Consumer complaint received 2025-07-07 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Personal line of credit
Issue: Getting a line of credit — 
Company: AMERICAN EXPRESS COMPANY
State: TN

Complaint narrative:
Consumer Complaint to the CFPB Complainant : XXXX XXXX Respondent : American Express National Bank Ref XXXX XXXX -- - Subject : Improper Use of Credit Application and Unlawful Securitization Activities Violations of Federal Law To the Consumer Financial Protection Bureau : I am filing this complaint to raise concerns regarding the handling of my credit application submitted to American Express National Bank on or around XX/XX/XXXX, which was denied, allegedly based on scoring data from XXXX. 

Shortly after receiving the denial, I reviewed public regulatory filings and discovered that American Express XXXX XXXX XXXX XXXX XXXX and its affiliates are actively engaged in securitizing consumer receivables, including data derived from credit card applications. This is confirmed in the SEC Rule 424 ( h ) filing ( XXXX XXXX XXXX. XXXX ) for XXXX XXXX XXXX Certificates, publicly accessible at XXXX. 

Notably, within the prospectus on pages XXXX, specifically XXXX XXXX, American Express outlines the procedures for distribution of proceeds resulting from the sale, disposition, or liquidation of receivables. These actions include collection and distribution of funds to Class A and Class B Certificateholders based on receivable performance and allocation instructions. These receivables are derived from consumer credit accounts and applications.

-- - Concerns and Legal Citations : 1. Securities Act of 1933 Sections 5 and 17 ( a ) The conduct described may represent violations under the Securities Act of 1933, including : Failure to properly disclose to applicants that their submitted information may be pooled and securitized ; Material omissions that may affect a reasonable consumers decision to apply ; Misuse of personal and financial data in a securities offering without informed consent.

2. 12 C.F.R. 226 ( TILA Regulation Z ) American Expresss handling of this application raises potential concerns under the Truth in Lending Act, particularly : Failure to provide transparent disclosures about the disposition of credit data and related financial instruments ; Potential issues with truthfulness in advertising and consumer protections related to credit application processing.

3. Uniform Commercial Code UCC 2-207, 3-603, 3-306 Under applicable UCC principles : If an application constitutes a commercial instrument or tender, its use without final agreement or mutual assent may represent a dishonor or misapplication under UCC 3-603 ; UCC 2-207 addresses varying terms in commercial exchanges , raising concern over any unilateral changes in the usage of submitted information ; UCC 3-306 reserves the right of claimants against an instrument to challenge unauthorized use by third parties.

-- - Summary of the Issue : While my application for credit was denied based on alleged past delinquencies, my submitted information may have been monetized through securitization and distributed to investors without any transparency, notice, or agreement on my part. The appearance of dual treatmentdenial on one end and financial use on the otherraises legal and ethical concerns that merit investigation.

I respectfully request that the CFPB review the attached evidence, including the American Express denial letter and referenced SEC filing, and assess whether these practices are compliant with consumer protection and federal securities laws. 

Thank you for your time and attention. 

Sincerely, XXXX XXXX

Company response to consumer: Closed with explanation