Consumer complaint received 2025-08-16 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Personal line of credit
Issue: Charged fees or interest you didn't expect — 
Company: GREENSKY OPERATIONS, LLC
State: PA

Complaint narrative:
CFPB XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXXXXXX. 

Consumer : XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX 
Merchant : XXXX, XXXX. 
XXXX ID : XXXX Date of Agreement : XX/XX/XXXX I. Statement of Facts On XX/XX/XXXX, I was issued a GreenSky Shopping Pass and installment loan agreement with XXXX XXXX Bank XXXX. for up to {$15000.00}, payable to XXXX, XXXX. 

The Truth in Lending Disclosure shows : XXXX : 10.99 % Finance Charge : {$7600.00} Amount Financed : {$15000.00} Total of Payments : {$22000.00} The agreement also states explicitly : THIS IS A CONSUMER CREDIT TRANSACTION. 

Despite this disclosure, the contract imposes periodic interest charges in addition to the disclosed finance charge, amounting to double billing and misrepresentation.

II. Violations of Law Truth in Lending Act ( TILA ), 15 U.S.C. 1601 et seq. ; Regulation Z ( 12 C.F.R. Part 1026 ) 15 U.S.C. 1605 ; 12 C.F.R. 1026.4 : Finance charge must reflect the entire cost of credit. GreenSky disclosed a {$7600.00} finance charge, but then imposed additional interest, resulting in unlawful double-billing.

15 U.S.C. 1638 ( a ) : Failure to clearly disclose the true cost of credit.

Pennsylvania UCC ( 13 Pa. C.S. ) 3104 : A note or signed application is a negotiable instrument. 

XXXX : The instrument itself is the obligation ; once issued, no separate loan of money occurred. 

XXXX : XXXX of payment discharges the obligation. 

By monetizing the note, the bank was already compensated.

Federal Reserve / Treasury Accounting Federal Reserve Accounting Manual ( FRAM ), 1.40 & 2.30 : All extensions of credit must be recorded as equal debits and cre
dits ; consumer notes are booked as assets offset by liabilities, meaning the books are balanced at inception.

Treasury Financial Manual ( TFM ), Vol. I, Part 2, Ch. XXXX ( Accounting for Liabilities ) : Federal obligations are XXXX in legal tender ; private banks monetize negotiable instruments rather than lend their own money. 

Failure to Balance the Books/ Double-Dip at Charge-Off XXXX XXXX XXXX ( Allowance for Loan and Lease Losses ; ALLL ) and OCC Banking Circular 2012-33 : Banks must charge off consumer credit at 120/180 days and recognize the loss.

By recording the loss, the bank already took accounting and tax benefits.

Yet GreenSky / XXXX XXXX continues to report a balance due after charge-off, effectively claiming a loss while still collecting or reporting the same obligation. 

This constitutes double-counting and false reporting under FCRA. 

FCRA, 15 U.S.C. 1681s-2, 1681i 1681s-2 ( a ) ( 1 ) ( A ) prohibits furnishing information known to be inaccurate.

1681i requires correction after dispute.

Reporting a balance post-charge-off is inaccurate and unlawful.

Contradiction with IRS 1099-C Reporting A 1099-C Cancellation of Debt form has already been filed in connection with this transaction, reflecting cancellation of the underlying obligation.

While the form lists XXXX XXXX XXXX. as the reporting party, the debt originated under the GreenSky XXXX XXXX XXXX agreement, meaning the same obligation has already been recognized as XXXX. 

Once a debt has been canceled and reported to the IRS, it can not simultaneously be treated as collectible or reportable on a credit file. 

GreenSky / XXXX XXXX continued reporting or collection activity therefore constitutes false reporting and double-counting in conflict with IRS treatment and FCRA requirements XXXX 

XXXXract Void for Misrepresentation and Failure of Consideration Under UCC and federal accounting rules, my signed note was itself money. The bank did not lend me its own funds ; instead, it used my instrument as the funding source.

By labeling this a loan of money rather than a consumer credit transaction, GreenSky and XXXX XXXX misrepresented the nature of the obligation. 

A contract built on misrepresentation and failure of consideration is void and unenforceable.

III. Requested Remedies Immediate correction or removal of the tradeline associated with this account.

Balance correction to {$0.00} if the account has been charged off.

Cessation of any further collection activity on this void and unlawful obligation. 

Production of accounting records showing how the books were balanced at origination and at charge-off.

Recognition that a 1099-C has already been filed, further proving discharge.

Investigation and enforcement action by CFPB to ensure compliance with TILA, FCRA, OCC accounting rules, and Pennsylvania UCC. 

IV. Conclusion This was not a valid loan. It was a consumer credit transaction funded by my own negotiable instrument, structured in violation of TILA and Regulation Z, improperly accounted for under OCC and Federal Reserve rules, and misrepresented to both myself and the credit bureaus. GreenSky XXXX XXXX XXXXXXXX XXXX XXXX. engaged in unlawful double-billing, double-dip charge-off practices, IRS reporting contradictions, and false credit reporting.

Because the contract was built on misrepresentation and lacked lawful consideration, it is void and unenforceable. 

I respectfully request that CFPB compel the creditor to correct these violations, remove or correct the tradeline, and provide full relief. 

Submitted by : XXXX XXXX XXXX

Company response to consumer: Closed with non-monetary relief