Consumer complaint received 2018-06-15 00:00:00
Product: Money transfer, virtual currency, or money service — Mobile or digital wallet
Issue: Managing, opening, or closing your mobile wallet account — 
Company: Early Warning Services, LLC
State: HI

Complaint narrative:
The company is Early Warning Services LLC, DBA/ XXXX . 

XXXX advertises itself as a money transfer/ payment processor. It allows customers to utilize their eligible debit cards in the application ; to send money to others domestically. ( It may also allow internationally but I did not use it for this purpose and am otherwise unaware of it's support for international use or transactions. ) The company collected my information both personal and financial, and I was able to use the application and the service for some time. I began to receive email 's from XXXX, requesting that I link my XXXX  XXXX XXXX Account within the XXXX application, to continue use of XXXX. 

I tried to comply with the request, but encountered errors with the application. 
Preventing me from logging in, such error 's as " Login Failure, Error 201 '' when I contacted the companies support team, I was routed to T2 ( Or second level support. ) this support team was unable to assist me other than to purport, that they can not see why but I am suddenly ineligible to use the XXXX application. 

They claim that the XXXX Application renders this decision autonomously, whenever the application receives an update. The employee 's indicate that they don't know how, nor why the decision is rendered, but claim that there is no escalation path beyond them to higher management nor to a technical team that can determine if the ineligibility could potentially be based on an error. 

They further claim that they see no end date for the ineligibility, and suggest that a user is likely ineligible indefinitely. ( Despite the prior claim that they can not see this information ) When asked how I could request the removal of my personal and financial information, I was advised that this is not possible. 

The behavior is extremely alarming, the company has partnered with Risk Management Companies,  that create and maintain a risk assessment/ profile of consumers behavior, identity details, and other comprehensive analysis information, based in part, on Consumer information the Application required to sign up.

By failing to provide insight into the sudden ineligibility of a consumer, and by in turn housing and retaining that consumer 's financial and personal information which is shared amongst the companies network of companies/ partnerships or housed in it's database 's the company is arbitrarily acting as if it were a Consumer Reporting Agency, whilst failing to abide by the FCRA.

Consumer reporting agency '' or CRA means any person which, for monetary fees, dues, or on a cooperative nonprofit basis, regularly engages in whole or in part in the practice of assembling or evaluating consumer credit information or other information on consumers for the purpose of furnishing consumer reports to third parties, and which uses any means or facility of interstate commerce for the purpose of preparing or furnishing consumer reports. ( 15 USCS 1681a ) ; See XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX ( XXXX. XX/XX/XXXX ) According to the FCRA a consumer is entitled to the following C You must be told if information in your file has been used against you. Anyone who uses a credit report or another type of consumer report to deny your application for credit, insurance, or employment or to take another adverse action against you must tell you, and must give you the name, address, and phone number of the agency that provided the information. 
C You have the right to know what is in your file. You may request and obtain all the information about you in the files of a consumer reporting agency ( your file disclosure ). You will be required to provide proper identification, which may include your Social Security number. In many cases, the disclosure will be free. You are entitled to a free file disclosure if : C a person has taken adverse action against you because of information in your credit report ; C you are the victim of identify theft and place a fraud alert in your file ; C your file contains inaccurate information as a result of fraud ; C you are on public assistance ; C you are unemployed but expect to apply for employment within 60 days.

In addition, by XX/XX/XXXX all consumers will be entitled to one free disclosure every 12 months upon request from each nationwide credit bureau and from nationwide specialty consumer reporting agencies. See www.ftc.gov/credit for additional information. 

The company is not acting in this manner, and it's my belief that they are illegally housing and collecting information personal and financial on millions of unsuspecting Americans, myself included.

Company response to consumer: Closed with explanation