Citibank did the following : 1.Citibank profited by defaulting on workout plan [ Profits by Default ] & sale to debt buyer. 
2.Fraud in Execution as Willful misrepresentation to Consumer of Work-out plan terms & risks creating financial benefit Citibank [ Profits by Default ]. Willfully & systematically created misleading representations of payment terms & attendant high probability of consumer default by risk of missed payments not caused by Consumer. 
Citibank used systematic misrepresentation on both Consumer Account ( XXXX XXXX XXXX ) XXXX & on Consumer Spouse Citibank Account ( Sears ). See [ Sears Dispute ] of Citibank response to CFPB Case # XXXX. 
3.Committed " Fraud in Execution '' in work-out plan design : Citibank set Consumer up to fail by systematic design of consumer assistance plans including : 1 ) knowing but not disclosing risks to Consumer of ACH or Bank-caused errors in required auto-draft payments that would be counted as a missed payment by Consumer, 2 ) violated FDIC AMG ( Account Management Guidance ) workout plan directives [ FDIC AMG ] by not defining key term " missed payments '' and not providing means to cure any missed payments, 3 ) Violating AMG by falsely stating in XXXX XXXX, XXXX Letter to define work-out plan that Consumer Account could not be re-aged & refusing to do so when auto-draft payment was disrupted by XXXX XXXX on Consumer checking. 
4.Knowingly caused High probability of default due to ACH or Bank errors alone or with a Consumer error to cause Workout plan default -- & it worked! XXXX XXXX did not pay XXXX XXXX auto-draft to Citibank for Account - without telling Consumer. [ XXXX XXXX XXXX ] XXXX XXXX 's action caused a missed payment -cured by Consumer - but used nonetheless as key to Citibank falsely claiming default on Account. XXXX XXXX caused same problem in same month for Spouse Citibank/Sears work-out plan. XXXX XXXX secret policy change on auto-drafts was combined by Citibank with one missed payment by Consumer on Account XXXX ( due to a family death & its costs ) to unlawfully cancel workout plan. 
The XXXX ACH achieved error rate on false debit entries was XXXX, with an allowed rate of XXXX [ XXXX ACH error ]. The XXXX ACH payments error rate was XXXX ( XXXX ACH errors ) Suppose Consumer is accurate at 98 % rate. Suppose Consumer Bank is accurate at ACH rate. This creates a probability across XXXX payments of all three actors ( assuming independence of events ) not making two missed payments across XXXX payments of about 19 % -- so Citibank makes loan assistance plans a Casino game - with winning odds for Citibank! Unlawful set-up & cancelling of consumer work-out plans across millions of credit accounts disposed of would benefit Citibank, among other ways, by falsely reducing reserves requirements ( Profits by Default ; Citibank reduces Reserves Requirements ) 5.Refused to investigate written Consumer complaint & re-age Consumer Work-out plan despite multiple complaints by Consumer to Citibank about wrongful work-out plan termination and written dispute by fax on XXXX, XXXX, XXXX. ( Fax Complaint ). See same tactics on Spouse Account ( Sears Dispute ) 6.Citibank used Deceptive Practice to breach contract. On or about XXXX XXXX, XXXX Consumer receives Citibank Letter dated XXXX XXXX, XXXX, with misleading information saying Consumer could cure missed payment. Time to cure was not defined with effect of defrauding Consumer. 
XXXX Dealing enabled Citibank to default by offering, then reneged on, cure of item 5. On or about XXXX XXXX, XXXX Consumer received Citibank letter dated XXXX XXXX, XXXX arbitrarily cancelling workout plan by denying time to cure as received in post day before. 
8.Citibank benefited by unlawful sale of Account XXXX to alleged buyer CACH/SquareTwo as " covered person '' with false information in same time frame & similar manner as noted in CFPB Citibank Order XXXX XXXX XXXX.