Consumer complaint received 2024-01-02 00:00:00
Product: Credit reporting or other personal consumer reports — Credit reporting
Issue: Improper use of your report — Reporting company used your report improperly
Company: NAVY FEDERAL CREDIT UNION
State: NY

Complaint narrative:
I am submitting a formal complaint against Navy Federal Credit Union, expressing significant concerns about potential privacy law violations, particularly the insufficient disclosure of opt-out rights. As a responsible credit union member, I expect institutions like Navy Federal Credit Union to uphold transparency, fairness, and compliance with regulations. Recent observations raise serious concerns, warranting a thorough investigation into Navy Federal Credit Union 's practices.

My primary concern is the apparent lack of disclosure regarding consumers ' right to opt out of information sharing, a crucial aspect of privacy. Section 15 USC 6802 ( b ) ( c ) mandates clear explanations, but Navy Federal Credit Union may not effectively communicate this information. The absence of opt-out information, a right under 12 CFR 1016.7, is troubling, hindering informed decisions and raising compliance questions. 

Beyond opt-out disclosures, concerns extend to potential Fair Credit Reporting Act ( 15 USC 1681 ) violations. Section 602a emphasizes fairness, impartiality, and respect for consumer privacy, areas where Navy Federal Credit Union may lack full compliance.

The apparent lack of information on opt-out options may signal broader insufficient privacy disclosures. Section 15 USC 1681C ( a ) ( 5 ) prohibits certain adverse information disclosure without proper authorization, necessitating clear privacy disclosures under The Privacy Act of 1974.

Notably, under 15 USC 6805, the privacy notice reveals involvement with third-party companies, implying potential Privacy Act and terms and conditions violations. 16 CFR Part 313 and 16 CFR 433.2 outline requirements for privacy practice information.

Emphasizing 5 USC 522a in relation to identity theft, protecting personal information is vital, and any false use of identity, as suspected with Navy Federal Credit Union, contravenes the law.

Additional concerns involve potential FCRA Sec 603 ( d ) ( 2 ) ( a ) ( I ) violations, as it prohibits having a consumer report containing solely transactional information. Such violations breach consumer trust and ignore fundamental principles of consumer protection.

Lastly, 15 U.S. Code 1681s2 ( A ) ( 1 ) A underscores the importance of furnishing accurate information to consumer reporting agencies, a responsibility that must be upheld.

In light of these concerns, I urgently request a thorough Consumer Financial Protection Bureau investigation into Navy Federal Credit Union 's practices. I implore the Bureau to address opt-out and privacy disclosures, considering relevant laws, and ensure compliance with privacy laws and consumer protection statutes.

I appreciate your attention to this matter and trust the Consumer Financial Protection Bureau will take necessary steps to safeguard consumer rights.

Company public response: Company believes it acted appropriately as authorized by contract or law
Company response to consumer: Closed with explanation