Consumer complaint received 2025-12-26 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Getting a credit card — Application denied
Company: FIRST NATIONAL BANK OF OMAHA
State: TX

Complaint narrative:
b'[CFPB Complaint Draft: Defective AdverseAction Notice and Failure to Provide Required ECOA/FCRA Disclosures]\n[Respondent: First National Bank of Omaha (FNBO)  Adverse Action Notice Compliance / Credit Services]\n[Reference / FNBO Notice Date: Reference No. XXXX  dated XXXX XXXX XXXXDate mailed to FNBO / Proof of receipt: Mailed via Certified Mail; XXXX  delivery confirmation dated XXXX XXXX XXXX (tracking XXXX XXXX XXXX XXXX XXXX XXXX).\nRelief requested: See Requested Relief section below.]\n1.) [Summary of complaint]\nOn XXXX XXXX XXXX FNBO mailed me an adverseaction notice regarding my credit card application (Ref. XXXX). The notice is partially illegible and internally inconsistent, and therefore fails to state the specific principal reasons for the adverse action in a clear, readable manner as required by the Equal Credit Opportunity Act and Regulation B (12 C.F.R. 1002.9). The notice also fails to provide clear, nonmisleading creditscore disclosures and related documentation required by the Fair Credit Reporting Act and Regulation V (15 U.S.C. 1681m; 12 C.F.R. 1022.72). I mailed FNBO a written demand for corrected notices and supporting records; FNBO received that demand on XXXX XXXX XXXX. I ask the CFPB to investigate and require FNBO to provide the relief listed below.\n\n2.)  [Chronology (key dates)]\nXXXX FNBO obtained credit score (per FNBO notice).XXXX FNBO mailed adverseaction notice (Ref. XXXX).XXXX I mailed a written demand to FNBO identifying illegibility and requesting corrected notice and records.XXXX XXXX certifiedmail delivery confirmation shows FNBO received my demand.\n3. Specific legal deficiencies alleged\nA. ECOA / Regulation B (12 C.F.R. 1002.9)\n\nThe adverseaction notice must contain a statement of the action taken and either (a) the specific principal reasons for the adverse action or (b) a clear statement of the applicants right to request those reasons. The FNBO notice contains garbled and corrupted text (headings and portions of the reasons section are illegible), preventing a reasonable consumer from identifying the principal reasons for denial. This renders the notice substantively defective and noncompliant with Reg B.\n\nB. FCRA / Regulation V (15 U.S.C. 1681m; 12 C.F.R. 1022.72)\n\nWhen an adverse action is based in whole or in part on a consumer report or credit score, the user must disclose the credit score, score range, date, provider, and key factors that adversely affected the score. FNBOs notice presents overlapping and ambiguous lists (reasons you did not score well vs. key factors) and fails to clearly tie the score factors to the adverse decision. The presentation is confusing and does not meaningfully explain how the score affected the decision.\n\nC. Consumer Credit Protection Act (FCRA subchapter)\n\nBecause FCRA disclosure obligations are part of the Consumer Credit Protection Act framework, FNBOs defective implementation of FCRA disclosures also violates the CCPAs consumerprotection objectives.\n\nD. Record retention and automated decision records\n\nRegulation B and supervisory guidance require creditors to retain application and decision records sufficient to demonstrate compliance. FNBO must preserve and produce automated decision logs, scoring outputs, and model inputs used in my application decision.\n\n4. Harm and why relief is needed\nThe defective notice deprived me of the ability to understand the principal reasons for denial and to meaningfully exercise my right to obtain a statement of specific reasons or to correct inaccurate information.\n\nThe ambiguous score disclosures prevent me from assessing whether the credit decision relied on inaccurate or incomplete information and from disputing errors with the consumer reporting agency or FNBO.\n\nWithout the requested records (consumer report copies, scoring output, model name/version, automated decision logs), I cannot verify the accuracy or fairness of FNBOs decision or determine whether systemic problems exist that could harm other consumers.'

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