated violation. This only continues to add to the growing list of FCBA violations. 

CITI also routinely fails to properly review provided documents regarding billing disputes or investigate these disputes as required. More often than not, CITIs claims and responses are further examples of their unfair, deceptive, or abusive acts ( UDAAP ). UDAAPs are illegal, according to the Dodd-Frank Wall Street Reform and Consumer Protection Act. While the examples are extensive some of the more flagrant deceptive statements made by CITI are as follows : We are unable to assist you with your dispute since you accepted and used these services with the knowledge they were not what you originally agreed upon. Please contact the merchant if you wish to pursue this matter further. 
Under FCBPA federal statutes Citi is obligated to adequately process and follow any billing errors or disputes you are notified of. Your suggestion that because I accepted and used the services has no bearing on my rights to dispute this charge. The requirements to dispute a charge as outlined in the MasterCard Dispute Resolution Guide include the following : The merchant did not honor the terms and conditions of the contract with the cardholder including, but not limited to, 100 percent money-back guarantee, written promises, or return policy. 

We needed a copy of the receipt, invoice or sales slip that shows you should have been billed a different amount. Any further attempts to resolve this dispute will need to be directed to the merchant or another form of resolution. 
Statements such as these are extremely deceptive when CITI was already in receipt of extensive documentation including my original reservation, terms of service agreed to with the merchant, photographic evidence, etc. The required supporting documentation required according to the MasterCard Dispute Resolution Agreement is : Cardholder email, letter, message, or completed Dispute Resolution Form Cardholder Dispute Chargeback ( Form XXXX ) describing the cardholder 's complaint in sufficient detail to enable all parties to understand the dispute. 
When the cardholder is a corporate entity with a contractual relationship with the merchant and the transaction is for an amount over what is specified in the contract, the contract must be provided when the merchant wasn't contacted to resolve the dispute. 
Optionally, documentation from an expert or professional that supports the cardholder 's dispute about the level of quality or misrepresentation. 
Optionally, documentation that supports the cardholder 's dispute including, but not limited to, the original receipt, invoice, work order, brochure, contract, or appraisal. 

Citis deceptive and abusive statements and actions, refusal to comply with contractual obligations, and FCBA, MLA, and UDAAP violations have amounted to improperly handled billing disputes totaling {$4400.00} in XXXX alone charged to my account.

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