Consumer complaint received 2023-10-14
Product: Money transfer, virtual currency, or money service — International money transfer
Issue: Other transaction problem — 
Company: CITIBANK, N.A. (TX)

Citi ( Citibank ) failed in to exercise due diligence and therefore failed in its responsibility to try and prevent XXXX XXXXXXXX XXXX. This resulted in myself, an XXXX man, being exploited for {$48.00}, XXXX on XX/XX/2023. 

Compounding the problem, Citis fraud investigation department focused its efforts on trying to absolve the bank of any responsibility. It sent a letter to me saying it wasnt the banks fault and then made it impossible to contact the bank again to discuss the issue further. This was done by forcing me through a XXXX  process to contact the bank for further explanation or to elevate the complaint. The system is clearly designed to be unreasonably difficult and time consuming to dissuade people from trying to pursue the matter further internally at the bank. 

Citi created a product targeted at gaining new accounts from the elderly and then failed to have reasonable and proper controls in place to prevent their being exploited on these accounts, creating a perfect storm allowing mass exploitation of the elderly. 
Citis systemic failures to try and prevent XXXX XXXXXXXX XXXX are extensive and undoubtedly affects numerous customers. 

Resolution : I ask that Citi refund the {$48.00}, XXXX to me and internally review and modify its processes to mitigate the risk of this happening to other elderly. If Citi chooses not to reimburse me, I request that the CFPB open an investigation into the banks practices related to mitigating XXXX XXXXXXXX XXXX. Lastly, a class action lawsuit is in order against Citi. 

Detailed facts highlighting Citis marketing to and then failing to protect the elderly, specifically myself an XXXX man. 

Citi marketed to and opened an account for me an elderly person. 

Citi created a Federally Insured very high interest rate savings account called Citi Accelerate Savings account with rates of 3 % to 5 % in an environment with competitive savings accounts offering less than 1 %.

Citi marketed the Citi Accelerate Savings account account to the elderly including me. The advertising highlights language such as earn XXXX the national average on your savings and FDIC Insured.

The Citi Accelerate Savings account is obviously designed to attract the elderly who have savings, need the security of Federal insurance and who live on their savings and the interest it earns. 

Should the CFPB demand Citis marketing records including banner ads, video, paid search, paid social, email, print, direct mail, TV and Radio including broadcast, cable, and streaming, it will certainly show that the elderly were disproportionality targeted by Citis marketing of this product.

Should the CFPB demand Citis account records for its Citi Accelerate Savings account it will certainly show that the elderly over index as consumers of this product relative to the general population, as it was designed to appeal to the elderly and then marketed to the elderly. 

Citi opened a new account for me, an XXXX  person without ordinary and customary protections being put in place. I was exploited by a stranger for {$48000.00} within months of opening the account. The money was wired to a XXXX  bank account, in an amount and destination that is obviously suspicious. 

Citi set up new accounts for the elderly and failed as a matter of policy to institute two-factor authentication, reviews of large wires, reviews of suspicious dollar amount wires, wires to XXXX accounts or other customary and ordinary protections that are nearly XXXX  on all bank accounts regardless of the owners age but that are particularly important for the elderly to mitigate the risk of them being defrauded. Citis failure to have proper policies in place to protect the XXXX  created an unreasonable security exploit that could be used against the elderly to defraud them. 

Citis failure to have policies in place to mandate the accounts of the XXXX  be set up with customary and ordinary protections against fraud and abuse led directly to me being exploited for {$48000.00}. 

It is a given that a large transfer out of an elderly persons account to a XXXX  bank account when the person does not have a history of such transfers is suspicious. Citi has no policy in place or failed to use it to review suspicious transfers creating an unreasonable security exploit that could be used against the elderly to defraud them. 

A transfer to a XXXX  bank account slightly below {$50000.00}, especially when funds were in the account in excess of {$50000.00}, is patently suspicious as XXXX  know the bank must expeditiously report fraud above {$50000.00} to the FBI for its assistance in recovering the funds and for which the FBI has a high success rate. Citi has no policy in place or failed to use it to review a patently suspicious transfer creating an unreasonable security exploit that was used against me and elderly person to defraud me. 

Its an obvious failure of Citi not to have policies in place, or not to follow its policies, to flag for review patently suspicious transfers to foreign bank accounts that are outside of the normal activity of an elderly persons account. This led directly to me being exploited for {$48000.00}. 

When I became aware of the fraud, within XXXX hours of it occurring, I notified Citi. 

Citi failed to take timely and appropriate actions to mitigate my damages such as reversing the wire in a timely fashion, or to properly assist me in efforts to lawfully recover my stolen funds after the fraud occurred. 

Instead, Citi instituted an internal investigation which was specifically designed to cast blame on me an elderly customer while simultaneously covering up the banks failure to have reasonable and ordinary controls in place to prevent or at least mitigate elderly customers being defrauded. 

Citi declared itself blameless in a letter. The letter specified that if I wanted more information, I should call a specific phone number. 

When I call the number, it goes to a general call center which refuses to connect the customer to the fraud investigation department. I was forced to explain the situation to every new person and was transferred to XXXX or XXXX different departments, each of which said it couldnt help me. After XXXX hours on the phone, I was told that the fraud investigations department doesnt allow customers to contact them even with a case number, and individuals name. The Fraud Investigations Department would call me back in XXXX to XXXX hours instead. This of course never happened. 

Citi has in place a XXXX  system that makes it nearly impossible for a customer to dispute or elevate internally at Citi its internal investigation. This is clearly a systematic effort specifically designed to dissuade customers from being able to elevate their case internally at Citi. This is not an ordinary big bank run around, it is a feature purpose built by the bank which specifically is an extra burden on all customer but in particular the elderly and it is carefully crafted to try and make customers give up and not pursue even valid claims any further. 

Unfortunately, this leaves me with few options other than requesting through the CFPB that Citi reimburse me or if that fails file a class action lawsuit against Citi for its systematic failures to prevent XXXX  XXXX XXXX.