Consumer complaint received 2023-06-27
Product: Credit card or prepaid card — General-purpose credit card or charge card
Issue: Getting a credit card — Application denied
Company: WELLS FARGO & COMPANY (WA)

Letter to Wells Fargo describing ongoing interactions when I tried to determine why I was denied a credit card with a XXXX score of XXXX. I never received a clear explanation. The reasons given were unsupportable and I believe I was rejected as a business decision not likely to generate interest/late charges. As follows : XX/XX/2023 Wells Fargo Enterprise Complaints Management Office XXXX XXXX  XXXX XXXX XXXX, SD XXXX Subject : Response to Letter Communication of XX/XX/2023 Case Number : XXXX Dear Staff : Thank you for responding to my inquiry regarding your decision to reject my credit card application. However, I find your response insufficient and perhaps even misleading on several points. While I provide the detail below, I respectfully suggest you review more closely the transcript of my conversation on XX/XX/2023 with a representative from the XXXX XXXX. The gentleman with whom I spoke was highly professional and appeared to be listening intently as I explained my inability to understand, in a clear manner, the application rejection. Apparently however and as I read your letter, some misunderstanding and/or a level of miscommunication occurred during the conversation. 

As my first example, I refer to your letter and the statement on discrimination, ... Based on this research, there was no evidence to support this claim. I am assuming here you are submitting that I made a claim of discrimination and that this occurred during my discussion with the representative. To be very clear, I never made a statement that Wells had discriminated against me by rejecting my credit card application. As I recall the conversation, which was moving along in a fully civil and not unpleasant manner, I specifically noted, ( and as I understand it ), providing credit is basically a function of risk. With an outstanding XXXX  score of XXXX, openly acknowledged by Wells in their rejection letter, I was totally unable to understand an underlying, and yes even a logical basis, for rejecting my application. As we continued our conversation, I brought forward my assumption that the rejection was based not on risk, but rather based on a business decision by Wells. With the gentleman appearing to be listening and seemingly following my thinking, I added that perhaps this could be thought of perhaps some discrimination based on age, though obviously indirect rather than direct. ( The recording should confirm that I made the point of indirect rather than direct discrimination ). I believe I even proposed a possible profile of myself where I would be seen as a customer that Wells would not necessarily be seeking. In effect : elderly retiree, limited use of current credit cards/lack of major purchases, seemingly of low/limited income, etc. Indeed, I noted that this would be close to my actual profile but also that Wells would have no ability ( or so I thought ) to know anything about my personal savings/investments, family gifts, etc., that are informative as to how I manage my daily living expenses.

In effect then, I was speculating that Wells had declined my application based not on risk, technically supported by my XXXX  scores, but on my profile of limited use of my credit relative to what the more typical customer, fully employed, and of working age, who not only use credit cards extensively but typically pay interest and perhaps even incur late payment charges. In effect, generate higher levels of revenue to Wells. Clearly I do not fit that profile. 

The second issue relates to my request to provide clarification as to the reasons cited in your rejection letter. In all communication with you, both by phone and in writing, you failed to provide any further explanation. As per all of your written communication, you offered the following reasons : To wit : 1 ) ratio of credit bureau trades with a balance greater than zero ( we look at the ratio of open and closed credit amounts that have a balance greater than zero in the last 6 months. 
My Response : I pay full balance on all credit cards where interest may ensue. When I have an interest- free period, I may utilize some small balances. I believe I have had no outstanding balances whatsoever in the past six months. Therefore, your statement is neither supportable, nor even logical. 

2 ) Number of revolving bankcards reported by credit bureau. ( We look at the number of bank credit cards in your credit bureau report ).

My Response : I discussed this with the executive representative. I have a number of cards which remain open but I do not use. I was under the common understanding that one should not close unused cards as open cards with access to credit amounts are looked upon favorably by lenders. I seem to recall that the representative concurred and found this reason as well to be unclear. Once again, I believe this statement is not supportable. 

In your last and final communication, in addition to restating the above reasons, you now include the following : credit history, income, amount of credit and relationship history, but again fail to be specific. 
My Response : My credit history is impeccable. Being quite XXXX, I am XXXX  with a social security income. I have not provided Wells ( Nor was I requested to do so ) with my personal savings and investment amounts. Surely, as with most retirees I draw upon these amounts for living expenses. 

In conclusion, I believe that my application for a credit card was denied, not based on a credible, credit risk assessment, but rather on a business decision by Wells Fargo. With a XXXX  score of XXXX, and absolutely no filings whatsoever indicating that credit was misused due to late payments, large or even multiple outstanding balances, or other related negative findings, a true credit risk clearly was not substantiated. Rather, a profile was established of an elderly retired person who makes limited use of large credit purchases, and virtually never incurs interest charges. While a claim of discrimination was never made, a case is conceivable for indirect discrimination of a retiree who is not likely to provide Wells Fargo with increased revenue based on interest charges or late payments. 

Furthermore, virtually no online marketing material for a Wells Fargo credit card includes any indication that credit may be denied even if the individual possesses an extensive and virtually unmarked credit history accompanied by an extremely high XXXX  score. This is misleading at best and when a customer makes an application within this type of scenario, denial is not only made but the hard inquiry impacts the overall credit score negatively. Based upon the Wells Fargo decision to deny credit, which I believe to be fully unsubstantiated, I will forward all materials in a formal complaint to the Consumer Protection Bureau. On principle alone, I believe the complaint is not only justified but quite possibly suggests regulatory violations for consumers. 

Sincerely,