Consumer complaint received 2025-07-22 00:00:00
Product: Checking or savings account — Checking account
Issue: Closing an account — Can't close your account
Company: PNC Bank N.A.
State: NJ

Complaint narrative:
From : XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  PNC XXXX XXXX XXXX XXXX XXXX. 
XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX CC : Consumer Financial Protection Bureau Case No. XXXX Office of the Comptroller of the Currency Case No. XXXX Subject : Documented Violation ( s ) of Federal Law ( s ) by PNC Bank XXXX XXXX XXXX ( XXXX XXXX XXXX ) Dear XXXX, As you and I discussed, and as the documented record overwhelmingly demonstrates, I made a formal complaint to you and PNC in which I claimed PNC violated the following state and federal law ( s ) : Deceptive Practices ( Federal CFPB, FTC Act, OCC ) Falsely claiming that Regulation E prohibits assistance after 60 days.

Misleading customers about their legal rights. 

Violates : CFPB UDAAP standards FTC Act 5 ( 15 U.S.C. 45 ) OCC Advisory Letter 2002-3 Unfair Practices ( Federal CFPB, OCC ) Systematic refusal to investigate legitimate fraud claims.

Blanket denial policies without case-by-case review.

Violates : CFPB UDAAP rules OCC UDAP guidance False Waiver or Nullification of Rights Misrepresenting that customers lost their rights after 60 days.

Violates : CFPB Circular 2022-04 12 CFR 1005.11 ( Reg E Commentary ) Dodd-Frank Act ( 12 U.S.C. 5531 ) Failure to Investigate Known Fraud Acknowledging transactions were fraudulent but still refusing assistance.

Violates : Regulation E ( 12 CFR 1005.11 ( c ) ) CFPB Reg E supervisory guidance Improper Internal Policy Training Training customer service staff to deliver false or misleading legal statements.

Violates : OCC Consumer Compliance Handbook CFPB UDAAP enforcement policy Misrepresentation of Dispute Status Declaring a dispute settled without acknowledgment or investigation.

Violates : CFPB Bulletin 2013-07 OCC UDAP guidance Violation of New Jersey Consumer Fraud Act ( N.J.S.A. 56:8-2 ) Engaging in false pretense, misrepresentation, or unconscionable business practices in banking services.

In response to my complaint which articulated and highlighted the above information, you sent me a XX/XX/year> letter ( XXXX XXXX XXXX ; XXXX XXXX XXXX ). 

In this letter, you and PNC refuse to acknowledge or respond to the core legal and regulatory complaintswhile addressing only non-substantive account-level issues.

Thus, your XX/XX/year> letter to me on behalf of PNC further violates multiple federal laws and industry compliance obligations.

For example, and to clarify, I submitted a detailed complaint documenting : ( 1 ) false statements made by PNC representatives that Regulation E prohibits PNC from assisting with fraud disputes reported more than 60 days after appearance on my statement ; ( 2 ) PNCs refusal to acknowledge or evaluate extenuating circumstances ; and ( 3 ) PNCs declarationwithout substantive reviewthat my dispute was effectively closed.

Your XX/XX/year> letter selectively addressed only limited, account-level transaction mechanics and did not acknowledge or respond to the core legal, regulatory, and bad-faith conduct I raised.

Such a selective response itself constitutes additional noncompliance issues, and further violations of both federal laws and supervisory standards : 1. Dodd-Frank Act Consumer Financial Protection Act ( 12 U.S.C. 5536 ) Engaging in unfair, deceptive, or abusive acts or practices ( UDAAP ). By failing to address the substance of my allegationswhile issuing a letter that creates the appearance of a full resolutionPNC engaged in a deceptive omission and abused its informational advantage over me as a consumer ( thereby violating the CFPBs enforcement framework under the Consumer Financial Protection Act ( CFPA ) ).

2. Federal Trade Commission Act 5 ( 15 U.S.C. 45 ) Prohibits unfair or deceptive acts or practices in commerce. PNCs failure to address the core substance of my complaint while creating the appearance of a full response constitutes deceptive business conduct. Your and or PNCs misrepresenting the scope of a resolution by omitting key allegations is materially misleading, deceptive, and unlawful.

