Consumer complaint received 2024-12-15
Product: Prepaid card — Government benefit card
Issue: Problem with a purchase or transfer — Card company isn't resolving a dispute about a purchase or transfer
Company: BANK OF AMERICA, NATIONAL ASSOCIATION (CA)

I am filing this complaint regarding Bank of Americas handling of my dispute involving unauthorized transactions on my account. Upon discovering multiple consecutive unauthorized transactions that ultimately drained my account to a XXXX balance, I promptly called the bank to dispute them. The representative informed me that the system required the disputes to be filed as separate claims. As a result, four claims were submitted for review.

Three of the claims were ruled in my favor, and the bank confirmed those transactions were unauthorized. However, the fourth claim was denied based on reasoning that is inconsistent with the findings of the other claims and unsupported by substantial evidence. The banks denial letter stated : No evidence of inconsistent or aggressive spending or high-velocity transactions associated with a compromised card. 
A pattern of transactions following card funding loads, pausing once the balance was used, and restarting after new funds were loadaed. 
The spending pattern appeared consistent between valid and disputed transactions. 
No failed PIN attempts were detected. 
These points fail to address the most critical and obvious inconsistency : three of the four claims found all the transactions in those claims to be fraudulent. The disputed transactions all occurred consecutively as part of the same fraudulent activity, draining my account to XXXX. If Bank of America determined those transactions were fraudulent, it is unreasonable to conclude that one was authorized without providing specific evidence to support that determination.XXXXAdditionally, the banks reliance on a lack of failed PIN attempts or " consistent spending patterns '' is flawed, particularly given the high levels of fraud during the XXXX pandemic, including unemployment-related fraud through XXXX. Criminals have become adept at accessing stolen personal informationsuch as mine, which has been compromised in previous data breaches, including the XXXX breachand using it to bypass traditional fraud detection methods. A lack of failed PIN attempts is not a strong argument when unemployment insurance fraud was rampant at that time. 

Despite my request for all investigation details, Bank of America only provided a generic list of transactions, including the date, time, merchant name, location, and amount, which is identical to what is available in my online banking statement. This does not meet the requirements of a thorough investigation under Regulation E.

Bank of America has failed to conduct a reasonable and thorough investigation into my claim, as required by federal law. Their basis for denying the fourth claim is fundamentally flawed, particularly given that three of the four claimsrepresenting parts of the same fraudulent activity involving consecutive transactionswere already found to be fraudulent. I respectfully request that the CFPB require Bank of America to : Reevaluate the denied claim based on a proper and transparent investigation. 
Provide all evidence and documentation used in their investigation, including any merchant logs or records, and a detailed explanation of their reasoning for deny this claim. ( Not just a list of transactions as found in an online statement, this is not sufficient ) Thank you for your attention to this matter.