Consumer complaint received 2025-07-29 00:00:00
Product: Prepaid card — Government benefit card
Issue: Unexpected or other fees — 
Company: Comerica
State: MN

Complaint narrative:
To : Consumer Financial Protection Bureau ( CFPB ) From : XXXX XXXX XXXX Address : XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX, MN XXXX Phone : ( XXXX ) XXXX Email : XXXX Date : XX/XX/XXXX Subject : Complaint Regarding Unauthorized Transactions and XXXX XXXX Payment Processing Service ( Case/Program Number : XXXX ) I am filing this formal complaint against XXXX XXXX Payment Processing Service for their failure to prevent unauthorized transactions, their mishandling of my fraud dispute, and their repeated violations of Regulation E of the Electronic Fund Transfer Act. 
Summary of Complaint : On XX/XX/XXXXXXXX XXXX XXXX XXXXXXXX automatically issued a new debit card ( Card XXXX ) to replace my expiring Card XXXX. This new card was mailed to an incorrect address ( presumably my previous address, XXXX XXXX XXXX XXXX XXXX, within the same building ) without my knowledge or request. I was unaware of XXXX XXXX existence until XX/XX/XXXX. 
On XX/XX/XXXX, an imposter activated XXXX XXXX, registered it, and changed its PIN, all without my knowledge or consent. XXXX XXXX failed to properly identify the consumer during this validation process, allowing the imposter to activate a card obtained through mail theft. According to Regulation E, Section 1005.5 ( b ) -4, if an institution fails to correctly verify a consumers identity and an imposter validates a device, the consumer is not liable for unauthorized transfers. I contend that XXXX XXXX is an unauthorized access device. 
From XXXX XXXX XXXX a series of unauthorized transactions totaling {$1300.00} occurred using XXXX XXXX. These transactions include : XXXX XXXXXXXX XXXX : {$200.00} XXXX XXXX XXXX XXXXXXXX : {$200.00} ( plus {$0.00} XXXX XXXX ) XXXX XXXX XXXX XXXXXXXX : {$200.00} ( plus {$0.00} XXXX XXXX XXXX XXXX XXXX  : {$200.00} ( plus {$0.00} XXXX XXXX XXXX XXXX XXXX XXXX {$200.00} ( plus {$0.00} XXXX XXXX XXXX XXXX XXXX  : {$200.00} ( plus {$0.00} XXXX XXXX XXXX XXXX XXXX XXXXXXXX : {$54.00} XXXX XXXX XXXX  : {$35.00} ( This transaction was later omitted from investigation ) On XX/XX/XXXX, when I received a new card ( Card XXXX ) and noticed a significant discrepancy in my balance. I immediately reported the fraudulent activity to XXXX XXXX on XX/XX/XXXX after seeing it in the web app. 
Issues with XXXX XXXX Handling of the Dispute : * Failure to Disclose Card XXXX : XXXX XXXX repeatedly failed to inform me about the existence of Card XXXX, even during my initial calls to report fraudulent activity. This omission significantly hampered my ability to accurately report the dispute. I only learned about XXXX XXXX on XX/XX/XXXX. 
* Improper Investigation and Denial of Claims : * Provisional credit was granted only for a {$33.00} XXXX  transaction, which XXXX XXXX later acknowledged was unauthorized. 
* My initial dispute ( XXXX XXXXXXXX ) was denied on XX/XX/XXXX, due to conflicting information. However, the information used for this denial did not reflect what I provided in my Questionnaire of Fraud, and it contained inaccurate disputed amounts and answers that only I would know. 
XXXX XXXX XXXX XXXXXXXX transaction was never investigated despite being included in my initial reporting. I had to dispute it again on XX/XX/XXXX. This subsequent dispute ( XXXX XXXXXXXX ) was denied on XX/XX/XXXX, citing Regulation E, Section 1005.18 ( 2 ) ( ii ). 
* Lack of Transparency and Communication : XXXX XXXX has failed to provide clear explanations regarding their dispute process, the reasons for denials, and the existence of multiple service requests. They also claimed to send alert notifications that I never received. 
* Failure to Provide Requested Records : I have repeatedly requested records pursuant to Section 609 of the Fair Credit Reporting Act, as a victim of identity theft, but have not received them. I also requested phone records of calls made by the imposter to access my account and activate the card, and related security/validation measures. 
Violations of Regulation E : XXXX XXXX has violated numerous provisions of Regulation E of the Electronic Fund Transfer Act, including : * Failure to properly identify the consumer during validation : XXXX XXXX allowed an imposter to activate Card XXXX, which was obtained through mail theft. Regulation E states that if a financial institution fails to correctly verify identity and an imposter succeeds in validation, the consumer is not liable for unauthorized transfers. 
* Failure to timely investigate cardholder error claims and report findings : XXXX XXXX investigation process was flawed, resulting in denials based on incorrect information and the omission of transactions. 
* Failure to provide the consumer with a written explanation of findings : I often received conflicting information or no clear explanation for denials. 
Demand for Resolution : I demand the following from XXXX XXXX : * A full credit to my account for all unauthorized transactions made with Card XXXX, totaling {$1300.00}, including the XXXX XXXX  transaction. 
* A complete re-investigation of these unauthorized transactions, acknowledging that XXXX XXXX was an unauthorized access device, mailed to an incorrect address, and activated without my consent. 
* Immediate provision of all requested investigation documents, including those related to the XXXX transaction, my identity theft, phone records of the imposters calls, and details of security/validation measures performed. 
* A clear explanation for the omission of the XXXX transaction from previous investigations and a transparent explanation of the dispute process and the existence of XXXX XXXX and XXXX XXXX. 
I believe that XXXX XXXX is liable for these unauthorized transactions under Regulation E, as XXXX XXXX was not an accepted access device because it was obtained and activated fraudulently due to their negligence. 
Sincerely, XXXX XXXX XXXX

Company response to consumer: Closed with monetary relief