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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

VIVEK SHAH,

Plaintiff,

v. Civil Action No.__________________

JPMORGAN CHASE BANK, N.A.,

Defendant.

VERIFIED COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF AND 

DAMAGES

JURY DEMANDED

PRELIMINARY STATEMENT

1. J.P. Morgan Chase, N.A. (“Chase”) is a convicted felon. So is Plaintiff Vivek 

Shah. Yet, Chase categorically discriminates felons from opening and maintaining any of its 

checking or credit accounts. It maintains and enforces a policy of automatically excluding any 

person with a record of a felony conviction and certain other types of criminal history from 

accessing its checking and credit products. Plaintiff, proceeding pro se, brings this suit against 

Defendant under the Equal Credit Opportunity Act (ECOA), 15 U.S.C. § 1691 et seq., 

Regulation B promulgated thereunder, 12 C.F.R. § 1002, and the civil remedies provided in the 

Racketeering Influenced and Corrupt Organizations (RICO), 18 U.S.C. § 1961 et seq. to (1) 

prevent Defendant from continuing its discriminatory and unlawful conduct against Plaintiff and 

those similarly situation, and to ensure that Plaintiff and others injured by the anti-felon policy –

who are disproportionately of color – will have a meaningful opportunity to have access to 

essential banking services, and (2) redress the harm Plaintiff has suffered as a direct result of 

Defendant’s conduct.

RECEIVED 6/8/2020

THOMAS G. BRUTON CLERK, U.S. DISTRICT COURT

20CV3355

JUDGE FEINERMAN

MAGISTRATE JUDGE KIM

FILED 6/9/2020

THOMAS G. BRUTON CLERK, U.S. DISTRICT COURT
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2. The anti-felon policy and practice’s disproportionate, adverse impact on people of 

color violates the Equal Credit Opportunity Act. There is a readily available and less 

discriminatory alternative to an automatic blanket ban on felonies and other criminal histories for 

dealing with any potential concerns about applicants with a criminal record. Instead of 

automatically excluding every applicant within the scope of its policy, Defendants can and are 

legally required to individually assess potential applicants with a felony or other covered 

criminal history by considering factors directly relevant to the prospective applicant’s credit 

history. Individualized assessments would permit Defendant to carefully review the credit history 

of applicants that would also permit prospective applicants who have a criminal record, but who 

pose no threat to the bank to obtain credit.

3. Defendant’s decision to maintain a far-reaching blanket ban, despite various 

industries’ rejection of such bans due to their discriminatory impact, indicates that this policy not 

only has an unlawful disparate impact, but was motivated by an intent to block people who are of 

color from obtaining credit.

4. Defendant’s discriminatory policy and practices directly prevent individuals like 

Plaintiff who are reentering society after time in prison from securing any tangible thing of 

value, whether it is housing, medical supplies or clothing, that is crucial to their successful 

reintegration. Defendant’s policy also impacts individuals with a prior conviction long after an 

individual has successfully reentered the community.

NATURE OF THE ACTION

5. Plaintiff seeks injunctive, monetary, and declaratory relief against Defendant for 

engaging in a practice of illegal discrimination on the basis of color at the banks that Defendant 

owns and operates.
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6. An applicant who has a criminal history within the scope of Defendant’s policy is 

automatically barred regardless of the nature of the conviction, the amount of time that has 

lapsed since the conviction, evidence of rehabilitation, prior credit or banking history, or any 

other factor related to whether the person poses a threat to Defendant’s business. As a result, an 

elderly person with a decades-old drug conviction is treated identically to a person with a very 

recent violent conviction: both are barred without further review.

7. As a direct result, applicants with a criminal record are either (1) deterred from 

ever applying to Defendant’s credit products since it would lower their credit score with the 

credit bureaus; or (2) automatically denied because of the anti-felon policy.

8. Analysis of criminal records and other data shows that the Defendant’s policy, 

though facially neutral, has a severe disparate impact on the basis of color. Today, people of 

color make up around 23% of the U.S. population. Yet, they account for approximately 40% of 

all convicted felons in the U.S. About 70 million Americans have a criminal record.

9. The State of Illinois has a population of 12.7 million people, consisting of 61% 

Whites and 39% people of color. 

10. In Cook County, Illinois, 42% of the residents are White, but account for only 

10% of all persons that have received a criminal sentence in the county.

11. An analysis of the 297 DNA exonerations revealed that people of color make up 

approximately 70% of those proven innocent through DNA testing. People of color are 7 times 

more likely to be wrongfully convicted or murder than White people. People of color serving 

time for sexual assault is 3.5 times more likely to be innocent than a White sexual assault

convict. Innocent people of color are 12 times more likely to be convicted of drug possession 

than innocent White people.
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12. 90% of Defendant’s Board of Directors are White. 100% of the Defendant’s 

Operating Committee is White.

13. The Equal Credit Opportunity Act prohibits the application of any policy or 

practice that has a disparate impact unless it is necessary to achieve a substantial, legitimate, 

nondiscriminatory business interest that cannot be satisfied by an alternative that has a less 

discriminatory effect.

14. Defendant’s policy and practice is not necessary to achieve a substantial,

legitimate, nondiscriminatory business interest. A less discriminatory alternative for dealing with 

any potential concerns raised by applicants with criminal records is available to Defendant.

15. Instead of automatically excluding every applicant covered by their far-reaching 

policy and practice, Defendant should individually assess an applicant with a criminal history by 

considering factors directly relevant to the applicant’s qualifications for credit such as the nature 

of the conviction or conduct, when it occurred, their age at the time the conduct occurred, their 

post-conviction and post-release conduct, evidence of their rehabilitation, evidence of whether 

their credit approval would create a direct threat to Defendant’s business, their credit history, and 

other relevant factors. When considered in their totality, such an individualized assessment 

enables a creditor to make a reasoned decision about a particular applicant’s suitability for credit 

approval.

16. The more tailored approach required by an individual assessment protects 

financial and business interests of Defendant, yet it is less discriminatory and exclusionary 

because it reduces the number of colored people who are categorically barred from being 

extended credit.
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17. Plaintiff brings this action to address Defendant’s discriminatory and unlawful 

conduct and to redress the harm he has suffered and will continue to suffer as a direct result of 

that conduct, absent relief.

PARTIES

18. Plaintiff Vivek Shah is a natural-born U.S. citizen. He is a non-White male. In 

August 2012 he was arrested by the FBI for attempting to extort money from several individuals. 

He was sentenced in the Southern District of West Virginia to 87 months in prison. On February 

4, 2019 he was released from prison, and on February 4, 2020 his supervision was terminated by 

Honorable Jorge L. Alonso of this Court.

19. Defendant JPMorgan Chase, N.A. is an American multinational investment bank 

and financial services holding company headquartered in New York, NY. JPMorgan Chase is 

ranked by S&P Global as the largest bank in the United States and the sixth largest bank in the 

world by total assets of US$2.687 trillion.

20. In January 2017 Defendant plead guilty in the District of Connecticut to one 

felony count of conspiring to manipulate the price of U.S. dollars and euros exchanged in the 

foreign currency exchange (FX) spot market, in violation of 15 U.S.C. § 1. Defendant was placed 

on a 3-year term of probation and $550 million in fines. Presumably, its term of probation 

expired in January 2020.

21. Prior to Defendant’s 2017 conviction, it entered into a nolle prosequi agreement 

with the United States for a $1.7 billion penalty stemming from two felony violations of the 

Bank Secrecy Act.
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22. In acting or omitting to act as alleged herein, Defendant was acting through its 

employees and/or agents and is liable on the basis of the acts and omissions of its employees 

and/or agents.

23. In acting or omitting to act as alleged herein, each employee, officer or agent of 

Defendant was acting in the course and scope of his or her actual or apparent authority pursuant 

to such agencies, or the alleged acts or omissions of each employee or officer as agent were 

subsequently ratified and adopted by Defendant as principal.

JURISDICTION AND VENUE

24. This Court has jurisdiction over this matter under 15 U.S.C. § 1691e, 18 U.S.C. 

§ 1964, and 28 U.S.C. § 1343. 

