Consumer complaint received 2025-11-15 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Problem with a company's investigation into an existing problem — Difficulty submitting a dispute or getting information about a dispute over the phone
Company: AMERICAN EXPRESS COMPANY
State: NY

Complaint narrative:
[ XXXX, XXXX, XXXX, XXXX ] [ XXXX XXXX XXXX ] [ XXXXXXXX XXXX XXXX XXXXXXXX ] [ XXXX ] [ XXXX ] [ XX/XX/year> ] Consumer Financial Protection Bureau XXXX. XXXXXXXX XXXX XXXX XXXX XXXX XXXX RE : XXXX XXXX XXXX American Express XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Account Application : [ Ref number : XXXX ] Date of Application : [ XX/XX/year> ] To Whom It May Concern : I am writing to file a formal complaint against American Express ( Amex ) for violating multiple federal consumer protection laws and regulations during my application for a credit card/credit line on or about [ XX/XX/year> ]. 

My application was denied, or the credit line offered was insufficient, based solely on an automated decision. When I attempted to appeal this decision and speak with a human underwriter to discuss my application and provide additional information or context, American Express systematically refused my request. They stated that speaking with an underwriter was " not possible '' or " against their policy. '' This practice is a clear violation of my rights as a consumer under several key legal frameworks : 1. Violation of the Equal Credit Opportunity Act ( ECOA ) Regulation B The ECOA, implemented by Regulation B ( 15 U.S.C. 1691 et seq. ), guarantees consumers a right to a statement of specific reasons for any adverse action ( credit denial ). While a written adverse action notice was likely provided, the spirit of the law is to provide a meaningful opportunity for the consumer to understand and challenge the decision.

By refusing to allow me to speak with the individual ( s ) responsible for that decisionthe underwriterAmerican Express has rendered my right to a " statement of reasons '' meaningless. I am unable to clarify inaccuracies, present mitigating circumstances, or provide additional proof of creditworthiness, which undermines the entire purpose of the ECOA 's disclosure requirements.

2. Violation of the Fair Credit Reporting Act ( FCRA ) My creditworthiness was undoubtedly assessed using information from one or more consumer reporting agencies ( CRAs ). Under the FCRA ( 15 U.S.C. 1681 et seq. ), I have the right to accurate reporting. If the denial was based on information in my credit report, the refusal to let me speak with an underwriter prevents me from addressing potential inaccuracies in real-time, potentially forcing me into a more protracted dispute process with the CRAs.

3. Unfair, Deceptive, or Abusive Acts or Practices ( UDAAP ) The CFPB has authority to take action against Unfair, Deceptive, or Abusive Acts or Practices. American Express 's policy of using a " black box '' automated system and denying any human review is unfair. It causes substantial injury to consumers like me that we can not reasonably avoid, and this injury is not outweighed by any countervailing benefits to consumers or competition. It is abusive as it materially interferes with my ability to understand the terms and conditions of my credit application.

4. Principles of Good Faith and Fair Dealing under the Uniform Commercial Code ( UCC ) While the UCC ( adopted in some form in all 50 states ) primarily governs the sale of goods, its foundational principle of " good faith '' honesty in fact and the observance of reasonable commercial standards of fair dealingis a cornerstone of commercial law. A policy that deliberately shields its decision-makers from consumer interaction, preventing any form of dialogue or reconsideration, is the antithesis of good faith and fair dealing.

5. Contrary to the Fair Credit Billing Act ( FCBA ) and General Consumer Rights While the FCBA primarily addresses billing errors, it establishes a framework for communication and dispute resolution between creditors and consumers. American Express 's refusal to engage in basic communication regarding the underwriting of an application demonstrates a systemic failure to uphold its duty to communicate with its customers in good faith. 

My Attempt to Resolve This Issue : On [ XX/XX/year> or XX/XX/year> ], I called American Express at [ XXXX ] and spoke with representatives [ I do not remember the representative name at the time ]. I explicitly requested to be connected to an underwriter or a supervisor in the underwriting department to discuss my application. On each occasion, I was informed that this was " not possible, '' " against policy, '' or that no such direct line of communication exists for applicants.

Request for Relief : I believe American Express 's policies are in direct violation of federal consumer protection laws. Therefore, I request that the CFPB : 1. Investigate American Express 's policy of denying applicants access to human underwriters.

2. Require American Express to provide a meaningful review of my application by a human underwriter with whom I can communicate.

3. Require American Express to amend its policies to allow for direct communication with an underwriter upon consumer request following an adverse credit decision.

4. Hold American Express accountable for any and all violations of the ECOA, FCRA, and UDAAP provisions.

I have enclosed copies of the adverse action notice ( if received ), my application details, and any notes from my conversations with American Express representatives. 

Thank you for your attention to this serious matter. I expect a formal response from both the CFPB and American Express regarding the violations outlined in this complaint. 

Sincerely, [ XXXX, XXXX, XXXX, XXXX ] [ XXXX, XXXX, XXXX, XXXX ]

Company response to consumer: Closed with explanation