Consumer complaint received 2024-11-08 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Advertising and marketing, including promotional offers — Didn't receive advertised or promotional terms
Company: BANK OF AMERICA, NATIONAL ASSOCIATION
State: TX

Complaint narrative:
Subject : Formal Complaint Against Bank of America for Deceptive Practices Regarding 0 % APR Promotional Expiration Leading to Unjust Finance Charges To the Consumer Financial Protection Bureau ( CFPB ) : I am submitting this formal complaint against Bank of America ( BOA ) for engaging in deceptive and potentially unlawful practices regarding the disclosure of the expiration date of a 0 % APR promotional offer on my credit card accounts ( Account # 1 : XXXX and Account # 2 : XXXX ). BOA 's failure to transparently communicate the termination of this promotional period has resulted in unexpected and unjust finance charges, despite my adherence to responsible credit management practices. 


Background : In XX/XX/year>, BOA extended a 0 % APR promotional offer on my credit card accounts ( Account # 1 and Account # 2 ). Throughout the promotional period, BOA failed to disclose the specific expiration date of this offer in any monthly statements or communications. They never show that information hoping that the customer will forget to pay in full on time. I am attaching snapshots from my most recent statements dated XX/XX/year>, as proof. Consequently, on XX/XX/year>, I was assessed the following finance charges : Account # 1, ending in XXXX : {$35.00} finance charge Account # 2, ending in XXXX : {$19.00} finance charge These charges were applied despite my consistent payments during the promotion period and full payments on both accounts, under the reasonable assumption that the 0 % APR promotion was still in effect. 

Legal Concerns : BOA 's omission of the promotional expiration date constitutes a violation of the Truth in Lending Act ( TILA ), which mandates clear and conspicuous disclosure of credit terms to consumers. Specifically, Regulation Z of TILA requires creditors to provide accurate information about finance charges and terms of credit. BOA 's failure to disclose the expiration date of the 0 % APR promotion impedes consumers ' ability to make informed financial decisions, thereby violating these provisions. 

Furthermore, this practice may contravene the Dodd-Frank Wall Street Reform and Consumer Protection Act 's prohibition against unfair, deceptive, or abusive acts or practices ( UDAAP ). By withholding critical information, BOA has engaged in deceptive practices that mislead consumers regarding the true cost of credit.

Precedent and Consumer Impact : This issue is not isolated. Similar complaints have been documented, indicating a pattern of BOA 's nondisclosure of promotional term expirations, leading to unexpected finance charges for consumers. Such practices not only erode consumer trust but also suggest a systemic issue within BOA 's disclosure policies that warrants regulatory scrutiny. 

Requested Action : I urge the CFPB to : Investigate BOA 's disclosure practices concerning promotional APR offers to determine compliance with TILA and UDAAP provisions. 

Mandate that BOA provide clear and conspicuous disclosure of promotional terms, including expiration dates, in all relevant communications and monthly statements. 

Require BOA to refund all finance charges improperly levied due to nondisclosure of promotional expirations and to compensate affected consumers for any resulting financial harm. 

Implement industry-wide guidelines ensuring that all financial institutions adhere to transparent disclosure practices for promotional credit offers. 

By addressing these concerns, the CFPB will uphold its mandate to protect consumers from deceptive financial practices and ensure fair treatment in the credit market. 

Thank you for your attention to this matter. I trust that the CFPB will take appropriate action to rectify these deceptive practices and prevent further consumer harm.

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