25. This Court has authority to grant declaratory and injunctive relief under 28 U.S.C. 

§§ 2201 and 2202 and Rule 57 of the Fed. Rules of Civ. P.

26. Venue is proper in this district under 28 U.S.C. § 1391(b) because Defendant is a 

national bank that is chartered and supervised by the Office of the Comptroller of the Currency, 

an agency in the U.S. Treasury Department, pursuant to the National Bank Act. Defendant has 

bank branches throughout the Northern District of Illinois where Plaintiff has transacted with 

Defendant. Plaintiff is a resident of Schaumburg, IL. A substantial part of the events and 

omissions giving rise to the claims occurred in this district.

FACTUAL BACKGROUND

I. Defendant’s Conduct Leading to the Instant Suit

27. In or around the year 2004, Plaintiff opened a Checking Account (“First 

Account”) at a Washington Mutual bank in Schaumburg, IL. In or around 2008, Defendant 
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Chase bank purchased and rebranded Washington Mutual to Chase. Plaintiff’s First Account was 

therefore converted to a Chase checking account.

28. In or around the year 2010, Plaintiff applied for and was approved for a Chase 

Sapphire Preferred Credit Card (“Sapphire Card”).

29. On August 10, 2012, Plaintiff was arrested by the FBI on allegations that he 

attempted to extort money from several individuals. None of Plaintiff’s conduct or allegations 

related to any of his banking relationship with Chase. At that time, the First Account had a 

deposit balance of approximately $261. Additionally, the Sapphire Card did not have any 

balance due.

30. In or around October 2012, while in jail awaiting trial, Plaintiff provided his 

father a handwritten, notarized power of attorney (“POA”), that mentioned, inter alia, that he 

was in jail and could not manage his accounts personally at the moment. The POA provided his 

father with broad powers to take any action on Plaintiff’s accounts related to the First Account 

and the Chase Sapphire Credit Card.

31. In or around October 2012, Plaintiff’s father walked into a Chase bank branch 

with the notarized POA. Plaintiff has no further knowledge of what transpired at the bank

branch.

32. In or around September 2013, Chase closed both the First Account and Sapphire 

Card.

33. In or around February 2019, Plaintiff walked into a Chase bank branch in 

Schaumburg, IL upon discovering an unclaimed property with the California State Controller. A 

female employee of the branch assisted Plaintiff with having a $261 check re-issued to him. The 

employee stated to Plaintiff that the $261 amount was the leftover balance from the First 
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Account upon closure of that account. Plaintiff asked the employee for the reason why it was 

closed, to which she stated that there was no particular reason stated other than a note that read 

that Plaintiff was not to be allowed to open any account with Chase.

34. In or around October 2019, Plaintiff was added as an Authorized User to the 

following credit cards issued by Chase:

a. United Explore MileagePlus, with the primary account holder being his father

b. British Airways, with the primary account holder being his mother

c. Sapphire, with the primary account holder being his brother

35. On or around February 1, 2020, Plaintiff applied with Chase for a credit card 

(“Chase Credit Card”) which was later denied under the guise that he had insufficient credit 

history. The denial was made despite Plaintiff having substantial credit history and a FICO score

of around 740 at the time of application.

36. On or around February 4, 2020, Plaintiff successfully opened a Business 

Checking Account under his own name at Chase. 

37. On or around April 4, 2020, Plaintiff applied for a Paycheck Protection Program 

(“PPP”) loan under the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) 

with Chase.

38. On or around April 17, 2020, Chase issued a letter to Plaintiff denying his PPP 

loan request, stating: “After a recent review of your accounts, we have decided to end our

relationship with you.”

39. On or around April 17, 2020, Chase issued a letter to Plaintiff’s father, mother, 

and brother stating that it has closed the cards that were issued to Plaintiff as an Authorized User. 

It did not provide any reason whatsoever as to why the cards were terminated.
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40. On or around April 20, 2020, Plaintiff applied for and was approved for an 

Amazon Prime Rewards Visa Signature Card (“Amazon Card”) that was issued by Chase. The 

Amazon Card was approved after Chase had pulled his credit history reports from Experian and 

Transunion.

41. On or around April 21, 2020, Chase issued a letter to Plaintiff regarding his 

Business Checking Account, which stated: “After a recent review of your account, we have 

decided to end our relationship with you.”

42. On or around June 1, 2020, Chase closed Plaintiff’s Amazon Card under the guise 

that:1) there was a “rapid increase in revolving balances” and 2) there were “too many requests 

for credit or reviews of credit.” Chase issued the letter despite the Amazon Card balance being 

paid in full on or before its due date, and Chase having no new information/credit-pull from 

which it could have determined that there were too many requests/review of credit. In fact, 

Plaintiff has on occasion even made overpayments of the balance due and thus has had a negative 

Amazon Card balance. Plaintiff requested Defendant to reconsider and reinstate the Amazon 

Card.

43. On June 4, 2020, Chase issued a letter denying reinstatement of the Amazon Card, 

yet again, under the same guise that: 1) there was a “rapid increase in revolving balances” and 2) 

there were “too many requests for credit or reviews of credit.” In fact, on June 4, 2020, the 

Amazon Card had a current balance of negative $85.81. In the history of the Amazon Card, 

Plaintiff at most utilized just 16.25% of the approved credit limit. Moreover, Chase did not check 

any of Plaintiff’s credit reports again through which it could glean new information that could 

form the basis of the denial.
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II. Anecdotes from Similarly-Situated Felons

44. In or around 2008, Kirk Radomski, a convicted felon with good credit history, had 

his credit card terminated that was issued to him by Chase, since Chase found out that he was a 

felon.

45. Unnamed Person #1 has a felony conviction stemming from conduct that occurred 

in 2017. In or around March 2020, this person applied for a credit card at Chase, was approved 

for it, but two weeks later received a letter that the account was terminated.

46. Unnamed Person #2 has a felony conviction and opened an account at Chase in or 

around March 2020; however, approximately 10 days later Chase closed the account.

47. Unnamed Person #3, a convicted felon, applied for and was approved for an 

Amazon Visa credit card issued by Chase in or around 2015. Approximately 5 months after its 

issuance and usage, the person received a letter in the mail stating that the Amazon Visa credit 

card was being closed because “continuing our relationship creates possible reputational risk for 

our company.”

48. Unnamed Person #4, a convicted felon, applied for and was approved for a credit 

card issued by Chase in or around 2015. Approximately 6 months after regular use and 

payments, Chase cancelled it. 

III. Defendant’s Policy Prevents Any Applicant with a Criminal Record from Being 

Considered for its Products and Services

49. Defendant practices and has a non-public policy of terminating any and all 

banking relations with any person who it finds out has a felony or other criminal histories. The 

policy and practice even applies to those people that were charged with a felony but were never 

convicted.
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50. Defendant’s policy and practices are an outwardly neutral practice that 

automatically excludes all applicants that have a felony conviction and other criminal histories, 

and even some people who have only been charged with but not convicted of criminal conduct. 

This policy and practice is consistently applied and enforced.

IV. Defendant’s Policy Prevents People with Criminal Records from Obtaining 

Essential Banking Services

51. The harm inflicted by discriminatory criminal records policies like Defendant’s is 

significant, not only in terms of the sheer number of people affected, but also in terms of the 

consequences, for the wellbeing of our communities.

52. When banks categorically discriminate felons, they are left with no more choices 

but to revert back to criminal activity. Companies such Chase never give felons a second chance. 

Thus society ends up paying the price of Chase’s discrimination.

53. Banking services are essential and are a particularly crucial need for individuals 

reentering their communities immediately after time in prison.

54. Research shows that success in opening a bank account and securing credit are 

critically important to allowing reentrants to gain employment, government benefits, and other 

community ties. Successful reintegration is not just a concern for those who return from prison: it 

is also a matter of public safety and economic necessity. Reducing recidivism is critical for 

community safety; providing effective rehabilitation and skill development for those incarcerated 

and formerly incarcerated is critical to strengthening households and the economy. Other 

research has shown reentrants who do not have access to essential banking services are more 

likely to recidivate than those who are able to. Recidivism additionally impacts the whole 

surrounding community.
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55. Automatic criminal history bans directly prevent reentrants from obtaining such 

essential banking services, whether immediately after release from prison or decades later, 

without giving any consideration to the particular circumstances of a person trying to cash a 

check or secure credit to start a legitimate business. Banks such as Chase that make it extremely 

difficult on reentrants to live a law-abiding life, unwittingly push them in the direction of 

recidivism. This complete disregard for individual circumstances cannot be justified under the 

law. Moreover, it needlessly injures formerly incarcerated individuals, their communities, and 

organizations like Plaintiffs that are committed to preserving access to essential necessities of 

life.

