Consumer complaint received 2026-02-10 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Problem with a purchase shown on your statement — Credit card company isn't resolving a dispute about a purchase on your statement
Company: AMERICAN EXPRESS COMPANY
State: AR

Complaint narrative:
Supplemental Narrative American Express XXXX Rationale and Inconsistent Dispute Outcomes This supplemental narrative is submitted to assist the Consumer Financial Protection Bureau in evaluating whether American Express is administering its dispute-handling process in a consistent, non-arbitrary, and legally compliant manner under the Fair Credit Billing Act ( FCBA ) and Regulation Z when invoking a reported more than XXXX  days after the statement date rationale to deny disputes. 

The central issue is not whether a timing concept exists, but how American Express has applied it. American Express has relied on the XXXX rationale to deny certain disputes while simultaneously crediting or actively investigating other transactions from the same merchants and time periods that are equal toor older thanthe denied transactions. As documented in the attached exhibits, transaction age has not been the controlling factor. Instead, materially similar transactions have received materially different outcomes. 

Once American Express elected to investigate and credit transactions beyond the asserted XXXX window, it effectively abandoned any claim that age alone serves as a strict eligibility bar. Having exercised discretion to review and credit older transactions, American Express can not coherently invoke timing as a rigid rule to summarily deny other disputes involving the same merchants, similar dates, and the same dispute posture. A timing standard that is selectively enforced is not a standard at all. 

Exhibit A is a consolidated, representative spreadsheet compiled directly from American Expresss own correspondence. It organizes each dispute by letter date, transaction date, merchant, reference number, and outcome ( including inquiry submitted, under investigation, account credited, or denied reported more than XXXX  days after statement date ). Exhibit A demonstrates that American Express : credited disputes for transactions dated as early as XX/XX/year> ; opened and maintained investigations for transactions dated between XXXX and XX/XX/year> ; and denied other XXXX XXXX  disputes from the same merchants as too old under the XXXX rationale. 

The distinguishing factor among these disputes is not timing, merchant, or transaction typeit is the outcome American Express chose to apply.

Exhibit B contains the underlying American Express dispute determination letters and electronic communications from which Exhibit A was compiled. These records confirm that the spreadsheet reflects American Expresss own written determinations, not consumer characterization. Read together, Exhibits A and B establish a clear pattern : substantially similar disputes have been credited, investigated, or denied as untimely without any transaction-level explanation justifying the divergent treatment. 

From a regulatory perspective, this inconsistency is significant. The FCBA and Regulation Z require creditors to conduct reasonable, good-faith investigations and to apply dispute-handling standards in a uniform, non-arbitrary manner. A timing rationale that is invoked to deny some disputes but disregarded for others of equal or greater age operates as a post-hoc justification rather than a consistently applied policy. Absent a written standard explaining when the XXXX rule is mandatory versus discretionaryand absent transaction-specific reasoning distinguishing credited disputes from denied onesthe denial letters function as conclusory determinations, not the product of a compliant investigative process. 

This submission does not request that the Bureau re-adjudicate individual disputes. It requests supervisory review of the process itself. Specifically, the consumer respectfully asks the CFPB to assess whether American Express is : applying its timing standards uniformly ; selectively invoking the XXXX rationale to deny disputes while disregarding it for others ; and conducting transaction-level, good-faith investigations as required under the FCBA and Regulation Z.

Company response to consumer: Closed with explanation