Consumer complaint received 2026-02-03 00:00:00
Product: Checking or savings account — Checking account
Issue: Problem caused by your funds being low — Non-sufficient funds and associated fees
Company: PENTAGON FEDERAL CREDIT UNION
State: MD

Complaint narrative:
# # # * * CFPB COMPLAINT NARRATIVE : PENTAGON FEDERAL CREDIT UNION * * * * I. PRODUCT AND ISSUE IDENTIFICATION * * * * * Company : * * Pentagon Federal Credit Union ( PenFed ) * * * Issue : * * Unauthorized transactions and failure to resolve errors under Regulation XXXX. 
* * * Disputed Transactions : * * * Claim # XXXX : * * {$370.00} * * * Claim # XXXX : * * {$350.00} * * * * XXXX. STATEMENT OF FACTS * * On XX/XX/XXXX, I formally notified PenFed of XXXX unauthorized electronic fund transfers that occurred on my account in XXXX and XX/XX/XXXX. 

1. * * Violation of Investigation Start Date ( 12 CFR 1005.11 ( c ) ) : * * Despite providing notice on XX/XX/XXXX, PenFed unilaterally claimed the 10-business-day investigation window did not begin until XX/XX/XXXX ( the date they chose to " process '' the claim ). Under Regulation E, the clock begins upon * * receipt of notice * *, not upon the institution 's internal administrative start date.

2. * * Bad Faith Summary Denial : * * On XX/XX/XXXX, a PenFed supervisor informed me the claims were denied because they were " past the time frame to process. '' This occurred on the same day the account was being finalized for closure. 
3. * * Prohibited Denial Based on Account Status : * * Per * * Official Staff Commentary to 12 CFR 1005.11 ( a ) -4 * *, a financial institution * * must * * comply with error resolution procedures even if the account has been closed. PenFed used my account closure as a " technical out '' to avoid their legal duty to investigate. 
4. * * Failure to Determine Liability ( 1005.6 ) : * * Even if the reporting fell outside the XXXX window for " Error Resolution '' ( the 10-day provisional credit rule ), the Bank is * * legally obligated * * to determine consumer liability under * * 12 CFR 1005.6 * *. The Bank can not simply refuse to investigate ; they must prove the transactions were authorized before holding me liable for the loss. A XXXX " review '' ( from XX/XX/XXXX to XX/XX/XXXX ) is not a " reasonable investigation '' under federal standards. 

* * III. PROCEDURAL IRREGULARITIES * * The supervisor I spoke with on XX/XX/XXXX provided conflicting information regarding the status of the investigation and the legal start date. This suggests that PenFed is using automated systems to " rubber-stamp '' denials for closed accounts rather than performing the manual, individualized review required by the Electronic Fund Transfer Act. 

* * IV. REQUESTED RELIEF * * I request that the CFPB compel PenFed Credit Union to : 1. Correct the legal start date of these claims to * * XX/XX/XXXX * *. 
2. Conduct a * * manual, good-faith investigation * * into the unauthorized nature of the {$370.00} and {$350.00} transactions, as required by 12 CFR 1005.6.

3. Provide the written findings of their investigation and a copy of all documents relied upon for the denial ( including merchant verification ), as required by * * 12 CFR 1005.11 ( d ) * *.

4. Reimburse the total amount of * * {$720.00} * * for these unauthorized transfers. 

-- - # # # * * Final Instructions for the CFPB Portal : * * 1. * * Select the Category : * * " Checking or savings account '' -> " Problem with a transaction or error. '' 2. * * Amount : * * Enter * * {$720.00} * *.

3. * * Attachments : * * If you have a screenshot of the call log from XX/XX/XXXX showing the call to PenFed, * * attach it. * * It is the most important proof that they lied about the " Start Date. '' 4. * * If the account is closed : * * Make sure to select " Yes '' when asked if you have a closed account with this company.

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