56. Defendant’s choice to maintain the overly broad and discriminatory policy and 

practices also reflects a substantial departure from usual industry practices, which raises an 

inference of discriminatory intent. Defendant’s outright rejection of applicants with felony and 

other convictions and arrests is entirely counter to normal business practices in the credit lending 

industry. In the normal course of business, creditors are highly motivated to get people in the 

door to obtain credit. Bank such as Defendant even offer hundreds of dollars of cash and rewards

incentives to people as an introductory bonus. Defendant’s policy and practices instead assures 

that a group of people - disproportionately people of color - has no reason to bank with 

Defendant.

57. Departures like this from industry norms suggest illicit motive.

58. In light of these facts, there is no non-discriminatory explanation for why 

Defendant deliberately choses and continues to implement the policy and practices over an 

individualized screening practice. Rather, these facts collectively support the inference - indeed, 
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they strongly suggest - that Defendant fully understands the unnecessary and unlawful disparate 

impact of its discriminatory impact. 

59. In fact, Jamie Dimon, the Chief Executive Officer of Defendant-company, has 

publicly said that “How we treat felons after they've paid their price is completely unfair.”

V. Defendant’s Policy Disproportionately Affects People of Color and Constitutes 

Unlawful Discrimination

60. Facially neutral credit lending practices that have a disparate impact on the basis 

of color are prohibited under the Equal Credit Opportunity Act unless they are necessary to 

achieve a substantial, legitimate, nondiscriminatory business interest that cannot be served 

through a less discriminatory alternative practice. Policies that automatically deny credit to 

people with records of felony convictions or other criminal history, including Defendant’s policy 

and practices that are maintained and enforced by Defendant, have a severe disparate impact on 

people of color at the national, state, and local levels, and are unlawful under this standard.

61. Because the proportion of people with criminal records in Cook County varies 

widely by skin color, Defendant’s policy and practices bars otherwise-qualified people of color 

from obtaining credit at a rate of close to nine times the rate at which otherwise-qualified Whites 

are excluded. Defendant’s policy and practices are the direct cause of this disparate impact.

62. Defendant’s policy is overbroad and cannot be justified. Protecting the bank’s 

reputation, safety or property is not a valid reason for an automatic ban, as most credit-applicants 

with criminal backgrounds do not pose a more significant risk to creditors than credit-applicants 

without criminal backgrounds. The protection of the reputation of the bank cannot be used to 

justify a policy that categorically banks all people with felonies or other types of criminal history 
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without any attempt to distinguish between past criminal conduct that presents a risk to 

Defendant’s assets or reputation and past criminal conduct that does not.

63. Any legitimate concerns, including protecting safety or property, can be satisfied 

by a readily available and less discriminatory policy: giving individualized consideration to each 

applicant’s circumstances and credit history.

VI. Automatic Credit Bans Based on Criminal History Disproportionately and 

Severely Impacts People of Color Nationally

64. Nationally, more than 625,000 inmates are released from confinement each year, 

and they become targets of automatic criminal history bans at precisely the tie then they need 

credit to reintegrate into society.

65. The sheer number of people released from prison every year has skyrocketed as 

the incarcerated population in the United States has grown from 300,000 in 1980 to more than 

2.3 million today. Most are imprisoned for non-violent offences. Approximately 10 million 

misdemeanor cases are filed each year. Approximately 19 million people across the country have 

at least one felony conviction. At the same time that the sheer number of people with criminal 

convictions has dramatically increased, it has become much easier and more creditors to identify 

and ban people with criminal records because of the digitization of records and the concomitant 

growth of private companies that provide inexpensive background checks.

66. The massive increase in incarceration and in the number of people with criminal 

convictions has had an unequal impact on the non-White community. People of color are 

incarcerated at rates disproportionate to their numbers in the United States general population.
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67. The fact that colored people are far more likely than Whites to have a criminal 

record means that colored people are much more likely than Whites to be barred from credit by 

automatic exclusions of people with criminal records.

68. Race and skin color are closely-related to each other. The Equal Employment 

Opportunity Commission’s (“EEOC”) analysis of the impact of automatic criminal history bans 

in the employment context further confirms the disparate impact described here. The EEOC 

analyzed national criminal records data, concluded that automatic criminal history bans have a 

disparate impact on the basis of race, and documented its findings in its Enforcement Guidance 

on the Consideration of Arrest and Conviction Records in Employment Decisions Under Title 

VII of the Civil Rights Act of 1964 (“Enforcement Guidance”).

69. The EEOC’s conclusion applies to the disparate impact analysis here because 

categorical criminal records bans operate the same way in credit as they do in employment. In 

both contexts, applicants are uniformly and permanently excluded, whether from credit 

opportunities or employment, before due consideration of the merits or qualifications of the 

applicant for the job or credit in question and without any individualized assessment of whether 

their criminal history makes them personally unqualified. They are excluded solely on the fact of 

a prior conviction or even a pending criminal charge, regardless of whether they pose a current 

risk.

VII. Defendant’s Policy Disproportionately and Severely Impacts People of Color in 

Cook County, Illinois

70. Defendant’s automatic criminal history ban has a disproportionate impact based 

on the color of a person’s skin. Specifically, Defendant’s policy and practices disproportionately 

excludes otherwise-qualified non-White applicants.
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71. Plaintiff is a resident of Cook County, Illinois and Defendant conducts business in 

Cook County, Illinois.

72. On the one hand, only 100 out of every 1000 residents of Cook County with a 

criminal record are White, whereas 900 out of every 1000 residents of Cook County with a 

criminal record are of color. On the other hand, 420 out of every 1000 resident so Cook County 

is White, whereas 580 out of every 1000 residents of Cook County are of color.

73. Based on this data, people of color are 9 times more likely than Whites to have a 

criminal record. That is, the risk of disqualifying convictions among people of color is almost 9 

times the risk of disqualifying convictions among White people.

74. People of color seeking credit from Defendant are thus substantially more likely 

than Whites to be harmed by Defendant’s policy and practices irrespective of the terms of credit.

75. Defendant’s refusal to provide credit to people of color on its policy and practices 

directly causes a racially disparate, adverse impact on people of color.

76. Defendant’s use of the non-public policy and practices means that applicants will 

never know the real reason why credit was denied.

77. The statistical disparities here are extraordinary. That is, the difference in the rates 

at which colored applicants are adversely affected by the policy and practices is dramatically 

larger than the rate at which White applicants are affected. Moreover, these dramatic disparities

are entirely foreseeable because of well-known disparities in the criminal justice system. As the 

Supreme Court has explained, large statistical disparities are “often a telltale sign of purposeful 

discrimination[.]” Int’l Bhd. Of Teamsters v. United States, 431 U.S. 324, 339 n.20 (1977).
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VIII. Defendant’s Broad Policy and Practices Cannot be Justified as Necessary for 

Protecting Safety, Assets, or Reputation

78. Extensive research establishes that protecting safety, assets or reputation does not 

justify a blanket criminal records policy. The research shows that additional factors, such as the 

amount of time since the last offense, the person’s age, and the type of conviction, must be 

considered to assess whether a past criminal conviction suggests a risk of future criminal 

conduct.

79. It was in fact on that basis and the recommendation of the U.S. Probation Office, 

as determined by its categorization of very low risk, that this Court terminated Plaintiff’s 3-year 

term of Supervised Release on the 1-year anniversary date from the commencement of 

supervision – a rare occurrence in criminal cases.

80. The amount of time since the last offense is a critical factor in making this 

assessment. Studies show that in seven years or even less, the risk of future arrest for somebody 

with a past conviction becomes no greater than the risk for somebody without a past conviction.