3. CFPB UDAAP Supervision & Examination Standards CFPB guidance requires covered financial institutions to acknowledge, address, and respond completely, and in good faith, to all material aspects of a consumer complaintnot just selectively. In this case PNCs response omits and deflects key claims ( misrepresentation of Regulation E, refusal to consider extenuating circumstances ), showing a pattern of selective engagement.

Thus, your and or PNCs clear and willful failure to provide a full, fair, and responsive investigation into the full scale and scope of my complaint constitutes deceptive and unlawful conduct.

4. OCC Guidelines for Responsible Conduct OCC emphasizes that financial institutions must respond substantively to complaints forwarded by federal agencies ( here, the OCC and CFPB ). Your and or PNCs omission in your XX/XX/year> response constitutes an additional failure to comply with federal legal and supervisory standards.

Thus, your and or PNCs failure to engage in timely, complete, and good-faith resolution of customer disputes constitutes a breach of safe and sound banking practices.

5. CFPB Circular 2022-04 Misrepresentation or Waiver of Consumer Rights Financial institutions may not misrepresent that a consumer has waived or lost legal rights under federal law. PNC representatives repeatedly told me that Regulation E prevented PNC from helping after 60 days. Your response letter did not correct or address this, effectively ratifying a false waiver of my rights.

You and or PNC ignoring that allegation constitutes tacit approval of a deceptive practiceitself a violation of federal standards.

6. 12 C.F.R. 1005.11 Regulation E ( Failure to Reassess Internal Error ) If PNCs internal policies or training are shown to be materially flawed, it may be required to reopen certain cases. Refusing to do so would violate procedural fairness under the rule.

Because I raised evidence that PNCs training misstates the law, your and or PNCs refusalin light of new evidence of systemic misrepresentationto revisit prior denials constitutes an additional failure to comply with with : 1 ) Regulation E and its duty to investigate, and 2 ) UDAAP regulatory framework.

7. Failure to Satisfy CFPBs Complaint Resolution Expectations CFPB expects responses that are specific, transparent, and address the consumers stated issues. Your and or PNCs XX/XX/year> letter only addresses account transactions and completely ignores allegations involving false legal claims, internal fraud, customer service miseducation, and violation of federal law.

In summary, because you and or PNC ( a ) misrepresented my rights under federal law, ( b ) refused to assess extenuating circumstances, and ( c ) responded to my formal complaints with a letter that ignored these material issues, PNCs conduct appears to violate ( or create exposure under ) : 12 U.S.C. 5536 ( Dodd-Frank / UDAAP ) Failure to respond substantively and fairly.

15 U.S.C. 45 ( FTC Act 5 ) Deceptive omissions and misleading partial response.

CFPB UDAAP Enforcement Manual Failure to resolve all material aspects of my complaint.

OCC Complaint Handling Guidelines Incomplete response to formal OCC/CFPB complaint.

CFPB Circular 2022-04 Tacit acceptance of false waiver of consumer rights.

12 C.F.R. 1005.11 ( Reg E ) Failure to reassess denied claims affected by internal misrepresentation.

CFPB Complaint Resolution Standards Failure to provide transparent and comprehensive resolution.

Therefore, I am requesting that you and or PNC please provide a corrected, compliant, snd comprehensive response that : Acknowledges my allegations regarding misstatements of Regulation E.

Confirms whether PNC trains customer service personnel to state that the bank is legally prohibited from assisting after 60 days.

Reopens and re-evaluates all denied fraud disputes in light of the above.

Identifies what remedial actions ( retraining, policy correction, restitution review ) PNC will undertake.

In conclusion, I request that you and or PNC issue a complete and legally compliant response within ten ( 10 ) business days of receipt of this letter.

Your and or PNCs failure to do so will compel me to pursue all available and appropriate legal avenues and regulatory mechanisms to ensure full accountability and to guarantee this matter is properly acknowledged, addressed, and remedied.

Moreover, please confirm your receipt of this correspondence at your first opportunity to do so.

I look forward to hearing back from you. 

Sincerely, XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX

Company response to consumer: Closed with explanation