Consumer complaint received 2025-09-16 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Deposits and withdrawals
Company: UNITED SERVICES AUTOMOBILE ASSOCIATION
State: KY

Complaint narrative:
XXXX XXXX This is not a duplicate complaint. XXXX XXXX  My prior complaint concerned USAAs refusal to accept passport credentials for my sons account. This complaint concerns a separate legal and regulatory issue : USAAs conduct, if mirrored across the financial industry, creates a systemic barrier to consumer access and may constitute a restraint of trade under 15 U.S.C. 1. CFPB has an independent duty to address XXXX  violations and to escalate potential antitrust violations to XXXX XXXX 
CFPB Complaint Narrative This filing is a new complaint, not a duplicate. My prior complaint concerned USAAs refusal to accept passport credentials for my sons account. This complaint concerns a separate legal and regulatory issue namely, USAAs systemic conduct that creates consumer barriers and may constitute a restraint of trade under 15 U.S.C. 1. It therefore raises broader consumer protection and antitrust escalation duties for CFPB. 

I. Distinct Legal Basis This is not a duplicate complaint. My prior complaint concerned USAAs refusal to accept passport credentials for my sons account. This complaint concerns a separate legal and regulatory issue : USAAs conduct, if mirrored across the financial industry, creates a systemic barrier to consumer access and may constitute a restraint of trade under 15 U.S.C. 1. CFPB has an independent duty to address XXXX  violations and to escalate potential antitrust violations to XXXX XXXX Accordingly, this filing is a new complaint concerning CFPBs own statutory duties, not merely a continuation of the original account issue. 

XXXX. Weak Points in USAAs Response 1. Conflation of policy with law o USAAs response cites the USA PATRIOT Act generally but fails to provide specific statutory or regulatory citations ( e.g., 31 U.S.C. 53115330 or 31 C.F.R. Part 1020 ). 
o They are asserting we require this as if internal policy equals binding law. That is not the same as providing constitutional or statutory authority. 
XXXX. Failure to Address Constitutional Challenge o The original complaint raised constitutional grounds under both the XXXX  Constitution and the Constitution of the United States of America. 
o USAA dismissed these as unsubstantiated without substantive argument, citation, or showing where Congress expressly required SSN disclosure as a condition of maintaining access to ones own property. 
XXXX. Due Process & Notice Failures o USAA admits sending late notices ( XX/XX/XXXX ), with deadlines ranging from XX/XX/XXXX to XX/XX/XXXX, under threat of closure. 
o That compressed timeline, paired with the threat of account restriction, constitutes coercion without adequate due process. 
XXXX. Social Security Number Issue o The Social Security Act of 1935 does not authorize compelled disclosure of SSNs for private banking purposes. 
o The Privacy Act of XXXX and subsequent legislation limit compelled SSN disclosure except where expressly required by federal statute. USAA never cited such a statute. 
XXXX. Failure to Address the Fee Schedule / Liability Notice o USAA ignored the liability notice and fee schedule served on the Office of the CEO and Board of Directors. 
o Silence on this point may be construed as acquiescence. 

XXXX. Legal and Constitutional Concerns USAAs response relies on general references to the USA PATRIOT Act but fails to cite any specific statutory or regulatory provision that mandates disclosure of a Social Security number and physical address in addition to a valid unexpired U.S. passport. The cited policies and procedures are internal corporate policies, not binding law. The Social Security Act of 1935 does not authorize compelled disclosure of SSNs in this context, and USAA has not provided any Congressional enactment or constitutional authority for its position. 
Further, the compressed timeline between USAAs late-mailed notices ( XX/XX/XXXX ) and the threatened deadlines ( XX/XX/XXXX, and XX/XX/XXXX ) constitutes coercion without due process. This directly implicates constitutional protections against deprivation of property without due process of law. 
USAAs response also fails to address the liability notice and fee schedule served on the XXXX of the XXXX and XXXX XXXX XXXX. Silence on this point will be construed as acquiescence. 

XXXXXXXX XXXX Constitutional Objection : This complaint also serves as a formal objection under Section XXXX of the Kentucky Constitution, which guarantees that no preference shall ever be given by law to any religious sect, society, or denomination ; nor shall any person be compelled to attend any place of worship, to contribute to the erection or maintenance of any such place, contrary to his consent ; nor shall any man be compelled to send his child to any school to which he may be conscientiously opposed. This section protects freedom of conscience and expressly bars compulsion that offends conscience or amounts to involuntary servitude.