81. Studies show that a person’s age and the frequency of past criminal activity are 

also key factors in determining whether the individual poses any risk to safety, assets, or 

reputation. People with a criminal record who are older, and those with fewer criminal offenses, 

are much less likely to engage in future criminal conduct or to pose a threat to the community.

82. Accordingly, safety, assets, and reputation do no provide a substantial and 

legitimate rationale for a broad blanket ban on eligibility like Defendant’s policy and practices.
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IX. Giving Individualized Consideration to Applicants’ Circumstances Is a Readily 

Available and Less Discriminatory Alternative That Would Satisfy Any 

Substantial, Legitimate, Nondiscriminatory Interest Behind Defendant’s Policy 

and Practices

83. Giving individualized consideration to each applicant’s circumstances is a less 

discriminatory alternative to Defendant’s policy and practices. This would address any 

substantial, legitimate, nondiscriminatory justification for the policy and practices.

84. Specifically, to the extent safety, assets and reputational risks of Defendant are a 

valid justification, protection of those concerns can be accomplished through the use of 

individual assessments that consider the nature of an individual’s conviction, the amount of time 

since the conviction or release, and evidence of rehabilitation, among other factors. An 

individualized assessment allows people with a criminal record, but who pose no realistic current 

or future threat to Defendant, to obtain credit. This more tailored approach both protects safety, 

assets, and reputation and is less discriminatory and exclusionary because it reduces the number 

of colored applicants who are categorically banned from obtaining credit from Defendant.

85. In the analogous employment context, the EEOC recognizes that individualized 

assessments are almost always required by law because they provide a less discriminatory 

alternative to automatic criminal history bans and are sufficient to protect legitimate interests, 

including safety. Specifically, the EEOC’s Enforcement Guidance advocates the use of “a 

targeted screen considering at least the nature of the crime, the time elapsed, and the nature of 

the job.” This screening should include “notice to the individual that he has been screened out 

because of a criminal conviction; an opportunity to demonstrate that the exclusion should not be 

applied due to his particular circumstances; and consideration by the employer as to whether the 
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additional information provided by the individual warrants an exception to the exclusion and 

shows that the policy as applied is not job related and consistent with business necessity.”

86. Defendant’s overly broad policy and practices prevents any individualized 

consideration. But Defendant would not have to compromise any legitimate concerns that they 

may have to give individualized considerations to applicants’ particular circumstances and allow

those individuals whose credit would not threaten safety, assets, or reputational interest of 

Defendant.

87. Defendant’s policy of automatically excluding people with felony convictions, 

certain misdemeanor convictions, and even some arrests, is not necessary to achieve a substantial 

and legitimate business interest.

X. General RICO Allegations

88. Plaintiff is a “person” with standing to sue within the meaning of the 

Racketeering Influenced Corrupt Organizations Act (RICO), 18 U.S.C. §§ 1961(3) and 1964(c). 

89. Defendant is a RICO “person” within the meaning of 18 U.S.C. § 1961(3) 

because it is an entity capable of holding a legal or beneficial interest in property.

90. Defendant, through its, employees, officers, directors, agents, representatives, and 

successors, acted in concert and associated as a distinct association-in-fact. Defendant therefore 

formed an enterprise within the meaning of 18 U.S.C. § 1961(4). Defendant does not operate as a 

completely separate entity in providing credit and other essential banking services under threat of 

violence. Rather, it has an ongoing relationship and shares the common purpose of 

discriminating Plaintiff and others by fraudulent means to deny credit and other essential 

banking services.
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91. Defendant functions as a continuing unit and has so functioned for a sufficient 

period of time to permit it to pursue the goals of the enterprise. Defendant has functioned as a 

continuing unit since at least 2008.Throughout the years, Defendant has sent denial of credit 

letters to those with felonies and/or other criminal histories, by the means of mail or wire, in 

which it claimed that its decision was based on certain credit history factors, when said claims 

were made falsely in order to fraudulently satisfy the Statement of Reasons requirement under 15 

U.S.C. § 1691(d).

92. Defendant sent such false denial of credit letters to innumerous applicants.

93. Defendant sent one such letter to Plaintiff when it denied his application for the 

Chase Credit Card on or around February 1, 2020.

94. Defendant sent another such letter to Plaintiff when it took the adverse action of 

terminating his Amazon Card on or around June 1, 2020.

95. Defendant yet sent another such letter to Plaintiff when it denied re-opening his 

Amazon Card on or around June 4, 2020.

96. Through these actions, Defendant facilitates and participates in a pattern of 

racketeering through predicate acts of mail and wire fraud. Defendant knows and intends that 

these acts of racketeering will be committed through its participation in the enterprise, and it has 

engaged in racketeering activities continuously over at least the previous 12 years. Defendant’s 

racketeering practices extend over multiple years and are a regular way of conducting the 

ongoing business of its credit lending business.

97. Defendant engaged in interstate commerce in that its activities and transactions 

relating to the false denial letters frequently required movement and communications across state 
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lines and the use of interstate facilities, including communication via mail, email and phone. 

Further, Defendant has a presence in all 50 states of the United States.

INJURY TO PLAINTIFF

98. As a result of Defendant’s actions described above, Plaintiff has been directly and 

substantially injured. Plaintiff has been frustrated in his attempt to maintain a deposit account 

and obtain credit.

99. Chase bank is everywhere. It is the largest bank in the United States. It has over 

5,000 branches that covers every State in the nation. Many major companies such as 

Amazon.com, United Airlines, Southwest Airlines, Marriott Hotels, Disney, Starbuck, etc. have 

their credit cards issued through Defendant. It has essentially turned itself into Evil Corp - a 

trope used in the USA Network’s hit television show Mr. Robot. It has become an indispensable 

bank in most Americans’ day-to-day lives.

100. Transitioning to a different bank will lead Plaintiff to access to fewer fee-free 

ATMs, different service fees, interest rates, and other such distinctive effects.

101. The denial of credit on two different occasions led to Defendant checking 

Plaintiff’s credit history thrice. Each check led to a drop in his credit score and appears as a 

credit-seeker to subsequent creditors. The termination of the Amazon Card by Defendant led to a 

display of short account history on his credit report. All factors in combination significantly 

alters his credit reports to the point that subsequent lenders will view him as a riskier applicant 

than he really is.

102. Because Defendant’s policy and practices have had and continue to have the 

effect of banning people with criminal records, who are disproportionately of color, from 
22

obtaining credit, Defendant’s conduct frustrates Plaintiff’s livelihood and opportunity to obtain 

credit equal to his White counterparts, and free of arbitrary barriers.

103. Plaintiff has been damaged by having to divert his assets elsewhere. Moreover, 

due to the COVID-19 stay-at-home orders, it is now harder than ever to locate a bank that will 

open a new account at a branch.

104. Plaintiff no longer has even one credit card.

105. On May 26, 2020, Plaintiff’s business was officially approved as a federal 

contractor to the government of the United States and was assigned a Commercial and 

Government Entity Code by the Department of Defense Logistics Agency. However, after the 

termination of the Amazon Card, Plaintiff does not have access to any credit card anymore to do 

business as a federal contractor. Without the line of credit that Plaintiff was previously 

authorized in the Amazon Card, he will not be able to fulfill any Purchase Orders of the 

government as a federal contractor.

106. But for the series of denials of the various banking services of Defendant, Plaintiff 

had to invest a substantial amount of time and money to relocate his assets.

107. Defendant’s discriminatory conduct, if continued, will lead Plaintiff to lose all 

potential business as a government contractor and the income generated thereof.

108. Defendant’s unlawful actions described herein were, and are, intentional, willful, 

and malicious, and/or have been, and are, implemented with callous and reckless disregard for 

rights protected under federal and state law.
23

CAUSES OF ACTION

COUNT I – Disparate Impact in Violation of the ECOA, 15 U.S.C. § 1691(a)(1)

109. Plaintiff repeats and incorporates by reference all allegations set forth in 

Paragraphs 1 through 108 above.

110. Defendant’s acts, policies and practices have an adverse and disproportionate 

impact on people of color as completed to similarly-situated Whites. This adverse and 

disproportionate impact is the direct result of Defendant’s policy and practices, which 

automatically denies credit to people with a criminal record without considering the applicant’s 

individual characteristics and circumstances.

