Consumer complaint received 2020-04-13
Product: Credit card or prepaid card — General-purpose credit card or charge card
Issue: Other features, terms, or problems — Other problem
Company: AMERICAN EXPRESS COMPANY (CA)

TABLE OF CONTENTS OF 11-PAGE LETTER OF COMPLAINT TO CFPB & FTC XX/XX/XXXX ( Attached ) Re : Non-bank Lender AMERICAN EXPRESS ( a ) systematically, deliberately and wilfully BREACHED the covenant of good faith and FAIR DEALING, ( b ) ABUSIVELY interpreted vague contract it drafted, ( c ) UNJUSTIFIABLY modified contract thereby INJURING borrowers, ( d ) all the above being UNFAIR TRADE PRACTICES as well. 

( 1 ) CIRCUMSTANCES AND EQUITY ( 1a ) Covenant of Good Faith and Fair Dealing ( 1b ) Abusive Interpretation of Contract it Drafted ( 1c ) Unjustified Modification of Contract ( And Pretext to Cover-up Breach of Covenant and Abusive Interpretation of Vagueness From/by Drafter of Contract ) ( 1d ) A Lender Can not Assess Late Fees Resulting from its Own Inequitable Action ( 2 ) THE FACTS ( 2a ) The Contract ( 2b ) Breach by American Express of the Covenant of Good Faith and Fair Dealing ( 2c ) Abusive Interpretation of Vagueness of Contract by Drafter Thereof ( American Express ) ( 2d ) Unjustified Modification of Contract ( 2e ) A Lender Can not Assess Late Fees Resulting from its Own Inequitable Action ( 3 ) GENERALITY OF BREACH RELEVANT TO FORM AND EXTENT OF REMEDIES ( 3a ) Other Types of Contract ( 3b ) The Concept of Maximal Benefit. 
( 3c ) Generality of Breach ( 3d ) For Whom and When Can Minimum % of Balance and Minimum Dollar Amount Be Raised? 

( 4 ) TRANSLATION TO THE LEGAL FRAMEWORK OF THE CONSUMER FINANCIAL PROTECTION ACT OF 2010 [ CFPA ] AND FEDERAL CONSUMER FINANCIAL LAW ( 4a ) CFPA 1031 [ 12 U.S.C. 5531 ] quantifies ( i ) unfairness, ( ii ) abuse ( including deception or fraud ) ( 4b ) Breach of the covenant of good faith and fair dealing inherent in any contract ( 4c ) Abusive interpretation of vagueness of contract by drafter/lender thereof ( American Express ) ( 4d ) Modification of the contract ( 4e ) The two-fold inequity of lender ( 5 ) INJURIES ( 6 ) REMEDIES ( 6a ) For the Type/class of Contract Herein ( 6b ) Generality ( 6c ) Practicality ( 6d ) Specific Remedies ( 6d-i ) CFPB and FTC can and should require AMERICAN EXPRESS to revert the cycle minimum dollar amount retroactively from {$39.00} to {$15.00}, the cycle minimum dollar amount applicable on XX/XX/XXXX or any earlier and lower cycle minimum dollar amount of any EXTANT time-limited promotional interest rate contract. 
( 6d-ii ) All credit card accounts affected and impacted by the raise ( s ) in the cycle minimum dollar amount or any raise in the cycle minimum % of balance should be corrected to reverse all late fees, etc.. 
( 6d-iii ) All interest rates should be retroactively restored to their contracted levels before any raise in the cycle minimum dollar amount or any raise in the cycle minimum % of balance, etc.. 
( 6d-iv ) All negative credit reports or notices by AMERICAN EXPRESS or its card ( s ) co-labelers to any and all credit report bureaux, agencies or otherwise should be retracted immediately and retroactively etc.. 
( 6d-v ) AMERICAN EXPRESS shall request similar retraction and retroactive re-computation of credit scores and pay for the expense etc.. 
( 6d-vi ) Under their enforcement authority, CFPB and FTC should consider issuing a letter of reprimand against AMERICAN EXPRESS, and send a copy of such letter to each and every credit report bureau, mandating them to etc. ... The credit reporting bureaus should also be instructed to forward a copy of that letter to any and all credit scoring agencies making use of credit data from the credit reporting bureaus and additionally etc. ... These requirements shall remain until American Express certifies and shows to the satisfaction of CFPB and FTC that all the remedies requested herein have been completed and all borrowers affected have been made whole in their accounts, in their credit reports, in their credit scores, and otherwise. 

( 7 ) EPILOG