By conditioning access to a bank account on compelled disclosure of a Social Security number and physical address, when a valid U.S. passport already establishes lawful identity, USAA forces individuals to act against religious conviction and conscience. Such coerced disclosure intrudes on protected conscience rights and raises an unlawful element of compelled service or involuntary subjection prohibited under both Section XXXX and the Kentucky Constitutions anti-slavery provisions. 
B. XXXX XXXX XXXX XXXX ( XXXX ) : In addition, this filing invokes the XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX et seq. Requiring compelled use of identifiers beyond lawful passport credentials imposes a substantial burden on the free exercise of religion and conscience, absent a showing of compelling governmental interest pursued by the least restrictive means. USAA has provided neither compelling interest nor statutory authority ; instead it has relied only on generalized references to internal policy and the USA PATRIOT Act, without specifying binding statutory or regulatory authority. 
XXXX Religious Grounds and Right of Conscience : Therefore, this objection is not only constitutional but also religious in nature, preserving rights of conscience as guaranteed under the XXXX  Constitution, the Constitution of the United States of America, and XXXX. These objections must be preserved in the CFPB record to ensure that any CFPB resolution, XXXX referral XXXX or court review does not disregard the protected religious and conscience-based dimensions of this dispute. 
XXXX Federal Jurisdiction and Use of Mail/Wire USAA transmitted its demands and threats of account restriction using both U.S. Mail ( letters sent on or about XX/XX/XXXX ) and electronic wire communications ( online account notifications, mobile app prompts, and website instructions ). These methods fall under the categories of mail and wire as defined in federal law. 
Because federal statutes ( 18 U.S.C. 1341, 1343 ) prohibit the use of mail or wires in furtherance of schemes to obtain money or property by false pretenses, the record of USAAs conduct should be preserved for potential review by the U.S. Department of Justice and the U.S. Postal Inspection Service. These statutes are also recognized as predicate acts in the XXXX XXXX and Corrupt Organizations Act ( RICO ), 18 U.S.C. 19611968, which places the matter squarely within federal jurisdiction.

I am not advancing a criminal charge in this forum. Instead, I am placing CFPB on notice that the factual record involves use of U.S. Mail and interstate electronic systems, and therefore may require escalation to XXXX, FTC, and USPS for investigation of systemic or enterprise-level misconduct. 

USAA has invoked the USA PATRIOT Act generally, but has failed to cite the specific statutory or regulatory authority that allegedly requires disclosure of both a Social Security number and a physical address when a valid U.S. passport and passport card are provided. 

The relevant authority is 31 U.S.C. 5318 ( l ) ( PATRIOT Act 326 ) and its implementing regulation at 31 C.F.R. 1020.220. That regulation requires banks to collect four categories of information, but expressly allows certain alternatives ( e.g., passport number for non-U.S. persons, alternative addresses in certain cases ). USAA has not explained why it can not accept a passport as sufficient identity documentation, nor why less restrictive alternatives are unavailable. My son is a not a US person.

Accordingly, I request that CFPB require USAA to provide the precise statutory and regulatory citation that makes SSN and physical address disclosure mandatory for an adult U.S. citizen, rather than one permissible option among alternatives, and to explain why no accommodation is available under the XXXX rule. 
IV. Requested Actions A. Accordingly, I request that CFPB require USAA to : XXXX. Provide the specific statutory authority for requiring SSN and physical address beyond valid government-issued passport credentials. 
XXXX. Explain why reasonable due process was not afforded given the delayed notice and imminent threat of account closure. 
XXXX. Address the liability notice and settlement demand served on the XXXX and XXXX. 
XXXX  satisfactory answers, I maintain that USAAs response is insufficient and request further CFPB review. 
CFPB must require USAA to cite exact statutory and regulatory provisions ( not just PATRIOT Act ) to justify their demand.

If USAA relies on 31 C.F.R. 1020.220, then : XXXX ) Passport should satisfy identity requirements. 

XXXX ) SSN collection may be found to create unconstitutional coercion where not narrowly tailored, and activate 15 USC 1, 42 USC 1983, peonage and other applicable statutes governing them 3 ) CFPB must explain whether banks have discretion to accept alternative identifiers under the regulation. 

