XXXX XXXX I purchased XXXX {$500.00} XXXX XXXX XXXX reloadable prepaid cards ( {$3.00} activation fee ) from XXXX. These cards are provided by InComm. The cards were activated and loaded. 

I did not attempt to load the cards into my account until XXXX XXXX, finding the funds of the first card had been removed. I immediately called the number on the back of the card ( InComm ) and scratched off the material to reveal the PIN while on the phone with their representative, to find the money removed as well. 

The cards have only ever been at my home and the XXXX XXXX sheriff 's office. I am the person who scratched the material off to reveal the PIN. I am a long time XXXX and XXXX user, technically savvy, with a degree XXXX. I work XXXX. I have a history of usage of these cards in my account to demonstrate my usage and knowledge about them. 

I am the victim of some type of fraud where it appears access was gained to my PIN. This could have been low tech ( tampering with the card ) to medium ( rogue employee at InComm with access to information ) to more sophisticated ( breach of InComm data. ) InComm 's position per XXXX XXXX ( XXXXXXXXXXXX ) is that because the money was loaded to many accounts, that this is an indicator that I got scammed and gave someone my PIN, and that InComm is not liable for making me whole because of this. 

I agree that that activity is suspicious and indicative of fraud and money laundering techniques designed to make the money hard to track and retrieve. It is likely that the money is gone and that compromised accounts were used as first line recipients of the money. I believe tracking down the criminals is unlikely to result in recovery of money or finding the perpetrators and believe this to be a criminal matter whose responsibility for further investigation is InComm 's. 

Although this suspicious activity is indicative of fraud, it provides no indication as to how the PIN was obtained to access money, nor indicative of any fault of mine as a cardholder. Furthermore, credit cards have XXXX nightly batch as well as in now real time are able to hold transactions as suspicious behavior is encountered. If InComm has discovered a pattern of suspicious activity, they can implement similar measures to protect their cardholders. However they have been negligent in doing so. Their position on this matter is not based on data that supports it, but on it being a conclusion they want to reach because they do not perceive themselves to be liable if a cardholder provided a PIN. 

I loaded this money into the card with the expectation that it would be safe. InComm has been negligent in XXXX making me whole as well as making a real effort to protect cardholders, with a culture of blaming the victim rather than improving their product. This can be seen in other examples of similar products they sell as well as this particular product. XXXX XXXX CASE # : XXXX, XXXX XXXX ) I have been in contact with the company privately but thus far they have refused to provide any relief. I am the victim of fraud and an unauthorized financial transfer from my account due to InComm 's negligence in both preventing and resolving fraud. 

Furthermore, I also believe this error resolution to be in violation of Regulation E - Electronic Fund Transfer Act. Per Subpart A, V. Consumer Liability and Error Resolution ( XXXX CFR XXXX, XXXX ) I believe InComm is in non-compliance with the federal regulation and has not attempted to follow any error resolution procedures. I have also found victims similar to myself who are in the same situation.