111. To wit, Defendant discriminated Plaintiff on the basis of color when he applied 

for and was denied or terminated for the Paycheck Protection Program, the Chase Credit Card, 

an Amazon Card, and three credit cards as an Authorized User.

112. Defendant’s policy and practices was not and is not necessary to serve any 

substantial, legitimate, nondiscriminatory interest, and any such interest could be satisfied by 

another practice – providing individualized consideration – that would have a less discriminatory 

effect.

113. Defendant’s acts, policies, and practices constitute discrimination and violate the 

ECOA and its implementing regulations, in that Defendant’s acts, policies, and practices 

constitute a refusal to lend credit because of color, and have made obtaining credit unavailable 

because of color, in violation of 15 U.S.C. § 1691(a)(1).
24

COUNT II – Failure to Provide a Statement of Reasons in Violation of the ECOA, 15 

U.S.C. § 1691(d)(2)

114. Plaintiff repeats and incorporates by reference all allegations set forth in 

Paragraphs 1 through 113 above.

115. Defendant denied or terminated Plaintiff’s Paycheck Protection Program loan 

application and three Authorized User credit cards without a statement of reasons as a matter of 

course to Plaintiff.

116. After the adverse actions were taken, Defendant neither provide Plaintiff with 

written notifications of the adverse actions that disclosed his right to a statement of reasons 

within 30 days after their receipt of the requests made within 60 days after such notification, nor 

provided the identity of the person or office from which such statement could have been obtained

117. Defendant also neither provided Plaintiff such statements orally nor gave him a 

written notification advising him of his right to have the statement of reasons confirmed in 

writing on written request.

118. Defendant’s acts and omissions constitute a violation of the ECOA and its

implementing regulations under of 15 U.S.C. § 1691(d)(2).

COUNT III – Refusal to Extend Credit Based on Marital Status in Violation of the ECOA,

15 U.S.C. § 1691(a)(1)

119. Plaintiff repeats and incorporates by reference all allegations set forth in 

Paragraphs 1 through 118 above.

120. Defendant denied or terminated Plaintiff’s three credit cards for which he was 

designated as an Authorized User.
25

121. Plaintiff was an immediate family member of the Primary Cardholder on each 

credit card.

122. Defendant not only terminated all three of Plaintiff’s credit cards, its action 

constituted a refusal to extend credit to Plaintiff by discriminating him on the basis of marital 

status.

123. Under 12 C.F.R. § 1002.7(a), Defendant is prohibited from refusing Plaintiff’s 

individual account on the basis of marital status. The interpretive rules issued by the Consumer 

Financial Protection Bureau of §1002.7(a) specifically prohibit Defendant from refusing to 

accept Plaintiff, a non-spouse, as an Authorized User of the Primary Cardholder.

124. Defendant’s acts and omissions constitute a violation of the ECOA and its 

implementing rules and regulations under 15 U.S.C. § 1691(a)(1).

COUNT IV – Pattern of Racketeering Activity under the RICO Act, in violation of 18

U.S.C. § 1962(c)

125. Plaintiff repeats and incorporates by reference all allegations set forth in 

Paragraphs 1 through 124 above.

126. Defendant, through its, employees, officers, directors, agents, representatives, and 

successors, conducted or participated in and conspired to conduct the affairs of a RICO 

enterprise through a pattern of racketeering activity by engaging in the following predicate acts 

of racketeering activity under 18 U.S.C. § 1961(1), in violation of 18 U.S.C. § 1962(c):

a. Mail fraud, in violation of 18 U.S.C. § 1341

b. Wire fraud, in violation of 18 U.S.C. § 1343

127. The predicate acts stated herein all occurred after the effective date of RICO and

more than two such acts occurred within ten years of one another.
26

128. The enterprise alleged herein also engaged in legitimate business activities 

beyond those necessary to carry out the alleged acts of racketeering.

129. The predicate acts described herein were related so as to establish a pattern of 

racketeering activity within the meaning of 18 U.S.C. § 1962(c), in that the common purpose of 

Defendant was to defraud Plaintiff and other similarly-situated people from accessing credit.

130. Plaintiff was a victim of racketeering; and/or the acts of racketeering were 

otherwise interrelated by distinguishing characteristics and were not isolated events.

131. All of the predicate acts described herein were continuous as to form a pattern of 

racketeering activity in that 1) Defendant engaged in the predicate acts over a substantial time; or 

2) the patterns of racketeering activity engaged in by Defendant continues or threatens to 

continue because such conduct has become a regular way of on-going business activities.

132. As a direct and proximate result of, and by reason of, the activities of Defendant

and its conduct in violation of 18 U.S.C. § 1962(c), Plaintiff has been injured in his business and 

property, within meaning of 18 U.S.C. § 1964(c) and is, therefore, entitled to recover threefold 

the damages sustained to him, with the cost of the suit, including reasonable attorneys’ and 

experts’ fees.

I. Mail Fraud Predicate Act

133. 18 U.S.C. § 1341. Mail Fraud. “Whoever, having devised or intending to devise 

any scheme or artifice to defraud,... places in any post office... to be sent by the Postal 

Service...” commits mail fraud.

134. Defendant’s denial of credit letter for the Chase Credit Card was mailed to 

Plaintiff via the U.S. Postal Service on or around February 1, 2020.
27

135. In order to deny Plaintiff credit, Defendant knowingly, voluntarily, and 

intentionally devised and participated in a scheme to defraud him by providing a false Statements 

of Reasons. Defendant used those false and material misrepresentations that were reasonably

calculated to deceive persons of ordinary prudence and intelligence.

136. Defendant intended for Plaintiff to rely on such false and material 

misrepresentations to defraud him of having access to credit. Moreover, Defendant acted with 

the knowledge and believe that by providing the false and material misrepresentations to 

Plaintiff, it would reduce its future liabilities. 

II. Wire Fraud Predicate Acts

137. 18 U.S.C. § 1343. Wire Fraud. “Whoever, having devised or intending to devise 

any scheme or artifice to defraud,... transmits or causes to be transmitted by means of wire... in 

interstate... commerce, any writing,... for the purpose of executing such scheme...” commits 

wire fraud.

138. First Wire Fraud Predicate Act: Defendant’s termination of credit letter for the 

Amazon Card was emailed and posted on Defendant’s website through logging in to his account 

via an online portal on or around June 1, 2020.

139. Second Wire Fraud Predicate Act: Defendant’s denial of re-opening of credit 

letter for the Amazon Card was emailed and posted on Defendant’s website through logging in to 

his account via an online portal on or around June 4, 2020

140. In order to deny Plaintiff further access to his credit, Defendant knowingly, 

voluntarily, and intentionally devised and participated in a scheme to defraud him by providing a 

false Statements of Reasons. Defendant used those false and material misrepresentations that 

were reasonably calculated to deceive persons of ordinary prudence and intelligence.
28

141. Defendant intended for Plaintiff to rely on such false and material 

misrepresentations to defraud him of having access to credit. Moreover, Defendant acted with 

the knowledge and believe that by providing the false and material misrepresentations to 

Plaintiff, it would reduce its future liabilities.

III. Other Mail and Wire Fraud Predicate Acts

142. Defendant has emailed, posted, and mailed via the U.S. Postal Service, such 

letters as aforementioned to innumerous other similarly-situated credit applicants.

143. In order to deny those applicants access to credit, Defendant knowingly, 

voluntarily, and intentionally devised and participated in a scheme to defraud them by providing 

a false Statements of Reasons. Defendant used those false and material misrepresentations that 

were reasonably calculated to deceive persons of ordinary prudence and intelligence.

144. Defendant intended for such applicants to rely on those false and material 

misrepresentations to defraud them from having access to credit. Moreover, Defendant acted 

with the knowledge and believe that by providing the false and material misrepresentations to 

such applicants, it would reduce its future liabilities.

145. Each letter sent to each victim of Defendant’s perpetrated fraud constitutes a 

predicate act of mail and/or wire fraud, in violation of 18 U.S.C. §§ 1341 and 1343.

DEMAND FOR JURY TRIAL

146. Under Fed. R. Civ. P. 38(b), Plaintiff demands a trial by jury on all issues triable 

as of right.

