Consumer complaint received 2024-04-25
Product: Credit card — General-purpose credit card or charge card
Issue: Getting a credit card — Application denied
Company: NAVY FEDERAL CREDIT UNION (IL)

This correspondence serves as my official notice of intent to dispute and if needed pursue litigation against Navy Federal Credit Union for their failure to adhere to fair and equal lending practices, resulting in the

violation of several of my fundamental consumer rights as outlined in The Equal Credit Opportunity Act, The Truth in Lending Act, and various other consumer protection statutes. I put in an application for a Navy Federal Card that I prequalified for. I was then notified that they needed my XXXX tax returns in order to process said application. I put in and was granted an extension request from the IRS for my taxes this year due to me being out of country. I first contacted them on it XX/XX/XXXX after they sent the verification email. When I spoke to Navy Federal they at first attempted to file an extension request, but could not extend it out until my listed return date of XX/XX/XXXX. I informed that that I could file my taxes but I was missing a W2 form that was mailed from a now defunct employer for contract work, which was mailed to me. They claimed on XX/XX/XXXX that they had no other way of verifying my income. I contacted both the IRS and all three credit bureaus and was advised by all entities almost uniformly that this was not accurate, and that Navy Federal, like most creditors, had to provide reasonable accommodation due to my approved extension request. The IRS themselves, although could not give me legal advice, strongly advised me against rushing to file my taxes with incomplete or missing information. I then contacted them back on XX/XX/XXXX, on a recorded line, where an agent informed me she did not know why I was communicated that information and that Navy Federal 's underwriting department frequently used previous years W2 's, ( as far back as XXXX years in some cases ) to verify income, particularly when an application is filed so close to tax day. She told me to submit my XXXX W2 's, alongside an explanation of what happened and they would accept it. I did and it was an almost automatic denial. 

The next day on XX/XX/XXXX I managed to get someone to go over to my house to grab said form and had my taxes filed and submitted. I contacted all three credit bureaus and the IRS again and was told that if the reason was due to income verification, not income debt to income ratio, that Navy Federal violated several consumer protection laws by not providing reasonable or adequate accessibility and accommodation for my circumstances, misrepresented what materials could be provided and they had accepted for other members, and purposefully mislead me in the application process. I contacted their credit department and asked for an escalation on that date.

I spoke specifically with their credit and lending department on this date and asked for a full explanation as to why I had been denied. They said they had sent the denial letter, which upon review does not actually state the specifics that I requested in writing and was told there was no way for them to email the form, even though I had made Navy Federal aware I was not in the country so had no way to access the form to file a dispute. I was highly discouraged from escalating, told they couldn't provide any information, yet when I directly questioned them about why I had been informed that they could accept my XXXX W2s, where my income is not dramatically different and would still more than qualify me, they claimed that Navy Federal did make exceptions and the agent did not know what was missing from the income verification. When I did further research I found that according to CFPB guidelines, I have a right to receive correspondence and decisions in my preferred method of communication, which I had told them multiples times was through their email portal. When I called and informed them of regulatory requirements, they magically managed to find a way to send this letter, after threat of a lawsuit and me citing directly where they were violating my consumer rights. This has become a a common theme of this organization doing this including : Right to Fair and Equal Lending Practices : My credit score is XXXX, I have XXXX hard inquiry, and XXXX years of on time payments, and low credit utilization. This is discriminatory Navy Federal 's decision to deny my credit application based on income verification contradicts the principle that creditors must not discriminate in extending or withholding credit based on factors such as income, credit history, or other pertinent characteristics. Both my documented income for XXXX and XXXX, alongside a commendable credit score and a proven track record of responsibly managing multiple credit accounts, clearly qualify me for the credit card in question. Additionally, recorded conversations with

Navy Federal 's credit department confirm exceptions to income verification protocols, highlighting the arbitrary nature of my denial. Right to Fair and Transparent Terms of Lending Practices : Navy Federal 's initial assurance regarding the sufficiency of my XXXX W-2 for income verification, followed by a subsequent denial citing an alleged inability to utilize said documentation, constitutes a deliberate misrepresentation of the credit determination process, contravening relevant consumer protection statutes. 

Right to Equitable and Transparent Access by Lenders : Navy Federal 's additional justification for denial based on the recent opening of my account further violates my entitlement to equitable and transparent access to credit. Regulatory protocols dictate that personal banking relationships can not be leveraged to assess creditworthiness for credit card applications, even through the banks. Moreover, my extensive credit history spanning over XXXX  years, characterized by punctual payments, underscores my creditworthiness. 

I have requested in writing these things : - Point of contacts for Navy Federal 's underwriting and legal department, so if I need to file additional litigation I can. They have refused to provide this information after being asked in writing.

- A comprehensive explanation as to the denial process, including which departments worked on the application, why I was advised incorrectly, and a reconsideration request. They have refused to provide this information after being asked in writing.

- - A comprehensive explanation as to the denial process, including which departments worked on the application, why I was advised incorrectly, and a reconsideration request. They have refused to provide this information after being asked in writing.

- A list of materials that Navy Federal underwriters use to verify income. They have refused to provide this information after being asked in writing.

- Notations listed on the account from all correspondences and departments over this incident. They have refused to provide this information after being asked in writing.

- The contact information for Navy Federal 's legal and underwriting departments to escalate my complaint to court. They have refused to provide this information after being asked in writing.

Failure to provide this information, not the notice letter, now that you have been informed in writing is a violation of my consumer protections. Just like you all claiming that you could not send out the denial or notice letter virtually, ( on a recorded line ), after being requested, and then after being notified that not providing that information in an accessible way was a violation, was also.

In light of these violations, I wrote them on XX/XX/XXXX to demand a thorough explanation of the denial process, including the specific departments within Navy Federal involved, and contact details for direct communication with Navy Federal 's legal, lending, and underwriting departments, preferably via email or messaging. They have not, contrary to CFPB standards, provided this information as of today 's date.