Consumer complaint received 2025-03-27 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Incorrect information on your report — Account status incorrect
Company: GOLDMAN SACHS BANK USA
State: OH

Complaint narrative:
I am submitting this complaint against Goldman Sachs Bank USA, issuer of the Apple Card, regarding their wrongful reversal of a properly initiated payment, contradictory contract interpretation, and potential violations of federal law, including the Fair Credit Reporting Act ( FCRA ), Regulation E, Uniform Commercial Code ( UCC ) Article 4A, and violations of internal XXXX XXXX credit reporting guidelines adopted by furnishers under their contractual agreements with consumer reporting agencies. 
On XX/XX/XXXX, I submitted a two ACH payments in the approximate amount of {$150.00} and {$1.00}, to my Apple Card account, issued by Goldman Sachs Bank, using a XXXX-linked checking account with routing number XXXX and account ending in XXXX. This payment originated from XXXX XXXX XXXX  XXXX, a federally insured U.S. financial institution ( FDIC XXXX # XXXX ). The account had sufficient funds at the time of the transfer to the Apple Card. Despite this, the payment was arbitrarily reversed by Goldman Sachs on XX/XX/XXXX, two days after the initiation on XX/XX/XXXX, without any error or fault on my part. 
Goldman Sachs has previously responded to a related complaint by stating : The Bank does not accept payment via XXXX at this time... The payments were subsequently declined by the Bank. 
Goldman Sachs response is not only factually unsupported by the Terms & Conditions, but legally and contractually indefensible. 
First, Venmo-linked accounts use ACH rail transfers and are routed through a legitimate U.S. bank XXXX XXXX XXXX XXXX XXXX XXXX. Goldman Sachs own Apple Card Customer Agreement specifically on pages 1213, expressly states that a consumer may make electronic payments from a bank account with a financial institution located in the U.S. XXXX XXXX XXXX XXXX. clearly meets this definition. There is no clause or section in Goldman Sachs agreement that excludes XXXX XXXX XXXX XXXX, or XXXX from eligibility. This constitutes a breach of the reasonable expectations of a consumer operating in accordance with plain contractual language Goldman Sachs can not unilaterally decide, without express contractual language, that a class of otherwise valid ACH payments is prohibited. ACH network rules ( governed by XXXX ) require immediate rejection of non-conforming entries. If the transaction was queued and reversed after the fact, it implies Goldman Sachs processed the transaction through initial filters, then used a backend rule to cancel it. Not a front-end eligibility block. 
Second, if Goldman Sachs truly does not accept XXXX-linked ACH payments, then the payment should have been automatically rejected at the point of initiation. Instead, the transaction was initiated and held for two days before being reversed on XX/XX/XXXX. This delay demonstrates that the payment was initially accepted through their own systems, processed in the normal ACH pipeline, and later reversed arbitrarily by internal processes, not due to any invalidity of the funding source. This undermines Goldman Sachs own claim that, [ Goldman Sachs ] conducted an investigation and confirmed no Bank error occurred. 
Goldman Sachs ' handling of this payment directly conflicts with 12 C.F.R. 1005.10 of Regulation E, which governs electronic fund transfers. Under this regulation, an electronic payment is considered rendered at the moment of initiation, not when the recipient bank decides to complete or reverse the transaction. Moreso, 12 C.F.R. 1005.10 ( a ) ( 1 ) ( ii ), plainly states, [ Goldman Sachs must provide ] oral or written notice, within two business days after the date on which the transfer was scheduled to occur, that the transfer did not occur. Goldman Sachs did no such notice. Regardless, I made a replacement payment the same day, and any attempt to report a missed payment in light of this violates both Regulation E and the Fair Credit Reporting Act. The consumers legal duty ends once they authorize a properly funded payment. Any failure in processing after that point is the recipient banks responsibility. Not the senders. The reversal on XX/XX/XXXX, was not prompted by insufficient funds or fraud but solely by Goldman Sachs ' internal reversal of a validly transmitted ACH transaction, per the Terms & Conditions. By initiating and accepting the ACH transfer request, Goldman Sachs triggered its Regulation E duties. Its later reversal, without consumer fault or insufficient funds, constitutes an unlawful denial of an electronic funds transfer under federal law. This constitutes an unfair practice under the Dodd-Frank Act ( 12 U.S.C. 5531 ), as it misleads consumers about payment acceptance while causing financial and reputational harm.