REQUESTED RELIEF

147. Plaintiff respectfully asks that the Court grant him the following relief:
29

a. Enter a declaratory judgment finding that the foregoing actions of Defendant 

violate 15 U.S.C. § 1691, 18 U.S.C. §§ 1341, 1343, and 1962.

b. Enter a permanent injunction:

i. Enjoining Defendant and its employees, agents, officers, and directors

from implementing and enforcing the illegal, discriminatory conduct 

described herein;

ii. Directing Defendant and its employees, agents, officers, and directors to 

revise its policy and practices, to reduce the adverse and disproportionate 

effect it causes on the basis of color and make it consistent with the Equal 

Credit Opportunity Act; and

iii. Directing Defendant and its employees, agents, officers, and directors to 

take all affirmative steps necessary to remedy the effects of the illegal, 

discriminatory conduct described herein and to prevent additional 

instances of such conduct or similar conduct from occurring in the future;

c. Award compensatory damages to Plaintiff in an amount to be determined by the 

jury that would fully compensate Plaintiff for injuries caused by the conduct of 

Defendant alleged herein;

d. Award punitive damages to Plaintiff in an amount to be determined by the jury 

that would punish Defendant for its willful, malicious, and reckless conduct 

alleged herein and that would effectively deter similar conduct in the future;

e. Award Plaintiff his reasonable attorneys’ fees and costs under 42 U.S.C. §

3613(c)(2);

f. Award prejudgment interest to Plaintiff; and
30

g. Order such other relief as this Court deems just and equitable.

Dated: June 6, 2020

Respectfully submitted,

/s/ Vivek Shah

Vivek Shah

236 Woburn Ln

Schaumburg, Il 60173

VERIFICATION OF COMPLAINT

I, Vivek Shah, hereby declare under penalty of perjury that the foregoing facts contained 

in this Complaint are true and correct to the best of my knowledge.

Executed on June 6, 2020

/s/ Vivek Shah

VIVEK SHAH
Exhibit

A
•

•

•

•

•

•

•

•

•

•

•

June 01, 2020

Your account ending in 1400

Dear Vivek Shah:

Based on a recent review of your account and credit information, we decided to close your credit account

above.

RAPID INCREASE IN REVOLVING BALANCES

TOO MANY REQUESTS FOR CREDIT OR REVIEWS OF CREDIT

Our decision was based in whole or in part on information obtained in a report from the consumer reporting

agency listed below. You have a right under the Fair Credit Reporting Act to know the information contained

in your file at the consumer reporting agency. The reporting agency played no part in our decision and is

unable to supply specific reasons for our decision.

Experian

(888) 397-3742

P.O. Box 2002

Allen, TX 75013

Details about your right to know the information in your credit report are provided at the end of this letter.

Destroy all cards and access checks.

Contact any merchants that automatically bill the account for ongoing services and make other

payment arrangements.

Make payments on any remaining balance by the due date on your statements.

Review the current terms and conditions that still apply to this account.

Tell anyone else that uses the account that its closed.

If you redeem rewards through Chase, you have at least 30 days to use them or youll lose them.

If you redeem rewards through a partner loyalty program, well transfer them to the partner.

Before your rewards are used or transferred, you can lose them for program misuse, fraudulent

activities, failure to pay, bankruptcy, or other reasons described in the terms of your rewards

program.

See the terms of your rewards program for details.

1-800-290-1316

www.chase.com/amazon

Cardmember Services

P.O. Box 15298

Wilmington, DE 19850-5298

We closed your account and we want to explain why

Here are the reasons we closed your account

Heres where we got our information

These are your next steps

If your account earns rewards, check your rewards activity

Questions?

Please see the end of this letter for important information.

18814 RCS 001 000 15320 - NNNNNNNNNNNN CSO116 

Vivek Shah

 

236 Woburn Ln

Schaumburg IL 60173-2136

Update:
Page 2

If you have questions, please call us at 1-800-290-1316. Were here Monday through Friday from 9 a.m. to 7

p.m. Eastern Time. We accept operator relay calls.

Sincerely,

Chase Card Services

Under the Fair Credit Reporting Act, you also have a right to a free copy of your

report from the reporting agency, if you request it no later than 60 days after you

receive this notice. In addition, if you find that any information contained in the

report you receive is inaccurate or incomplete, you have the right to dispute the

matter with the reporting agency.

The Federal Equal Credit Opportunity Act prohibits creditors from discriminating

against credit applicants on the basis of race, color, religion, national origin, sex,

marital status, age (provided the applicant has the capacity to enter into a binding

contract); because all or part of the applicant's income derives from any public

assistance program; or because the applicant has in good faith exercised any right

under the Consumer Credit Protection Act. The Federal agency that administers

compliance with this law concerning this creditor is the Bureau of Consumer

Financial Protection, 1700 G Street NW, Washington, DC 20006.

FAIR CREDIT REPORTING ACT NOTICE

EQUAL CREDIT OPPORTUNITY ACT NOTICE
•

•

•

June 04, 2020

Your account ending in 1400

Dear Vivek Shah:

Thank you for asking us to reopen your credit card account above. We reviewed your credit information and

decided not to reopen it because:

RAPID INCREASE IN REVOLVING BALANCES

TOO MANY REQUESTS FOR CREDIT OR REVIEWS OF CREDIT

Our decision was based in whole or in part on information obtained in a report from the consumer reporting

agency listed below. You have a right under the Fair Credit Reporting Act to know the information contained

in your file at the consumer reporting agency. The reporting agency played no part in our decision and is

unable to supply specific reasons for our decision.

Experian

P.O. Box 2002

Allen, TX 75013

(888) 397-3742

Details about your right to know the information in your credit report are provided at the end of this letter.

If you owe a balance on the account:

We will continue to send you monthly statements.

You then must pay either the minimum monthly payment or the full balance.

We still apply all terms and conditions of the account.

If you have questions, please call us at 1-800-290-1316. We're here Monday through Friday from 9 a.m. to 7

p.m. Eastern Time.

Sincerely,

Chase Card Services

www.chase.com/amazon

1-800-290-1316

We accept operator relay calls

Cardmember Services

P.O. Box 15298

Wilmington, DE 19850-5298

We didn't reopen your credit card account

Here's where we got our information

Questions?

See the end of this letter for important information

32459 RCS 001 000 15620 - NNNNNNNNNNNN CLO058 

Vivek Shah

 

236 Woburn Ln

Schaumburg IL 60173-2136

Update:
Page 2

Under the Fair Credit Reporting Act, you also have a right to a free copy of your

report from the reporting agency, if you request it no later than 60 days after you

receive this notice. In addition, if you find that any information contained in the

report you receive is inaccurate or incomplete, you have the right to dispute the

matter with the reporting agency.

The Federal Equal Credit Opportunity Act prohibits creditors from discriminating

against credit applicants on the basis of race, color, religion, national origin, sex,

marital status, age (provided the applicant has the capacity to enter into a binding

contract); because all or part of the applicant's income derives from any public

assistance program; or because the applicant has in good faith exercised any right

under the Consumer Credit Protection Act. The Federal agency that administers

compliance with this law concerning this creditor is the Bureau of Consumer

Financial Protection, 1700 G Street NW, Washington, DC 20006.

FAIR CREDIT REPORTING ACT NOTICE

EQUAL CREDIT OPPORTUNITY ACT NOTICE


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Credit Score Decrease

Your FICO® Score has decreased by 21 points.

Credit Line Closed by Grantor

JPMCB CARD has agged your account as Credit Line Closed by Grantor.

Credit Score Increase

Your FICO® Score has increased by 5 points.

Your Andigo Credit Union account needs attention

Please reconnect your Andigo Credit Union.

Credit Rating Increase

Your FICO® Score rating has changed from Good to Very Good!

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Credit Score Increase

Your FICO® Score has increased by 1 points.

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US SM BUS ADMIN ODA obtained a copy of your Experian Credit Report.

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JPMCB CARD reported a new account on your Experian Credit Report.

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Download the

Chase Mobile app today ® ACCOUNT SUMMARY YOUR ACCOUNT MESSAGES

AUTOPAY IS ON

See Your Account

Messages for details.

