Consumer complaint received 2024-10-21
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Problem with a company's investigation into an existing problem — Their investigation did not fix an error on your report
Company: CNG FINANCIAL CORPORATION (MI)

Thank you for forwarding the response from XXXX XXXXXXXX XXXX  ( XXXX ) regarding the XXXX XXXX dispute. After reviewing their letter, I must say, it's truly remarkable how they managed to craft such a lengthy response without addressing any of the actual concerns raised in my complaint. Let 's break down this masterpiece of misdirection and selective amnesia, shall we? 

1. Predatory Interest Rates : " Perfectly Legal '' Doesnt Mean Ethical XXXX  smugly quotes 12 U.S.C . 1831d, which allows them to export Utahs obscenely high interest rates across state lines. How fortunate for them! However, Im more concerned about the fact that the Annual Percentage Rate ( APR ) of XXXX  % is grossly predatory, bordering on usurious, even if technically permissible under federal law. The audacity to claim this loan was designed to " help consumers build credit '' is laughable. With rates that high, its designed to bury consumers under a mountain of debt. 

Moreover, while they can lean on Utah 's laws all they like, Michigans usury lawsMich. Comp. Laws 438.31still apply when addressing loans made to Michigan residents. Just because they found a loophole doesnt absolve them from the clear ethical breaches involved in charging such egregious rates.

2. Debt Validation : A Conveniently Glossed-Over Investigation XXXX XXXX claim that I have no grounds to question the legitimacy of the loan because they " emailed '' me the documents is truly a stroke of genius. Clearly, the burden of proof in their world starts and ends with hitting " send '' on an email. 15 U.S.C. 1681i ( Fair Credit Reporting Act ) requires a thorough investigation, and guess what? That means more than a vague reference to Multi-Factor Authentication ( MFA ) and no proof that I, in fact, received, reviewed, or agreed to any of these terms.

They claim I " didnt raise any concerns '' with the previous loansperhaps thats because I hadnt yet realized I was being swindled. Nice try, though.

3. FDCPA & TILA : Twisting the Law for Convenience Oh, how generous of XXXX  to remind me that they are not a " debt collector '' under the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692. Perhaps they missed the part where the FCRA, 15 U.S.C. 1681 governs how they report these loans, regardless of whether they play the original creditor card. Their feigned ignorance of the fact that they are still bound by consumer protection laws is either a testament to their laziness or a strategic attempt to skirt accountability.

As for Truth in Lending Act ( TILA ), 15 U.S.C. 1601, they proudly state they provided all necessary disclosures. The problem, of course, is that shoving legally mandated fine print into an email doesnt automatically mean those disclosures were properly conveyed or understood. But sure, lets just pretend that mass emailing a PDF is an act of full compliance. Perhaps next time they could just send it via carrier pigeonsame difference, right?

4. ACH Revocation : Hidden Clauses and the Fine Art of Buried Information Their explanation about how I could revoke Automatic Clearing House ( ACH ) payments would be almost comical if it werent so blatantly evasive. They mention its hidden in the fine print somewhere in the Method of Repayment section. How convenient. Maybe I shouldve taken a magnifying glass to the agreement? Clearly, the onus is on me to sift through their deliberately obscure contract terms to find out how to stop payments that I allegedly authorized. Thanks for that helpful tip!

5. Predatory Lending Practices : An Attempt to Dress Up Exploitation Their closing remarks about how this loan was designed to " help '' people with poor credit is touching. Im sure offering loans with interest rates upwards of XXXX % is really the best way to give consumers a fresh start. In reality, this loan is designed to trap individuals in a vicious cycle of debta point XXXX conveniently forgets to mention while patting themselves on the back for offering " credit-building opportunities. '' Its worth pointing out that 12 U.S.C. 1831d doesn't give them carte blanche to gouge consumers into oblivion. Predatory lending is predatory lending, no matter how they try to dress it up in legalese. 

Demand for Action : Removal of Negative Reporting and Sanctions Given the lack of verification and the blatant violations of both the Fair Credit Reporting Act and other applicable laws, I demand that all negative entries related to this loan be removed from my credit report immediately. The information reported is not only inaccurate but has also been reported without the required validation of debt, in direct violation of my rights.