Consumer complaint received 2025-12-15 00:00:00
Product: Vehicle loan or lease — Loan
Issue: Managing the loan or lease — Billing problem
Company: UNITED SERVICES AUTOMOBILE ASSOCIATION
State: NC

Complaint narrative:
I am submitting this complaint to preserve the administrative record regarding USAA Federal Savings Banks handling of an auto refinance account ending in XXXX. 
Despite receiving multiple Billing Error Notices, Requests for Information, rescission notices, a tender of a collateralized negotiable instrument, a formal election of arbitration, and a sworn Affidavit of Loan / Extension of Credit Denial, USAA has continued adverse credit reporting, enforcement activity, and repossession without producing required verification, accounting, or proof of standing. 
USAA claims it followed standard operating procedures of consumer reporting, but that assertion is contradicted by the record. The account was placed into a formally noticed billing-error dispute beginning in XX/XX/XXXX. Under federal law, reporting and collection activity must cease while a billing error remains unresolved. USAA never resolved the dispute and never provided complete, GAAP-compliant accounting showing who funded the alleged loan, how it was booked, or whether the obligation remains outstanding. 
USAA further ignored multiple rescission notices that voided any asserted security interest by operation of law, proceeded with repossession after rescission, and ignored a Letter of Intent to Arbitrate issued on XX/XX/XXXX, despite the arbitration clause requiring disputes to be resolved before enforcement actions could occur. 
USAAs own UCC financing statements and SEC disclosures reflect that the Retail Installment Sales Contract was transferred to a trust. USAA has not demonstrated reacquisition, current ownership, or lawful authority to enforce, report, or collect after that transfer, resulting in enforcement and reporting without standing. 
The account is reported as charged-off, yet USAA continues to assert a remaining balance without producing charge-off accounting, sale or disposition records, or issuing a required Form XXXX. Reporting an unverified or extinguished obligation for credit or tax purposes is materially misleading. 
Finally, on XX/XX/XXXX, I served a notarized Affidavit of Loan / Extension of Credit Denial denying the existence of a funded loan absent proof of consideration and accounting. USAA has never rebutted the affidavit with sworn verification or documentary evidence. Silence in the face of a sworn denial leaves the alleged obligation unverified. 
I am attaching my formal response letter to USAA as Exhibit A, which documents the full administrative record, statutory duties, breaches, and resulting harm. 

Administrative & Correspondence Timeline USAA Vehicle Loan Dispute XXXX Vehicle refinanced with USAA Federal Savings Bank via a Retail Installment Sales Contract ( XXXX ) for {$29000.00} XX/XX/XXXX USAA received a collateralized negotiable instrument tendered in connection with the account. 

The instrument was tendered as a lawful commercial instrument, consistent with standard banking and commercial practice in which negotiable instruments are routinely accepted, deposited, transferred, or monetized by financial institutions. 

Negotiable instruments are governed by XXXX XXXX XXXX and are recognized in commerce as transferable instruments capable of representing value and settling obligations when properly presented. 

The instrument was never returned, never properly dishonored, and never credited to the account, nor was any accounting provided reflecting how it was treated on USAAs books. 

XXXX XXXX XXXX USAA received a formal Billing Error Notice, Cease & Desist, and Requests for Information ( RFIs ) via trackable certified mail. 

Requests included : Complete, GAAP-compliant accounting Proof of funding and source of funds Verification of the obligation Loan ownership and servicing authority These notices placed the account into a billing-error dispute and invoked rules pending resolution, prohibiting adverse reporting and enforcement until the dispute was resolved. 

XX/XX/XXXX USAA claims it mailed a Verification of Debt. 
No GAAP-compliant accounting, proof of funding, or reconciliation was provided, only copies of statements were received. 

XX/XX/XXXX XXXX Notice of Rescission sent, voiding any asserted security interest. Barring any repossession activities. 

XX/XX/XXXX Additional rescission notice issued reaffirming prior rescission. 

XX/XX/XXXX Second rescission notice sent. 

XX/XX/XXXX USAA correspondence acknowledges the billing-error framework but still fails to provide complete accounting or resolve the dispute. 

XX/XX/XXXX Third rescission notice issued. 

XX/XX/XXXX Additional correspondence sent reiterating : Ongoing billing-error dispute Demand for complete GAAP-compliant accounting Tender and accounting issues Prohibition on reporting or enforcement pending resolution. 

XX/XX/XXXX Follow-up correspondence sent due to continued non-response. 

XX/XX/XXXX Letter of Intent to Arbitrate issued, invoking the contractual arbitration clause governing disputes. 

Under the agreement, disputes were required to be addressed through arbitration prior to enforcement actions. 

USAA did not respond and did not initiate arbitration. 

XX/XX/XXXX Additional correspondence sent reiterating unresolved disputes and arbitration election. 

XX/XX/XXXX Vehicle unlawfully repossessed by USAA while : the billing-error dispute remained unresolved, multiple rescission notices were active, and an arbitration election was pending. 

XX/XX/XXXX Revocation of Power of Attorney and Rescission sent, further voiding any claimed authority to enforce or repossess. 

XX/XX/XXXX Additional correspondence sent due to continued failure to provide accounting or verification. 

XX/XX/XXXX GLBA / Regulation P Opt-Out Notice sent, revoking consent to disclose or report nonpublic personal information to third parties absent a lawful exception. 

XX/XX/XXXX USAA later stated the repossessed vehicle was sold for {$7600.00} on this date. 

XX/XX/XXXX USAA sent a letter stating : the vehicle was sold on XX/XX/XXXX for {$7600.00}, and an alleged remaining balance of {$10000.00} was still owed. 

XX/XX/XXXX Additional correspondence sent reiterating unresolved disputes, lack of accounting, charge-off inconsistencies, and enforcement concerns. 

XX/XX/XXXX Notarized Affidavit of Loan / Extension of Credit Denial executed and served. 

The affidavit denied the existence of a funded loan absent proof of : consideration, funding source, GAAP-compliant accounting, and lawful ownership or authority. 

USAA did not rebut the affidavit with a sworn response or documentary evidence. 

XX/XX/XXXX ( approx. ) USAA mailed a letter accompanied by a {$320.00} check with no explanation or accounting. 

USAA later stated the matter was too old to explain, despite the dispute remaining active. 

Current Credit Reporting Status Credit reports show : an alleged balance of {$10000.00}, payment status listed as Charge-Off. 

No Form XXXX has been issued despite charge-off and sale of collateral. 

XX/XX/XXXX USAA issued a letter titled Response to Your Concern, asserting compliance with standard procedures. 

The letter did not resolve the billing-error dispute, provide complete accounting, address rescission or arbitration, establish standing, reconcile charge-off and sale, or rebut the affidavit.

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