AUTOPAY IS ON

P.O. BOX 15123

 WILMINGTON, DE 19850-5123

For Undeliverable Mail Only

$

Payment Due Date: 06/05/20

New Balance: $1,040.10

Minimum Payment: $35.00

Credit Card Statement

0000001 FIS33339 C 2 Y 9 08 20/05/08 Page 1 of 2 06654 MA MA 81683 12910000020008168301

81683 BEX 9 12920 C 

0510 

www.chase.com/amazon 1-888-247-4080

Download the

Chase Mobile app today

Late Payment Warning: 

Minimum Payment Warning: 

Account Number: 4147 4002 7898 1400

New Balance $1,040.10

Past Due Amount $0.00

Balance over the Credit Access Line $0.00

Account number: 4147 4002 7898 1400

If we do not receive your minimum

payment by the date listed above, you may have to pay a late fee of

up to $39.00.

 If you make only the minimum

payment each period, you will pay more in interest and it will take

you longer to pay off your balance. For example:

If you make no

additional charges

using this card and

each month you pay...

You will pay off the

balance shown on this

statement in about...

And you will end up

paying an estimated

total of...

Only the minimum

payment

3 years $1,427

$38 3 years $1,380

(Savings=$47)

If you would like information about credit counseling services, call

1-866-797-2885.

Previous points balance 0

+ 5% Back on Amazon.com purchases 2,302

+ 5% Back on Whole Foods Market purchases 0

+ 2% Back at gas stations 0

+ 2% Back at restaurants 65

+ 2% Back at drugstores 0

+ 1% Back on all other purchases 548

"% Back rewards" are the rewards you earn under the program.

% Back rewards are tracked as points and each $1 in % Back

rewards earned is equal to 100 pts. You can redeem your points

toward millions of items when you shop at Amazon.com or for

cash back, gift cards and travel at chase.com/amazonrewards.

To see if your card earns 5% Back or 3% Back on Amazon.com

and Whole Foods Market purchases, sign into an Amazon.com

account where your card is loaded, visit "Your Account" page,

click the "Manage Payment Options" page under the "Payment

Methods" section, and expand the details of your credit card. If

that Amazon.com account has an eligible Prime membership, and

your card could be earning 5% Back on Amazon.com and Whole

Foods Market purchases, you'll see how to start earning 5% Back

on Amazon.com and Whole Foods Market purchases. You can

go to Chase.com to see whether you earned 5% Back or 3%

Back on previous Amazon.com and Whole Foods Market

purchases.

Have a question about what you ordered at Amazon.com? Sign in

to your Amazon.com account and go to "Your Account," then

"Your Orders" to view your recent orders. For questions about

purchases or returns, call Amazon Customer Service at

1-866-216-1072. 

VIVEK SHAH

236 WOBURN LN

SCHAUMBURG IL 60173-2136

_________________________.___________Amount Enclosed

New Balance

Minimum Payment Due

Payment Due Date

DEFAULTD

Previous Balance $0.00

Payment, Credits -$9.89

Purchases +$1,049.99

Cash Advances $0.00

Balance Transfers $0.00

Fees Charged $0.00

Interest Charged $0.00

Opening/Closing Date 04/22/20 - 05/08/20

Credit Access Line $6,400

Available Credit $5,359

Cash Access Line $1,280

Available for Cash $1,280

June 2020

S M T W T F S

31 1 2 3 4 5 6

7 8 9 10 11 12 13

14 15 16 17 18 19 20

21 22 23 24 25 26 27

28 29 30 1 2 3 4

5 6 7 8 9 10 11

 `

`

`

If you experience COVID-19 related mail delivery disruptions, remember you can always access your statements on chase.com or the 

Chase Mobile App.

CARDMEMBER SERVICE

PO BOX 1423

CHARLOTTE NC 28201-1423

ACCOUNT SUMMARY

POINTS SUMMARY

Total points available for

redemption 2,915

$1,040.10

$35.00

06/05/20

YOUR ACCOUNT MESSAGES

® 
To contact us regarding your account:

P.O. Box 1423

Charlotte, NC 28201-1423

To manage your account, including card payments, alerts, and change of address, visit 

 or call the customer service number which appears on your account

statement.

Chase.com/cardhelp

P.O. Box 15298

Wilmington, DE 19850-5298

www.chase.com/cardhelp

In U.S. 1-888-247-4080

Spanish 1-888-446-3308

Pay by phone 1-800-436-7958

International 1-302-594-8200

We accept operator relay calls
Download the

Chase Mobile app today ® ACCOUNT ACTIVITY

Year-to-date totals do not reflect any fee or interest refunds

you may have received. INTEREST CHARGES 0000001 FIS33339 C 2 Y 9 08 20/05/08 Page 2 of 2 06654 MA MA 81683 12910000020008168302

www.chase.com/amazon 1-888-247-4080

Download the

Chase Mobile app today

2020 Totals Year-to-Date

Annual Percentage Rate (APR) 

Balance Type

Annual

Percentage

Rate (APR)

Balance

Subject To

Interest Rate

Interest

Charges

PURCHASES

CASH ADVANCES

BALANCE TRANSFERS

16 Days in Billing Period

VIVEK SHAH Page 2 of 2 Statement Date: 05/08/20

Your next AutoPay payment for $1,040.10 will be deducted from your Pay From account and credited on your due date. If your due date 

falls on a Saturday, we'll credit your payment the Friday before.

Your AutoPay amount will be reduced by any payments or merchant credits that post to your account before we process your AutoPay 

payment. If the total of these payments and merchant credits is more than your set AutoPay amount, your AutoPay payment for that 

month will be zero.

Date of

Transaction Merchant Name or Transaction Description $ Amount

05/04 GROUPON-CUISINE OF INDI Chicago CA -9.89

04/28 WFM Amazon*AH4288863 Amzn.com/bill WA 42.08

Order Number 114-1224438-7913069

04/30 BLUE SHIELD CALIFORNIA 800-393-6130 CA 208.02

04/30 PUSH HEALTH 8557874432 CA 245.79

05/02 AMZN Mktp US*MM3QS6JW3 Amzn.com/bill WA 229.84

Order Number 113-7256232-6597813

05/02 AMZN Mktp US*IW88T6SH3 Amzn.com/bill WA 3.02

Order Number 113-8891053-9333810

05/02 CUISINE OF INDIA MP LLC MOUNT PROSPEC IL 19.78

05/01 GRUBHUBCAFEZUPASSCHAU GRUBHUB.COM NY 12.30

05/03 AMZN Mktp US*788ZG0QZ3 Amzn.com/bill WA 20.19

Order Number 112-7888930-4057009

05/04 TARGET 00008805 SCHAUMBURG IL 34.23

05/04 RAISE.COM HTTPSRAISE.CO IL 34.98

05/04 AMZN Mktp US*4G9JQ9GY3 Amzn.com/bill WA 55.12

Order Number 113-9564732-4334653

05/04 Amazon Prime*IR1BL31L3 Amzn.com/bill WA 5.99

Order Number D01-2718299-2649860

05/06 CARDCASH 800-227-4214 NJ 20.46

05/06 AMZN Mktp US*T26JS3K63 Amzn.com/bill WA 104.01

Order Number 114-8085119-7644240

05/07 RAISE.COM HTTPSRAISE.CO IL 14.18

Total fees charged in 2020 $0.00

Total interest charged in 2020 $0.00

Year-to-date totals do not reflect any fee or interest refunds

you may have received.

Your is the annual interest rate on your account.

Purchases 19.24%(v)(d) - 0 - - 0 - 

Cash Advances 24.99%(v)(d) - 0 - - 0 - 

Balance Transfer 19.24%(v)(d) - 0 - - 0 - 

(v) = Variable Rate

(d) = Daily Balance Method (including new transactions)

(a) = Average Daily Balance Method (including new transactions)

Please see Information About Your Account section for the Calculation of Balance Subject to Interest Rate, Annual Renewal Notice,

How to Avoid Interest onPurchases, and other important information, as applicable.

