Consumer complaint received 2025-09-19 00:00:00
Product: Checking or savings account — Other banking product or service
Issue: Opening an account — Unable to open an account
Company: BANK OF AMERICA, NATIONAL ASSOCIATION
State: GA

Complaint narrative:
Bank of America Complaint ( Expanded with Federal Law Citations ) From : XXXX XXXX XXXX XXXX XXXX Executive Trustee / Fiduciary / Secure Party Creditor Irrevocable Private Common Law Trust Organization To : Office of the Comptroller of the Currency ( OCC ) Consumer Financial Protection Bureau ( CFPB ) XXXX XXXX XXXX XXXX XXXX XXXX Subject : Complaint Against Bank of America Private Bank XXXX XXXX GA ( XXXX XXXX XXXX XXXX XXXX XXXX GA XXXX XXXX Date : XX/XX/XXXX Summary of Complaint On XX/XX/XXXX, I visited Bank of America Private Bank in XXXX, GA ( XXXX XXXX location XXXX to open a trust account for the XXXX XXXX XXXX XXXX XXXX ( Irrevocable Private Common Law Trust Organization ). 

I was denied service by XXXX XXXX XXXX, Officer Market Financial Center Manager, Georgia XXXX XXXX, who stated : 1. Bank of America does not open common law irrevocable trust organizations.

2. My account could not be opened because of the language contained in my Affidavit of Truth and Status, which lawfully affirms my nationality. 

This is discriminatory, inconsistent, and arbitrary. I had previously opened an account at the same branch with the same type of trust documentation. 



Issues Raised Inconsistency & Arbitrary Refusal Bank of America allowed my trust account previously, but now denies it without citing policy. 
Racial Profiling & Fiduciary Discrimination XXXX XXXX denial targeted me because of my lawful nationality declaration and fiduciary status. 
Disrespect Toward Fiduciary Authority As a Secure Party Creditor, Fiduciary, and Executive Trustee, my lawful authority was disregarded. 
Failure to Cite Policy or Law No written Bank of America policy, OCC regulation, or CFPB rule was provided. 



Federal Law Violations The conduct of Bank of America and its officer, XXXX XXXX XXXX, appears to violate the following federal protections : 1. Equal Credit Opportunity Act ( ECOA ), 15 U.S.C. 1691 ( a ) : Prohibits discrimination in banking services on the basis of race, national origin, or the exercise of lawful rights.

2. Civil Rights Act of 1964, Title II ( 42 U.S.C. 2000a ) : Prohibits discrimination in places of public accommodation, including banks.

3. Fair Housing Act ( 12 U.S.C. 3605 ) : Extends nondiscrimination requirements to lending and financial practices. 
4. OCC Regulations ( 12 C.F.R. 30, Appendix C ) : Require banks to maintain compliance and fair treatment of customers. 

By refusing my trust account based on my nationality declaration and fiduciary status, Bank of America has engaged in racial profiling, fiduciary discrimination, and denial of lawful financial services. 



Requested Relief 1. A formal investigation into Bank of America XXXX branch ( XXXX XXXX location ). 
2. A written explanation of the specific law, regulation, or policy used to deny my trust account.

3. Corrective action to prevent further XXXX profiling and fiduciary discrimination. 
4. Disciplinary review of XXXX XXXX XXXX. 
5. Assurance that lawful Irrevocable Private Common Law Trusts will be honored and treated consistently.

Conclusion This was my second denial at this branch for the same account request. The behavior displayed by XXXX XXXX is discriminatory and unlawful under federal statutes and OCC regulations. 

Respectfully submitted, XXXX XXXX XXXX XXXX XXXX XXXX Trustee / Fiduciary / Secure Party Creditor UCC 1308 ALL RIGHT RESERVED Without Prejudice Irrevocable Private Common Law Trust Organization Phone : XXXX Email : [ XXXX ]

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation