Consumer complaint received 2026-02-23 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Problem with a purchase shown on your statement — Credit card company isn't resolving a dispute about a purchase on your statement
Company: AMERICAN EXPRESS COMPANY
State: AR

Complaint narrative:
URGENT UPDATE Reliability of Merchant Representments in Question Following Arkansas Attorney General Inquiry This submission is provided as a supplemental update concerning procedural violations of the Fair Credit Billing Act ( 15 U.S.C. 1666 ) and Regulation Z ( 12 C.F.R. 1026.13 ) in connection with American Expresss handling of disputed transactions and subsequent reinstatement of those charges. This matter concerns : Failure to conduct a reasonable investigation ; Failure to provide a compliant written explanation under 1026.13 ( f ) ; Investigative misalignment with the defined dispute scope ; Improper reliance on a timing defense under 1026.13 ( b ) ( 1 ) ; Reinstatement of disputed debt without procedural compliance. In early XX/XX/year>, I submitted written billing-error notices identifying specific transactions and clearly defining the scope of the dispute. My notice raised XXXX XXXX XXXX ( XXXX ) classification concerns, transaction coding issues, and questions regarding the reliability of merchant representments. Despite the defined scope submitted in writing, American Express treated the matter as a limited fraud-style review and did not meaningfully address classification analysis or representment reliability concerns. The disputed charges were later reinstated without a compliant written explanation detailing investigative steps taken, evidence relied upon, or classification review performed, as required under 12 C.F.R. 1026.13 ( f ). Subsequent to reinstatement, the Arkansas Attorney Generals Office initiated inquiry activity involving XXXX of the merchants associated with the disputed transactions. Following that inquiry activity, both merchants retained outside legal counsel and initiated outreach seeking to discuss potential resolution of the matter. I did not solicit this outreach. I have not entered negotiations. I have not engaged in settlement discussions. I have expressly declined to participate in any settlement activity. This information is provided strictly for evidentiary purposes and must not be interpreted as evidence of consumer participation in merchant negotiations. The relevance of this development is procedural. If American Express relied upon merchant representments in determining that no billing error occurred, the subsequent Attorney General inquiry and retention of outside counsel materially affect the reliability of those representments and warrant reassessment under the reasonable investigation standard of Regulation Z. Additionally, American Express has rejected or dismissed dispute submissions on the basis that they are allegedly over 60 days old. While Regulation Z contains a XXXX written notice provision under 1026.13 ( b ) ( 1 ), that provision limits certain automatic protections. It does not prohibit investigation of disputes submitted beyond that period, nor does it excuse reinstating disputed debt without providing a compliant written explanation once review has occurred. Where provisional credits were issued and charges were subsequently reinstated, the investigative obligations under 1026.13 ( f ) remain operative. Because this submission is made through a public-facing regulatory portal, the names of the merchants referenced above have been intentionally withheld from this filing. This omission is deliberate and solely for XXXX reasons. Merchant identities, redacted documentation, and supporting correspondence can be provided under appropriate confidential circumstances upon formal request. Under Regulation Z, the burden to conduct a reasonable and independent investigation rests entirely with the issuer. The statute does not shift responsibility to the consumer to negotiate with merchants, validate merchant responses independently, or resolve disputes outside the statutory framework. I respectfully request supervisory review to determine whether American Express satisfied its obligations under 12 C.F.R. 1026.13 before reinstating the disputed amounts. My preference remains voluntary remediation consistent with the Fair Credit Billing Act and Regulation Z.

Company response to consumer: Closed with explanation