Consumer complaint received 2025-06-03 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Installment loan
Issue: Problem when making payments — 
Company: Affirm Holdings, Inc
State: TX

Complaint narrative:
Complaint Against Affirm , Inc. and XXXX XXXX XXXX for Violations of the Fair Credit Billing Act ( FCBA ), Texas Deceptive Trade Practices Act ( DTPA ), and CFPB Guidelines Summary of Issue I am filing this complaint against Affirm , Inc. and XXXX XXXX XXXX regarding a misrepresented educational service and Affirms subsequent failure to uphold its obligations under the Fair Credit Billing Act ( 15 U.S.C. 1666 et seq. ) and Consumer Financial Protection Bureau ( CFPB ) regulations. 
XX/XX/XXXXXXXX  - Affirm financed my purchase of a {$3100.00} course titled the XXXX XXXX XXXX XXXX from XXXX XXXX XXXX XXXX The merchant failed to deliver substantial portions of the promised services, including live instruction, one-on-one coaching, pertinent documents, and access to course content for the advertised duration. In fact, I was blocked from the course entirely after inquiring about missing components. 
This constitutes misrepresentation and nondelivery of services, which is explicitly covered under the FCBA as grounds for a billing dispute ( 15 U.S.C. 1666i ). 

Timeline of Events I contacted the merchant multiple times between XX/XX/XXXX, XXXXXXXX XXXX XXXX regarding the missing components and was met with silence and was ultimately blocked from access on XX/XX/XXXX. 
I initiated a formal billing dispute with Affirm on XX/XX/XXXX. 
Affirm denied the first dispute based solely on a delivery receipt for a promotional XXXX XXXX, which was not the product I financed. 

I submitted a second dispute on XX/XX/XXXXXXXX  with additional evidence, including : ~Screenshots of missing or inaccessible course content ~A communication from the merchant promising to send the missing documents, which she never fulfilled ~Communications showing canceled one-on-one coaching ~A copy of the merchants own contract clearly showing obligations that were not fulfilled Despite this, Affirm denied my second dispute on, explicitly stating that they defer entirely to the merchants refund, return, and cancellation policy. 
Affirm wrote : As such, we must adhere to all refund, return and cancellation policies of the merchant. You are still responsible for making all remaining payments on this loan unless a full refund is issued by the merchant. 

A third dispute was requested through a conversation with Customer Service Supervisor XXXX on XX/XX/XXXX. He stated that he would escalate the dispute. At this time, I also requested a copy of the merchants submitted evidence, pursuant to CFPB guidance and Regulation Z. 
The third dispute was closed, again citing : As such, we must adhere to all refund, return and cancellation policies of the merchant. You are still responsible for making all remaining payments on this loan unless a full refund is issued by the merchant. 
The requested evidence was never provided. 

A fourth dispute was initiated via a written request to Affirms legal department on XX/XX/XXXX, specifically requesting the merchants evidence and a fair investigation. That dispute was also denied, with Affirm stating : After looking into your account, it appears that your dispute for this loan has already been closed in favor of XXXX XXXX XXXX as the merchant provided evidence indicating that the service was provided. 
Please keep in mind that Affirm manages the financing of your purchase. As such, we must adhere to all refund, return and cancellation policies of the merchant. You are still responsible for making all remaining payments on this loan unless a full refund is issued by the merchant. 

These responses contradict Affirms obligations under federal law, specifically : Legal Violations 1. Violation of the Fair Credit Billing Act ( 15 U.S.C. 1666 & 1666i ) : Affirm is obligated to conduct a reasonable, independent investigation into disputes involving billing errors, including nondelivery of services. Instead, Affirm deferred entirely to the merchants internal policy, abdicating its responsibility. 
A creditor may not treat a disputed amount as owing while the investigation is pending. ( 15 U.S.C. 1666a ) Affirms failure to conduct a reasonable investigation, its reliance on the merchants internal policy, and premature dispute closure all while continuing to bill me violate this provision.

2. Violation of FCBA Procedural Rights ( 12 CFR 1026.13 ) : Under Regulation Z, Affirm must provide : ~A written explanation of dispute results ~Disclosure of supporting evidence ( upon request ) I formally requested this evidence via letters to the legal department , communications with customer service, and during a phone call with Supervisor XXXX on XX/XX/XXXXXXXX  @ XXXX XXXX. I was never granted access to the merchants submitted evidence, violating 12 CFR 1026.13 ( c ) ( 3 ).

3. Violation of Texas Deceptive Trade Practices Act ( Tex. Bus. & Com. Code 17.46 ) : XXXX XXXX XXXX  actions constitute : ~False advertising ~Breach of contract ~Misrepresentation of services Specifically, the merchants conduct falls under violations outlined in 17.46 ( b ), including : 17.46 ( b ) ( 5 ) Representing that goods or services have sponsorship, approval, characteristics, ingredients, uses, benefits, or quantities which they do not have ; 17.46 ( b ) ( 7 ) Representing that goods or services are of a particular standard, quality, or grade when they are of another ; 17.46 ( b ) ( 24 ) Failing to disclose information concerning goods or services which was known at the time of the transaction, if such failure was intended to induce the consumer into a transaction they would not have entered had the information been disclosed. 
This conduct violates Texas consumer protection law and renders the sale invalid. As the lender, Affirm holds liability for financing a fraudulent or unlawful sale under 15 U.S.C. 1666i ( b ). 

CFPB Guidelines Violated The CFPB requires lenders to : ~Protect consumers from unfair billing practices ~Conduct fair dispute resolution ~Disclose key evidence in disputes upon request Affirm failed on all three counts, undermining confidence in digital financing platforms and violating consumers ' rights. 

Relief Requested I respectfully request the CFPB to : ~Investigate Affirms dispute-handling process for violations of the FCBA and Regulation Z ~Compel Affirm to : ~Refund the {$3100.00} for the undelivered services ~Provide full transparency by releasing the merchants evidence to me ~Cease requiring further payments on this loan until a lawful, complete review is conducted ~Examine whether Affirms systemic dispute practices violate CFPB compliance standards Next Steps If Affirm fails to provide a satisfactory resolution within 30 days, I intend to : ~File a formal complaint under the Texas XXXX ~Initiate legal action in small claims court ~Report this matter to additional regulatory bodies, including the Texas Attorney General and the FTC This is not just a matter of poor service it is a systemic failure by a lender to follow federal law. Affirm allowed the merchant to dictate the outcome of a billing dispute without due process, independent review, or disclosure. I urge the CFPB to intervene, hold Affirm accountable, and restore consumer protections guaranteed under the Fair Credit Billing Act.

Company response to consumer: Closed with explanation