Consumer complaint received 2025-09-11 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Banking errors
Company: UNITED SERVICES AUTOMOBILE ASSOCIATION
State: FL

Complaint narrative:
To Whom It May Concern : I am filing a formal complaint against USAA Federal Savings Bank regarding its handling of my dispute over two unauthorized electronic fund transfers on my personal bank account. The transactions in question occurred on XX/XX/year>XXXX  and XX/XX/year>, while I was XXXX  and XXXX. I was admitted to the XXXX on XX/XX/year>, and remained under XXXX XXXX XXXX  ( and largely unable to communicate or manage my finances ) until XX/XX/year>. As a result, I did not discover or report the fraudulent transactions until early XX/XX/year>, shortly after I had recovered enough to review my account statements. 

Upon notifying USAA of these unauthorized charges, the banks customer service initially issued provisional credits to my account for the disputed amounts, pending investigation. However, I was later informed by USAA that my claim was denied and the credits were reversed. The reason given was that my report came too late ( beyond the typical 60-day window from when the transactions appeared on my statements ), and that the bank had concluded no error occurred. I strongly believe USAAs decision violates the consumer protections afforded to me under the Electronic Fund Transfer Act ( EFTA ) and its implementing Regulation E, and I am requesting the CFPBs assistance to ensure my rights are upheld. 

Regulation E Violation Failure to Extend Notification Period for Extenuating Circumstances : USAAs denial of my claim due to late reporting fails to consider the extenuating circumstances that caused my delay. Under 12 C.F.R. 1005.6 ( b ) ( 4 ) ( Regulation E ), if a consumers delay in reporting an unauthorized electronic fund transfer was because of extenuating circumstances beyond their control, the financial institution shall extend the [ notification ] times specified to a reasonable period. The Consumer Financial Protection Bureaus official interpretation of this provision specifically cites a consumers extended hospitalization as an example of a situation requiring extension of the normal 60-day reporting window. In my case, I was XXXX  for an extended period ( over six weeks ) during which I was prevented from discovering or reporting the unauthorized transactions. I notified USAA at the earliest reasonable opportunity once I was medically able to do so. By law, USAA should have treated my XXXX notice as timely given these circumstances, rather than using the delay to summarily deny my dispute. 

Improper Denial of an Unauthorized EFT Claim : The transactions on XX/XX/XXXX and XX/XX/year> were not authorized by me in any way. They meet the EFTAs definition of an unauthorized electronic fund transfer, which includes any transfer from a consumers account initiated by another person without authority and from which the consumer receives no benefit. Regulation Es error resolution rules obligate financial institutions to investigate consumers reports of unauthorized EFTs and correct any errors found, while limiting the consumers liability for fraudulent transactions. USAA initially appeared to follow these rules by providing provisional credit, but then reversed course. The banks final position refusing to cover the losses solely because my report was delayed is inconsistent with Regulation Es protections. Even when a notice of error is given outside the typical 60-day statement period, the law does not permit the bank to ignore a legitimate unauthorized transaction claim or to impose unlimited liability on the consumer without considering extenuating factors. Indeed, the Official Staff Commentary to Regulation E makes clear that the 60-day rule for error notices does not entirely strip a consumer of protection for earlier unauthorized transactions, and that liability limits still apply to those transactions. Furthermore, a consumers failure to report promptly due to no fault of their own ( for example, due to hospitalization ) can not be used by the bank as a basis to increase the consumers liability beyond what the regulation explicitly allows. 

In my situation, USAAs actions ( denying the claim and debiting my account for the previously credited funds ) effectively hold me financially responsible for fraudulent transactions that I was physically incapable of reporting sooner. This outcome defeats the purpose of the EFTA/Regulation E, which is to protect consumers from unauthorized transfers and ensure they are not held liable in unfair circumstances. USAAs stance appears to be a direct contravention of 12 C.F.R. 1005.6 ( b ) ( 4 ) and the related consumer protections. It is deeply frustrating and distressing to face financial loss from fraud, only to have my bank reject the claim on a technicality that should not apply due to my medical emergency. 

Requested Resolution : I am seeking the CFPBs assistance in resolving this matter. I request that USAA be instructed or guided to reinvestigate my unauthorized transaction claims with full consideration of the extenuating circumstances, and to reimburse me for the amounts of the XX/XX/year>XXXX  and XX/XX/year>XXXX  unauthorized charges. This would involve restoring the provisional credits ( or otherwise crediting my account ) for those transactions, consistent with USAAs obligations under Regulation E. I also ask that the CFPB ensure USAA adjusts its processes if necessary to comply with Regulation E, so that other consumers are not similarly disadvantaged when they face legitimate delays in reporting due to reasons beyond their control. I am happy to provide the CFPB and USAA with documentation of my hospitalization and incapacity during the period in question, or any additional information needed to support my claim. 

Thank you for your attention to this complaint. I appreciate the Consumer Financial Protection Bureaus role in enforcing consumer protection laws and ensuring fair treatment. I hope for a prompt and fair resolution that makes me whole for the unauthorized transactions and holds USAA accountable to its regulatory obligations.

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation