Consumer complaint received 2017-05-23
Company: UNITED SERVICES AUTOMOBILE ASSOCIATION
State: VA
Product: Payday loan, title loan, or personal loan
Sub-product: Personal line of credit
Issue: Getting a line of credit

Complaint:
On Saturday,  XX/XX/XXXX  I spoke with  XXXX ,  USAA  representative  ( USAA rep ) to apply for a {$20000.00} debt consolidation loan. The USAA rep explained that USAA does not offer debt consolidation loans, but instead just a loan, which I may disburse to my creditors at my discretion. My response was I wanted to move forward and apply for {$20000.00} loan. Although I have never been offered or applied for a consumer loan with USAA, I am an established insurance customer of USAA for several years. I started out   insuring  XXXX  vehicle and I now have  XXXX  vehicles and  XXXX  family members under my policy. My  XXXX  product was the secured USAA  XXXX   XXXX  Card to help re-build my credit which I was able to deposit the maximum {$5000.00} and after several years, I closed the accou nt for two  reasons 1 ) I was declined for an unsecured USAA  XXXX   XXXX  Card-after being approved for a Platinum Card by  XXXX   XXXX  2 ) because my credit had been established well enough to be approved for generous amounts of credit by multiple entities including a  USAA Visa  which was the lowest amount of {$5000.00} until a few months ago I asked for an increase and is now {$15000.00} ( which lags behind other lending institutions ). In addition to access to unsecured bank credit cards, high end department store cards, and personal loans from  XXXX  credit unions, car purchases/leases, and last but not least I qualified for a VA  Jumbo Home Loan  for {$670000.00} which I began to build in  XX/XX/XXXX  and closed  XX/XX/XXXX  which is solely in my name. Also, seemingly going through the grueling process of purchasing a home and verifying income and providing supporting documentation from the IRS, bank statements, employment verificatio n, 100 percen t on time payment history on all accounts for many years, and etc. Which all speaks volumes to my employment history, credit worthiness, stability, and income model. However, I sensed that after I stated my annual access income is {$250000.00} and the tonality and posturing in the USAA reps voice began to change and become condescending and the profiling began as if it was a ridiculous amount of money for someone like me (  XXXX   XXXX   Woman ) to  have access too. The  USAA  rep began to demonstrate implicit bias and by the time she ran my credit, placed me on hold, and came back to the phone it was full-blown explicit bias that I felt, which is properly termed in this incident as disparate treatment which induced disparate impact. So, I then broke the income down for her and explained that my income is {$150000.00} per year and the income that I have access from my husband is {$8300.00} per month, which is {$100000.00} per year for a total of {$250000.00} per year.  USAA  rep went on to discourage me from using my husbands income because Id stated this would be an individual application, not a joint application. It was then stated that if the {$8300.00} was alimony or child support I could use it, but since it was my husband it had to be a joint application. Sounds like Im being penalized for having a husband and not an ex-husband-discrimination based on marital status. I began to explain to USAA rep that the stated income has been used on all of my credit applications and lending institutions from car buying/leasing, to credit cards, and consumer loans from other banking institutions without fail and most recently as a compensating factor for home purchase. The only lender that Ive had to verify income was for building/purchasing a home in  XX/XX/XXXX , increments during that time and right before closing recently in  XX/XX/XXXX .  USAA  rep stated that the application would need to be reviewed by the Underwriter which came back requiring income verification with  XXXX  recent pay check stubs. My response was thats not a problem, but why? My credit application/report supports my income model, and my stated income. I also asked if  USAA  required all applicants to submit these documents for consumer loans because nothing was ever mentioned about my  credit score, credit worthiness, or the fact that I had again paid off over {$8000.00} on my USAA credit card just days prior to the loan request which they held the check    for seven ( 7 ) busi ness days endorsed by my credit union. There is a disparate treatment which is causing disparate impact based on my race, sex, and marital status. I asked to speak with the Underwriter, but I was told there was onl y one of   duty for the day. Then I asked for my call to be escalated to a USAA supervisor, and thats when  XXXX  announced herself and she began to explain that USAA is a conservative lender and there are triggers as to whom to ask for verifiable information because the bank wants to protect itself from fraud. I explained to her that this level of conservativeness is beginning to look more like discrimination. She went on to give the disclaimer that USAA does not discriminate based on race, religion, etc. I told her shes paid to say that, but just like  XXXX   XXXX ,  XXXX   XXXX   XXXX ,  XXXX , and so many other institutions, they were still found to be in violation of the fair lending practices. By now, Im sure I am a victim of  USAA  by means of comparative evidence of disparate treatment and disparate impact requiring additional documentation that is required for triggers. USAA please define triggers as to be sure not to discriminate certain groups of people from the standard for fair lending practices without exceptions or discretion of reps and underwriters profiling deserving applicants. I wanted to know if USAA is conducting lending practices with a different set of rules beyond Equal Credit Opportunity Act (  ECOA  ), abiding by Consumer Financial Protection Bureau ( cfpb ). Since that time I have receive d two mailings, one  dated  XX/XX/XXXX  stating that before they can make a decision on my application I need to submit  XXXX  Most Recent Paystubs with  XXXX  Most Recent  XXXX  Form, this is more than what was initially asked for during the phone call, which further lets me know that USAA is guilty of Disparate Treatment and Impact which explicit discrimination. Since when does someone submit  XXXX  forms for a consumer loan? The second letter dated  XX/XX/XXXX  signed by  XXXX   XXXX , Vice President, Loan Experiences,  USAA Federal Savings  Bank states Notice of Decision for {$20000.00} Consumer Loan was not approved because Insufficient or lack of income. If there was true justification for closing the loan, it should have been for incomplete application or an issue with my  credit score   XXXX  ( which declined since I purchased home ), or additional information required. Overall, the consumer loan application process with USAA rep, Underwriter, and  Supervisor  left a lot to be desired. It appears that USAA has no problem with me paying them insurance money and paying high interest on their credit cards, but there is disparity in loaning money to deserving customers all while using the money that is paid to them for their conservative loan applicants. My credit profile is a testament to my discipline, hard work, stability, and efforts to obtain and maintain the  American Dream,  but institutions that continue to redline  XXXX   XXXX  is the core reason there is disconnect with achieving these very things. If anything, USAA needs to be courting me with various products to increase my portfolio with their services.

Company public response: Company believes it acted appropriately as authorized by contract or law
Company response to consumer: Closed with explanation