PAYMENTS AND OTHER CREDITS

PURCHASE

YOUR ACCOUNT MESSAGES (CONTINUED)

ACCOUNT ACTIVITY

INTEREST CHARGES

® 

6/6/2020 CREDIT CARD - chase.com

https://secure05c.chase.com/web/auth/dashboard#/dashboard/accounts/summary/creditCard;params=card,787541203 1/4

Current balance

−$85.81

Available credit

$0.00

Amazon Prime Rewards

Minimum payment due

$0.00

Remaining statement

balance

$0.00

Automatic payment is On.

Account activity

SHOWING Activity since last statement

Current balance −$85.81

Date Description Category Amount

Jun 3, 2020 AMZN Mktp US −$350.61

Jun 2, 2020 AMZN Mktp US −$229.84

May 31, 2020 WENDY'S 7003 $2.23

May 31, 2020 AMZN Mktp US*MY1HC2NX1 $34.08

May 31, 2020 Amazon.com*MY8HY9ZZ1 $35.88

May 30, 2020 Upwork -304745299REF $360.50

May 29, 2020 BOSTON MARKET 0260 $13.31

May 29, 2020 TRADER JOE'S #705 QPS $14.28

May 28, 2020 CAFE ZUPAS ONLINE ORDER −$800.00

May 28, 2020 CAFE ZUPAS ONLINE ORDER $800.00

May 28, 2020 MISTER MAIL $20.42

May 27, 2020 Payment Thank You - Web — −$543.73

May 26, 2020 Amazon.com*M77QR7QK0 $12.94

May 25, 2020 WALMART.COM $25.24

Shopping

Shopping

Food & drink

Shopping

Groceries

Professional services

Food & drink

Groceries

Food & drink

Food & drink

Personal

Shopping

Shopping

CREDIT CARD (...1400)

Printed from Chase for Business
6/6/2020 CREDIT CARD - chase.com

https://secure05c.chase.com/web/auth/dashboard#/dashboard/accounts/summary/creditCard;params=card,787541203 2/4

Date Description Category Amount

May 25, 2020 Upwork -304127617REF $103.00

May 25, 2020 AMZN Mktp US*M75BO0KF1 $10.58

May 24, 2020 GROUPON INC $4.25

May 24, 2020 AMZN Mktp US*M72JB8082 $22.56

May 24, 2020 Amazon.com*M72KS51R2 $7.42

May 24, 2020 GROUPON INC $3.07

May 24, 2020 TARGET 00008805 $44.36

May 24, 2020 AMZN Mktp US*M73PP7D31 $23.64

May 23, 2020 WWW.1AND1.COM $1.00

May 23, 2020 Amazon.com*M72RR3EB2 $28.97

May 23, 2020 Amazon.com*M71009841 $23.31

May 22, 2020 BACK IN LINE CHIROPRACTIC $93.71

May 21, 2020 Payment Thank You - Web — −$773.12

May 21, 2020 WALGREENS #9506 $3.58

May 20, 2020 AMZN Mktp US*M77JJ1E31 $53.31

May 20, 2020 TRADER JOE'S #705 QPS $46.23

May 20, 2020 AMZN Mktp US*M75NK0T90 $50.50

May 20, 2020 INTUIT *TURBOTAX $50.00

May 19, 2020 AMZN Mktp US*M793U2CI2 $21.24

May 19, 2020 AMZN Mktp US*M76LK9TB1 $350.61

May 19, 2020 GROUPON-GREEN BASIL THA −$0.71

May 19, 2020 Amazon.com*M72AW2JB1 $7.79

May 18, 2020 TULSI GROCERS $12.11

May 18, 2020 AMZN Mktp US*M720Y7LP1 $17.51

Professional services

Shopping

Personal

Shopping

Shopping

Personal

Shopping

Shopping

Bills & utilities

Shopping

Shopping

Health & wellness

Health & wellness

Shopping

Groceries

Shopping

Shopping

Shopping

Shopping

Personal

Shopping

Groceries

Shopping
6/6/2020 CREDIT CARD - chase.com

https://secure05c.chase.com/web/auth/dashboard#/dashboard/accounts/summary/creditCard;params=card,787541203 3/4

Date Description Category Amount

May 18, 2020 AMZN Mktp US*M786523G1 $42.39

May 18, 2020 AMZN Mktp US*M70HC9L21 $7.43

May 17, 2020 AMZN Mktp US*MC9GB0992 $25.49

May 17, 2020 Amazon.com*M72U60FD0 $14.72

May 17, 2020 Amazon.com*MC5UH6UF2 $24.62

May 17, 2020 Amazon.com*M76UU8FK0 $27.26

May 17, 2020 Payment Thank You - Web — −$546.41

May 16, 2020 TARGET 00008805 $45.42

May 16, 2020 AMZN Mktp US*MC6FK9YT1 $20.96

May 16, 2020 Amazon.com*M75HV8CE1 $10.87

May 16, 2020 AMZN Mktp US*M73Z81CG1 $25.86

May 16, 2020 Amazon.com*M74Z83CO1 $13.62

May 15, 2020 AMZN Mktp US*MC8645SG2 $18.80

May 15, 2020 AMZN Mktp US*MC1SY1RD0 $2.61

May 15, 2020 AMZN Mktp US*MC7665SU2 $20.17

May 14, 2020 GREEN BASIL THAI $14.35

May 14, 2020 SUSHI THAI II $4.30

May 14, 2020 TARGET 00008334 $5.67

May 14, 2020 GROUPON-TBK GRILL −$10.00

May 13, 2020 AMZN Mktp US*MC79E92I1 $16.11

May 13, 2020 STAPLES DIRECT $4.25

May 12, 2020 US REEBOK ONLINE STORE $16.39

May 11, 2020 RAISE.COM $22.76

May 11, 2020 Amazon.com*ZV1VC0SK3 $20.59

Shopping

Shopping

Shopping

Shopping

Shopping

Shopping

Shopping

Shopping

Shopping

Shopping

Shopping

Shopping

Shopping

Shopping

Food & drink

Food & drink

Groceries

Personal

Shopping

Shopping

Shopping

Shopping

Shopping
6/6/2020 CREDIT CARD - chase.com

https://secure05c.chase.com/web/auth/dashboard#/dashboard/accounts/summary/creditCard;params=card,787541203 4/4

Date Description Category Amount

May 11, 2020 HEALTH CARE SERVICES COM $399.04

May 11, 2020 AMZN Mktp US*MC4U61QH1 $44.89

May 11, 2020 Payment Thank You-Mobile — −$1,809.54

May 10, 2020 2975 Dominos Pizza $8.95

May 10, 2020 TBK GRILL $13.46

May 9, 2020 Amazon.com*DC8MR5QL3 $25.51

May 9, 2020 AMZN Mktp US*2H1316903 $18.36

May 8, 2020 BIG BOWL SCHAUMBURG $10.75

May 8, 2020 RAISE.COM $50.00

May 8, 2020 Amazon.com*HF01G67P3 $50.93

May 8, 2020 SAG-AFTRA $578.56

May 8, 2020 JEWEL-OSCO $31.06

May 8, 2020 RITUAL.CO* RITUAL-YUS $1.59

May 7, 2020 BUFFALO WILD WINGS 0342 $2.68

Bills & utilities

Shopping

Food & drink

Food & drink

Shopping

Shopping

Food & drink

Shopping

Groceries

Personal

Groceries

Food & drink

Food & drink

JPMorgan Chase Bank, N.A. Member FDIC ©2020 JPMorgan Chase & Co. Equal Opportunity Lender 
6/6/2020 Score Tracker

https://usa.experian.com/member/credit/score/experian/now/tracker 1/3

Your Next 3 Bureau Credit Report and FICO Scores will be available in 340 days. Can't wait? ®

Score Tracker 

Credit score is calculated based on FICO Score 8 model, unless otherwise noted. In addition to the FICO Score 8, we may offer and provide other base

or industry-specic FICO Scores (such as FICO Auto Scores and FICO Bankcard Scores). Your lender or insurer may use a different FICO Score than

FICO Score 8 or such other base or industry-specic FICO Score (if available), or another type of credit score altogether. Learn more.

May 23 May 30 Jun 6

Jul 2019 Oct 2019 Jan 2020 Apr 2020

Poor

300-579

Fair

580-669

Good

670-739

Very Good

740-799

Exceptional

800-850 749 VERY GOOD

Jun 02, 2020

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