B. Antitrust / Escalation Request While I recognize that the Consumer Financial Protection Bureau does not directly enforce the Sherman Antitrust Act ( 15 U.S.C. 1 ), the Bureau has a duty to address consumer financial protection violations that overlap with systemic restraints of trade. USAAs refusal to honor valid U.S. passport credentials, combined with its insistence on Social Security number and physical address disclosure, imposes an artificial barrier to account access. If this requirement reflects coordinated industry practice, it may constitute a restraint of trade under 15 U.S.C. 1.

Accordingly, I request that CFPB not only address this matter under its unfair, deceptive, or abusive acts and practices ( UDAAP ) authority, but also escalate and refer the antitrust dimension to the U.S. Department of Justice XXXX XXXX or the Federal Trade Commission for review.

V. Reservation of Rights For the record, I reiterate that the published Fee Schedule and liability notice served on the Office of the CEO and XXXX XXXX XXXX remains in full force and effect. USAA has failed to rebut or cure, and silence will be construed as acquiescence. I reserve all rights to pursue damages, remedies, and enforcement of contractual and constitutional claims in any competent jurisdiction, including but not limited to claims under 42 U.S.C. 1983, the Privacy Act, and applicable state constitutional provisions. Nothing in this CFPB filing waives, diminishes, or alters those rights. 
VI. Notice to Officers and Board Members This serves as NOTICE to USAA XXXX XXXX XXXX XXXX and all individual Board Members and Trustees of USAA FSB, in their individual and corporate capacities, that you are each being held responsible under the terms of this complaint and the liability notice and fee schedule previously served. 
Below are the names of current USAA Board of Directors and Trustees ( or as publicly listed ) to whom this Notice is directed : XXXX XXXX ( XXXX, XXXX. ) XXXX XXXX XXXX XXXX of the XXXX USAA XXXX XXXX ( XXXX, XXXX. ) XXXX XXXX XXXX XXXX Chair USAA XXXX XXXX XXXX XXXX & XXXX XXXX XXXX ; Board Member XXXX XXXX XXXX XXXX XXXX USAA XXXX XXXX XXXX XXXX XXXX of USAA Bank XXXX Board XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Independent XXXX USAA XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX. XXXX XXXX USAA XXXX XXXX XXXX XXXX ( XXXX, XXXX. ) XXXX USAA USAA Federal Savings Bank ( USAA FSB ) leadership items publicly confirmable : XXXX XXXX XXXX XXXX XXXX of the Board, USAA Bank ( USAA FSB ). USAA XXXX XXXX XXXX, USAA Federal Savings Bank ( appointed XXXX. 
Important disclosure request to CFPB : USAAs public pages and news releases do not list the full, current roster of USAA FSBs directors and trustees accessible without authentication/cookies. I therefore request that CFPB compel USAA FSB to identify all current directors and trustees by name and office, including committee assignments and dates of service, and place that list into the CFPB record. This information is material to notice, service, and accountability, particularly given the OCCs recent enforcement actions addressing governance and consumer. 

This filing also constitutes NOTICE OF PERSONAL AND OFFICIAL CAPACITY SERVICE upon the above-named individuals and any successors and assigns to the Office of CEO and to the USAA and USAA FSB Boards. All liability, fee schedule terms, and preservation of rights stated in my filing apply to each named individual and to the offices they hold.

NOTICE TO AGENT IS NOTICE TO PRINCIPAL. NOTICE TO PRINCIPAL IS NOTICE TO AGENT, SUCCESSOR, ASSIGNS, ALL. USAA and ITS OFFICERS AND DIRECTORS ARE SERVED NOTICE. Published Fee Schedule on file with the Governor, Secretary of State, and Attorney General of Kentucky, California, and Florida applies. The liability remains upon each named officer and director in their individual capacities and upon the OFFICE OF OFFICER and OFFICE OF DIRECTOR until remedied.

The address listed on CFPB is incorrect. We not UNITED STATES. This Zip Code is a UNITED STATES IDENTIFIER. According to 28 USC 1746 we are without UNITED STATES. it should say United States of America, without zip code. But your system forces the zipcode and UNITED STATES, which we are not.

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