Consumer complaint received 2025-07-11 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Other features, terms, or problems — Other problem
Company: AMERICAN EXPRESS COMPANY
State: PA

Complaint narrative:
I am attaching all communication between myself and American Express as well as a new demand letter dated XX/XX/XXXX and a PDF copy of my CFPB complaint since its so lengthy. 



Subject : Violation of CARD Act of XXXX Improper Extension of Credit to Consumer Under Age XXXX RE : Violation of Consumer Rights & Credit Protection Laws American Express Account Ending in XXXX I am submitting this formal complaint to report a clear violation of the Credit Card Accountability Responsibility and Disclosure Act of XXXX ( CARD Act ) specifically, 15 U.S. Code 1637 ( c ) ( 8 ) by American Express, a credit card issuer that extended credit to me when I was under the age of XXXX without complying with the mandatory provisions set forth by federal law. 
Despite receiving my initial complaint back in XX/XX/XXXX XXXX sent via XXXX with a tracking number XXXX and confirmed as delivered. The letter included written authorization for the creditor to communicate with XXXX XXXX t on my behalf along with a demand letter. American Express failed to respond. 
This constitutes a clear disregard for a legitimate consumer inquiry. When XXXX XXXX subsequently filed CFPB complaints on my behalf on XX/XX/XXXX, American Express responded on XX/XX/XXXX, falsely claimed they were not authorized to speak with her, despite being in possession of my signed authorization since XX/XX/XXXX. 
This deliberate misrepresentation appears to have been a calculated attempt to deflect accountability and delay addressing the underlying violations of the Credit Card Accountability Responsibility and Disclosure Act of XXXX. In response. 
My most recent complaint and demand letter dated XX/XX/XXXX will be attached to this CFPB complaint in a PDF format so that American Express can not continue their egregious deceptive acts of deflection, I want to avoid any further evasion or bad-faith tactics by the creditor. 







Violation Summary : When I was under the age of XXXX, American Express approved and extended two credit card accounts in my name. As required by the CARD Act ( Section 301 of Public Law 11124, codified in part under 15 U.S.C. 1637 ( c ) ( 8 ) ), a creditor may only issue a credit card to a consumer under 21 if : The consumer has submitted a signed agreement of a co-signer, guarantor, or joint account holder who is over XXXX, OR The consumer has submitted financial information showing independent ability to make the required minimum payments. 

In my case, American Express issued me the credit card without obtaining a co-signer agreement, nor was I required to provide documentation of independent income or financial ability to repay the debt. This issuance was unlawful and in direct violation of federal consumer protection laws.

Applicable Law : 15 U.S.C. 1637 ( c ) ( 8 ) ( B ) : A credit card issuer may not issue a credit card to a consumer under the age of XXXX unless they have submitted either : o Financial information indicating an independent means of repaying obligations, or o A signed agreement from a qualified co-signer over age XXXX. 
XXXX XXXX of XXXX, Section XXXX : This statute was specifically enacted to prevent predatory and reckless credit extensions to young consumers without the capacity to repay. 
Furthermore, any appearance of creditworthiness based on my XXXX score was grossly misleading, as my credit profile was derived solely from being listed as an authorized user on another partys account. Your institution knew or should have known that an authorized user relationship does not demonstrate independent creditworthiness or income. 

The decision to approve this individual for credit without verified income or a co-signer not only violated the CARD Act, but also constitutes reckless, irresponsible, and predatory lending. At the time of account origination, XXXX XXXX was a recent high school graduate, without full-time employment, steady income, or any reasonable ability to repay the obligations extended by your institution. As a direct result of this failure, the account is now in default, and I am financially insolvent. 


Precedent : In similar enforcement actions, the CFPB has held credit issuers accountable for violating the CARD Acts protections. For example : The CFPB has previously investigated and penalized institutions for improper marketing or credit extensions to college students or young adults that failed to comply with CARD Act provisions ( CFPB Enforcement Action 2013-07 ).

There are notable consumer protection actions where courts penalized lenders for similarly reckless or unfair practices : The law is clear. 15U.S.C. 163
7 ( c ) ( 8 ) explicitly prohibits issuing credit to underXXXX individuals unless income is verified or a qualified cosigner is provided. 
Regulatory backing exists. Congress included the rule as a consumer protection measure under the CARD Act, indicating their intent to shield young, inexperienced consumers from taking on credit they cant repay.

Consumer protection precedent. Courts have shown they will step in on deceptive or predatory credit practices under statutes like New Yorks Executive Law, even when TILA alone wouldnt apply.

Requested Action : I respectfully request that your offices investigate this matter and : 1. Hold American Express accountable for violating the CARD Acts protections for consumers under XXXX. 
2. Initiate enforcement or compliance action against American Express under applicable federal and Pennsylvania consumer protection laws.

3. Ensure restitution and correction, including but not limited to full cancellation of the debt or reversal of any negative credit reporting tied to the improperly issued account.

Thank you for your attention to this serious matter. I am prepared to cooperate fully in any investigation or inquiry you initiate. Please confirm receipt of this complaint and advise me of any further information required.

Company response to consumer: Closed with non-monetary relief