Consumer complaint received 2025-08-11 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Title loan
Issue: Was approved for a loan, but didn't receive money — 
Company: CCF Intermediate Holdings LLC
State: TX

Complaint narrative:
This is a request to reopen my prior CFPB complaint ( No. XXXX ) against TitleMax XXXX XXXX XXXX XXXXXXXX and XXXX XXXX XXXX XXXX XXXX The CFPB closed my case based solely on an unverified statement from the company without requiring any supporting documentation. That is not proof of compliance or a lawful debt. The CFPB has a duty to protect consumers by requiring documentation before closing a case. 

This complaint concerns a deceptive practice in which TitleMax XXXX XXXX XXXXXXXX and XXXX XXXX XXXX XXXX misrepresented creditor/debtor roles, took my property without full disclosure, and used misleading contract language to conceal that I was the original creditor. 

1. My Promissory Note Was My Property Under Generally Accepted Accounting Principles ( GAAP ) and XXXX XXXX XXXX XXXX ( XXXX ) rules, a signed promissory note is treated as a cash-equivalent asset. I provided this asset making me the original creditor while the company was the true borrower. This applies to both the Original Loan No. XXXX ( XX/XX/XXXX ) and the Refinance Loan No. XXXX ( XX/XX/XXXX ). 

2. Misleading Grant Language The contracts say I grant the company rights to my promissory note and credit enhancement. This wording is deceptive because : - It implies the company already had rights and I was only granting permission. 
- It conceals that the note and credit enhancement were my property and the true source of funds. 
- It omits that these assets would be immediately sold, pledged, or securitized for the companys benefit. 

3. Conversion and Theft by Deception Under Texas law ( XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ), conversion occurs when someone wrongfully exercises control over anothers property against the owners rights. 
- My promissory note was my personal property until lawfully transferred with informed consent. 
- The company took it, treated it as its own asset, and transferred it without clear disclosure. 
- This is conversion, and because it was done through deceptive wording, it also meets the definition of theft by deception under Texas Penal Code 31.01 and 31.03.

4. Fraud by Nondisclosure Texas law ( XXXX XXXX XXXX, XXXX XXXX XXXX ) recognizes fraud by nondisclosure when a party with a duty to disclose material facts fails to do so. The company had a duty under XXXX XXXX XXXX XXXX. XXXX and federal lending laws to disclose the true use and disposition of my note and credit enhancement and did not. 

5. Truth in Lending Act ( TILA ) Violation The Truth in Lending Act ( 15 U.S.C. 1601 et seq. ) and Regulation Z ( 12 C.F.R. Part 1026 ) require disclosure of the actual source of funds, all finance charges, and any amounts paid to third parties.

- They failed to disclose that I was the creditor, that my property funded the transaction, and that it was transferred for value. 
- This omission extends my right to rescind up to 3 years under 15 U.S.C. 1635 ( f ).

6. Breach of Contract The contract contains language stating that I give up my right to demand payment.

- This clause is a deliberate attempt to preemptively block me from asserting my rightful claim to the value I provided. 
- By law, the consideration in a contract must be mutual. My promissory note and credit enhancement constituted the value given, making payment due to me. 
- A clause that strips me of my right to demand payment is effectively an acknowledgment by the company that value is owed to me. 
- This is a breach of contract in itself because a contract that contains provisions contrary to law, public policy, or made through concealment is voidable and unenforceable. 

7. CFPBs Duty to Protect Consumers The CFPBs role is to protect consumers, not to accept unverified corporate statements as fact. In my prior complaint, the company responded only with you signed the contract. That is not proof. The CFPB must require documentation showing : - How my promissory note was recorded on their books ; - Any sale, pledge, or securitization ; - All assignments or endorsements.

These requests apply to both the Original Loan No. XXXX ( XX/XX/XXXX ) and Refinance Loan No. XXXX ( XX/XX/XXXX ). 

This is bigger than my case TitleMax/XXXX XXXX are funneling consumer promissory notes and credit enhancements to TMX Finance XXXX XXXX which bundles and securitizes them without disclosure. This is a systemic practice harming consumers nationwide. 

Requested Action : I request that the CFPB reopen my prior complaint ( No. XXXX ), require the company to produce all relevant documentation, and address the misrepresentation of creditor/debtor roles, the wrongful conversion of consumer property, and the breach of contract provisions that waive fundamental rights. 

My Information : XXXX XXXX XXXX Phone : XXXX Email : XXXX XXXX ( for clarity ) : - UCC-1 Filing No. : XXXX - Vehicle VIN : XXXX - XXXX XXXX XXXX. : XXXX ( XX/XX/XXXX ) - Refinance Loan No. : XXXX ( XX/XX/XXXX )

Company response to consumer: Closed with explanation