Consumer complaint received 2025-12-31 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Getting a credit card — Application denied
Company: BARCLAYS BANK DELAWARE
State: TX

Complaint narrative:
Subject / Short title : XXXX XXXX & XXXX XXXX violations inadequate adverse-action notice / failure to provide specific reasons ; possible failure to provide 615 FCRA disclosures ( Request ID XXXX XXXX This correspondence constitutes a formal dispute, demand for statutory compliance, and litigation-hold notice under : Equal Credit Opportunity Act ( ECOA ), 15 U.S.C. 16911691f Regulation B, 12 C.F.R. Part 1002 ( including 1002.9 ) Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681m Regulation V, 12 C.F.R. Part 1022 I. Defective and Non-Compliant Adverse Action Notice ( ECOA / Regulation B ) Your adverse action notice dated XX/XX/year> states : Our records indicate that a previous credit card account that you held with Barclays Bank Delaware experienced charge-off, bankruptcy, severe delinquency, or other negative performance. 

This language is non-compliant with 12 C.F.R. 1002.9 ( b ) ( 2 ) because it fails to identify the specific principal reason ( s ) actually relied upon. Instead, it presents a multi-option boilerplate list and a catch-all phrase, which Regulation B and CFPB guidance explicitly prohibit. 

You did not identify : Which specific condition allegedly applied Which account was relied upon The relevant dates, balances, or performance facts Whether the reason was singular or cumulative Such boilerplate language does not satisfy ECOAs requirement that an applicant be informed of the actual reason ( s ) for adverse action.

II. Failure to Provide Required ECOA Right-to-Request Disclosure Your notice also fails to provide the required stand-alone statement informing the applicant of the right to request a written statement of specific reasons within 60 days, as contemplated by 12 C.F.R. 1002.9 ( a ) ( 2 ) and Appendix C to Regulation B.

The inclusion of a general ECOA nondiscrimination paragraph does not cure this defect.

III. FCRA/ Regulation V Compliance Concerns Your notice further states : There was no impact to your credit score as a credit bureau report was not used in making this determination.

This representation triggers compliance obligations under 15 U.S.C. 1681m and 12 C.F.R. Part 1022.

Accordingly, Barclays must affirmatively certify whether any of the following were used in whole or in part : A consumer report from a CRA A credit score A proprietary or third-party scoring model Any third-party data source covered by FCRA If any such information was used, your failure to provide the disclosures required by FCRA 615 constitutes an additional statutory violation.

IV. Formal Demand Pursuant to the statutes cited above, I hereby demand that Barclays provide within thirty ( 30 ) days of receipt of this letter : A written, itemized statement of the specific principal reason ( s ) for the adverse action, including : Identification of the specific account relied upon Dates of alleged derogatory events Balances or amounts at issue Internal notes, decision logs, or underwriting records supporting the decision Certification under penalty of perjury as to whether any consumer report, credit score, or third-party data was used, and if so : The name, address, and telephone number of the CRA ( s ) Copies of any report ( s ) or score ( s ) relied upon Score reason codes and model identifiers Identification of : The decision-maker ( s ) or approving authority Any automated underwriting system or algorithm used The model name, version, and date of execution Written confirmation that no adverse consumer reporting has been furnished in connection with this denial, or if furnished, proof of immediate correction or deletion.

Re-evaluation of my application using accurate and compliant criteria, or rescission of the adverse action.

V. Preservation of Evidence You are hereby directed to preserve all documents and electronically stored information relating to this application and adverse action, including but not limited to internal emails, underwriting notes, system logs, model outputs, scorecards, and backups. This preservation obligation is ongoing.

VI. Notice of Escalation Failure to comply within the statutory timeframe will result in : A formal complaint to the Consumer Financial Protection Bureau, Escalation to state regulators, and Preservation of my right to pursue all remedies available under 15 U.S.C. 1691e and 15 U.S.C. 1681n1681o, including statutory damages, punitive damages, attorneys fees, and equitable relief.

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