Consumer complaint received 2026-03-31 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Problem using a debit or ATM card
Company: CITIZENS FINANCIAL GROUP, INC.
State: FL

Complaint narrative:
CONSUMER FINANCIAL PROTECTION BUREAU FORMAL COMPLAINT Filed Pursuant to 12 U.S.C. 5531 and Regulation E ( 12 C.F.R. Part 1005 ) I. PARTIES AND ACCOUNT INFORMATION Complainant : XXXX XXXX XXXX XXXXXXXX XXXX Citizens Bank , N.A. Product : Consumer checking account with linked debit card Date of Incident : XX/XX/year> Amount in Dispute : Approximately {$8700.00} ( representing approximately 95 % of the total account balance ) Branch Where Fraud Occurred : Citizens Bank, XXXX XXXX XXXX XXXX XXXX, XXXX XXXXXXXX XXXX XXXX. SUMMARY OF COMPLAINT This complaint is filed against Citizens Bank , N.A. for its failure to comply with the Electronic Fund Transfer Act ( EFTA ), 15 U.S.C. 1693 et seq., and its implementing regulation, Regulation E, 12 C.F.R. Part 1005, in connection with its denial of a fraud claim involving unauthorized electronic fund transfers totaling approximately {$8700.00}. On XX/XX/year>, XXXX separate unauthorized transactions were conducted at the Citizens Bank XXXX XXXX XXXX in XXXX XXXX, XXXX. The complainant did not authorize, conduct, or benefit from any of these transactions. The complainant was at her home at the time of the transactions, caring for her XXXX children, including a newborn. Citizens Bank denied the fraud claim without adequate investigation, in apparent violation of its obligations under Regulation XXXX. XXXX. FACTUAL BACKGROUND A. Account Transfer and Card Issuance The complainants account was transferred to Citizens Bank from a prior institution. Following the transfer, Citizens Bank issued a new debit card linked to the account. This card was intercepted before it was received by the complainant. The complainant never received, activated, or used the card in question. B. The Unauthorized Transactions On XX/XX/year>, XXXX separate fraudulent withdrawals were executed at the Citizens Bank branch located at XXXX XXXX XXXX XXXX XXXX, XXXX XXXX, XXXX. The combined total of these transactions was approximately {$8700.00}, which represented approximately 95 % of the complainants entire account balance. The complainant was not present at the branch, was not in the vicinity, and had no knowledge of the transactions until after they occurred. XXXX Claim Denial and Lack of Adequate Investigation The complainant promptly reported the unauthorized transactions and filed a fraud claim with Citizens Bank. The bank denied the claim. Upon information and belief, the denial was based solely on the fact that the transactions involved a validly issued card and a correct PINfactors that are insufficient under federal law to establish that the transactions were authorized by the account holder. Citizens Bank failed to provide provisional credit as required under Regulation XXXX and failed to conduct an adequate investigation into the circumstances of the fraud. XXXX Police Report A police report has been filed with the XXXX XXXX Police Department documenting the unauthorized transactions. The report is available upon request. IV. LEGAL BASIS FOR COMPLAINT A. Regulation E Unauthorized Electronic Fund Transfers Under Regulation E, 12 C.F.R. 1005.2 ( m ), an unauthorized electronic fund transfer is a transfer initiated by a person other than the consumer without actual authority to initiate the transfer and from which the consumer receives no benefit. The transactions at issue meet this definition in full : they were initiated by an unknown third party who intercepted the complainants debit card ; the complainant did not authorize the transactions ; and the complainant received no benefit. B. Burden of Proof Rests with the Financial Institution Under 12 C.F.R. 1005.6 ( b ) ( 3 ) and the Official Staff Commentary, the burden is on the financial institution to demonstrate that a transaction was authorized. The mere fact that a valid card and correct PIN were used does not, standing alone, establish authorization. The Consumer Financial Protection Bureau has consistently held that card present and correct PIN are not sufficient bases to deny a fraud claim. A card that was intercepted in the mail and used by a third party is a textbook case of an unauthorized XXXX, regardless of whether the XXXX was compromised through social engineering, interception, or other means. XXXX Failure to Provide Provisional Credit Under 12 C.F.R. 1005.11 ( c ) ( 2 ), a financial institution that is unable to complete its investigation within XXXX business days must provisionally credit the consumers account for the amount of the alleged error. Upon information and belief, Citizens Bank failed to provide provisional credit within the required timeframe, compounding the financial harm to the complainant and her family. XXXX Failure to Conduct Adequate Investigation Regulation E requires that institutions conduct a reasonable investigation of error claims. An adequate investigation in this case would include, at minimum : review of surveillance footage from the XXXX XXXX branch at the time of the transactions ; analysis of card activation and usage records to confirm the complainant never activated or previously used the card ; comparison of the complainants location data or other evidence establishing she was not present at the branch ; and coordination with law enforcement. Upon information and belief, Citizens Bank failed to undertake these basic investigative steps before denying the claim. V. HARM TO THE CONSUMER The denial of this fraud claim and the loss of approximately {$8700.00} has caused severe financial and emotional harm to the complainant and her family. XXXX XXXX is a mother of XXXX children, including a newborn. The stolen funds represented nearly the entirety of the account balance. The family has endured more than a month of repeated denials and delays from Citizens Bank, during which the financial strain has been acute. The emotional toll of having nearly all available funds stolenand then being told by the bank that the claim is deniedwhile caring for a newborn and XXXX other children can not be overstated. VI. RELIEF REQUESTED The complainant respectfully requests that the Consumer Financial Protection Bureau XXXX Citizens Bank to take the following actions : XXXX. XXXX reimbursement of the full {$8700.00} in unauthorized withdrawals, plus any associated fees or charges incurred as a result of the unauthorized transactions. XXXX. Full internal review and reconsideration of the denied fraud claim, conducted in compliance with XXXX XXXX investigation requirements. XXXX. Retrieval and preservation of all surveillance footage from the Citizens Bank XXXX XXXX branch ( XXXX XXXX XXXX XXXX XXXX, XXXX XXXX, FL ) for the dates and times corresponding to the XXXX unauthorized transactions. XXXX. Full cooperation with law enforcement to identify and apprehend the individual ( XXXX ) responsible for the card interception and unauthorized withdrawals. XXXX. Confirmation of compliance with XXXX XXXX provisional credit and investigation timeline requirements, and an explanation of the basis for the denial. XXXX. XXXX review of Citizens Banks fraud investigation procedures to determine whether the institutions practices constitute a pattern of Regulation XXXX violations. XXXX. ADDITIONAL REGULATORY CONTEXT The complainant notes that this matter XXXX also warrant review by the XXXX XXXX XXXX Comptroller of the Currency ( XXXX ), as the primary federal regulator of Citizens Bank , N.A. The fact pattern described hereincard interception, non-receipt fraud, denial based solely on card-present and PIN-match criteriareflects practices that the CFPB and XXXX have XXXX as XXXX in prior enforcement actions and supervisory guidance. The complainant reserves the right to file parallel complaints with the XXXX and the relevant state banking regulator. Respectfully submitted, ________________________________________ On behalf of XXXX XXXX XXXX : _______________ Attachments ( to be provided upon request ) : Police report filed with XXXX XXXX Police Department ; account statements reflecting the unauthorized transactions ; correspondence with Citizens Bank regarding the denied fraud claim.

Company response to consumer: Closed with monetary relief