Additionally, under U.C.C. 4A-406, once a payment order is authorized and properly transmitted, any delay, rejection, or failure to process the order appropriately is the legal responsibility of the receiving bank. UCC 4A-406 shifts liability to the recipient bank when a properly authorized and transmitted payment is rejected or mishandled. Goldman Sachs accepted the payment authorization, which transferred responsibility. Their reversal, after acceptance, is not a neutral technical error it is a legally attributable act that carries fault. In this case, Goldman Sachs. Payment was accepted and then reversed. The law does not allow a receiving bank to retroactively blame the sender for its own internal policy enforcement failures. Selective enforcement of unstated ACH exclusions violates both the contract 's plain meaning and the implied covenant of good faith and fair dealing under common law and U.C.C. principles. 
Compounding this is Goldman Sachs statement that : The Customer did not make a payment to satisfy at least the minimum amount due by XX/XX/XXXX, until XX/XX/XXXX. As a result, the Bank reported the account past due. 
This is materially false and misleading. Every furnisher has the ability and obligation to update inaccurate data through XXXX. Goldman Sachs own XXXX reporting obligations under the CDIA require the accurate reflection of consumer intent and payment behavior, including proper coding of payments and disputes received but improperly classified ( e.g., XB or CP compliance codes ). 
Refusal to correct potential misreporting, in the face of a disputed and reversed payment they initiated, is a willful violation under FCRA 1681n. The FCRA allows for a remedy for a willful violation. A willful act or violation includes, not only knowing violations of [ the statute ], but reckless ones as well. Safeco Ins. Co. of Am. v. Burr, 551 U.S. 47, 57 ( XXXX  ). A reckless action includes conduct whereby the company ran a risk of violating the law substantially greater than the risk associated with a reading that was merely careless. 
This reporting, if furnished, would be textbook inaccurate under the FCRA 1681s-2 and data furnisher agreement with the consumer reporting agencies. The FCRA subsection 1681s-2 ( a ) ( 1 ) ( A ) clearly states, A person [ Goldman Sachs ] shall not furnish any information relating to a consumer to any consumer reporting agency if the person knows or has reasonable cause to believe that the information is inaccurate. The FCRA prohibits reporting a late payment unless the account is at least 30-days delinquent. My payment was initiated on XX/XX/XXXX, just 29 days after the XX/XX/XXXX, due date. The reversal was caused by Goldman Sachs actions, not mine. Furnishing derogatory credit information under these conditions would be misleading and unlawful. Even if the reversal caused a delay past XX/XX/XXXX, it can not be attributed to the consumer when the consumer followed all procedural and contractual rules to submit the payment. 
Further, Goldman Sachs can not in good faith, claim : The Bank is obligated to report accurately to the credit reporting agencies and is unable to update the Customer 's credit reporting. 
This is a blatant misstatement if not outright lie. As a data furnisher Goldman Sachs has inflexible obligations under the FCRA and data furnisher agreements with the consumer reporting agencies to adhere to FCRA and CDIA guidelines. All furnishers have the ability, and the dutyto update, correct, or delete inaccurate, incomplete, unverifiable information. Claiming they are unable to update reporting is a blatant refusal to adhere to the statutory obligations. If Goldman Sachs maintains that it is unable to update credit reporting in light of internal processing errors, then this represents a systemic FCRA compliance failure that likely affects other consumers warranting CFPB review and further enforcement. 
If Goldman Sachs reported this payment as late, despite knowing the reversal was internally caused, they have furnished misleading data in violation of federal law, and their refusal to correct it would qualify as willful noncompliance under FCRA 1681n, exposing them to statutory damages and legal consequences. The XXXX XXXX has unequivocally held that a report is inaccurate when it is patently incorrect or when it is misleading in such a way and to such an extent that it can be expected to have an adverse effect. ( XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX ( XXXX XXXX  XXXX ) ( cXXXX XXXX XXXX  XXXX XXXX XXXX, XXXX XXXX XXXX XXXX XXXX, XXXX ( XXXX XXXX XXXXXXXX ) ) ). 
In conclusion, Goldman Sachs : 1. Accepted an ACH payment from a U.S. financial institution and reversed it without valid justification ; 2. Failed to disclose any contractual provision barring such payments ; 3. Violated Regulation E and UCC Article 4A by reversing a properly initiated electronic fund transfer ; 4. Willfully violated the FCRA and XXXX XXXX guidelines by inaccurately reporting a late payment caused solely by their own system ; and 5. Misrepresented their ability to update credit reporting, contrary to federal law.

Pursuant to 15 U.S.C. 1681s-2 ( b ), I am formally requesting a detailed description of the procedures employed by Goldman Sachs Bank USA during its investigation of my dispute, including the scope of the investigation, what records were reviewed, and how the determination to uphold the tradeline was reached. Please also confirm whether any documents, correspondence, or communications were received from the consumer reporting agency, and whether any third-party records ( such as bank payment history or transaction logs ) were reviewed.

Company response to consumer: Closed with explanation