Consumer complaint received 2026-01-03 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Other advances of future income
Issue: Confusing or misleading advertising or marketing — 
Company: HUNTINGTON NATIONAL BANK, THE
State: WV

Complaint narrative:
Product Type : * * Line of credit / short-term cash advance ( digital-only XXXX XXXX  Unfair, deceptive, or abusive acts or practices ( UDAAP ) under the Consumer Financial Protection Act, including bait-and-switch tactics, coercive design that pressures unnecessary deposits/transfers/borrowing, and exploitation of users ' addictive tendencies, potentially supporting individual or class-action litigation I have been a Huntington Bank checking account customer since XXXX and then on XXXX when opening another account with consistent positive activity such as timely repayments ( when applicable ) and no major issues. The * * XXXX XXXX * * feature ( a digital line of credit/cash advance, allowing access to {$100.00} {$750.00} with a 5 % fee per advance ) was made available to me based on my initial checking and deposit historyno credit check required, and initially presented as a helpful emergency tool. 
My XXXX XXXX access was granted or increased based on early account activity, creating reasonable reliance that it would remain available for responsible use in unexpected situations. However, my XXXX XXXX access was recently * * cut off, reduced, or suspended * * because I do not meet the ongoing requirement of * * {$1000.00} or more in monthly deposits * * into the Huntington checking account ( as required for both initial eligibility after XXXX consecutive months and to maintain ongoing access ). I also do not have the required average daily balance of $ XXXX over the past 30 days in all cases. This cutoff occurs specifically when I do not move sufficient money into the account ( via deposits or transfers ), despite my history of responsible banking and no overdrafts or other disqualifying factors in many instances. This practice appears * * deceptive, unfair, and abusive * *, and could form the basis for a lawsuit because : - Initial access was presented as based on general checking/deposit history, implying * * ongoing availability * * for customers who manage their account responsibly, creating reasonable expectations and reliance. 
- The strict enforcement of the * * {$1000.00} monthly deposit * * threshold ( and related balance requirements ) to prevent cutoff feels like a * * bait-and-switch * *, where users are enticed with accessible emergency credit only to have it withdrawn unless they route significant ongoing funds ( deposits/transfers ) through Huntingtoneffectively pressuring users to maintain high activity or borrow more frequently ( incurring 5 % fees ) just to regain or preserve access. 
- I have no obligation to deposit {$1000.00} monthly or use Huntington as my primary banking platform. Traditional banks are expected to promote financial stability and responsible credit accessnot to require sustained high deposits ( which can lead to more fees or unnecessary transfers ) simply to maintain emergency funds. 
- This design is * * particularly coercive and abusive * * for vulnerable users, including those with * * addictive personalities * *, * * gambling issues * *, or * * compulsive spending/borrowing tendencies * *. By tying continued access to ongoing high deposit/activity levels, the program incentivizes compulsive behaviorsencouraging users to transfer or deposit more than needed, borrow repeatedly ( paying fees ), or engage in risky financial maneuvers just to avoid losing access. This can exacerbate financial stress, push users into unnecessary debt cycles, and exploit psychological vulnerabilities, making the practice especially harmful and potentially violative of UDAAP standards on abusive conduct. 

The terms include disclaimers about discretion over eligibility and the right to change criteria, but the reliance on strict monthly deposit thresholds ( with cutoffs when unmet ) feels misleading and takes unfair advantage of customers who initially qualified through good behavior. I have not yet suffered direct financial loss beyond restricted access, but the cutoff severely limits my ability to handle emergencies responsibly, and the pressure to move money into the account is inherently coercive. 

I request that the * * CFPB * * investigate whether these practices violate UDAAP under the Consumer Financial Protection Act, particularly for non-traditional short-term credit products like XXXX XXXX. Offering credit access based on deposit patterns ( without always requiring verified income ) seems inherently riskyyet the bank promotes and then restricts this access. This raises questions of whether it functions as a form of * * entrapment * * to encourage ongoing deposits, more frequent use, or lock users into banking habits that benefit the bank at the customer 's expense. 

Why tie emergency credit availability so tightly to monthly $ XXXX deposits? This model appears designed to create dependency and potential debt traps, especially when combined with features that exploit addictive behaviors.

Company response to consumer: Closed with explanation