Consumer complaint received 2025-09-24 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Funds not handled or disbursed as instructed
Company: NAVY FEDERAL CREDIT UNION
State: TN

Complaint narrative:
This is a new, subsequent, and independent complaint from the first. Navy Federal is now stating, without specifying a date or time period, that they concluded their investigation XXXX days ago and performed a chargeback. Now, it has been XXXX XXXX and NFCU states that I am again not receiving a provisional credit because they are waiting to see how the other bank and vendor will react. I have requested and captured all requests, both present and prior, made for the NFCU policy and procedures, as well as the standard operating guidelines, and have been denied every time. This is not the first instance where NFCU has treated me inequitably, denying services and products without cause. XXXX things can not be true here : either the Navy Federal Credit Union offers services and products under uniform, industry standard, equitable, " as to all, '' equitable opportunities, based on " DOCUMENTED, NFCU XXXX, XXXX, and/or XXXX, '' including the permanently XXXX, and other protected classifications, as well as the overall customer base, or they are making discriminatory, XXXX, CFPB, XXXX, XXXX, protected. If NFCU does not provide, or can not provide, documents maintained by every business and corporation within consumer finance, * * Complaint Concerning Discriminatory Practices and Failure to Provide Equitable Treatment by Navy Federal Credit Union * * This complaint delineates distinct and newly articulated grievances that are independent from my previous submissions. Navy Federal Credit Union ( NFCU ) has announced that its investigation concluded XXXX days ago, without specifying the exact timeframe involved, and has reportedly executed a chargeback. Despite this, it has now been XXXX XXXX, and NFCU asserts that I am still not receiving provisional credit as they await the reactions from the merchants bank and the vendor. 

I have meticulously documented all requests made to procure NFCUs policy and procedures, standard operating guidelines ( SOP ), and other operational protocolsall of which have been systematically denied. This ongoing situation is not an isolated incident ; it echoes prior experiences where NFCU has exhibited inequitable treatment, restricting access to services and products without justifiable cause. 

The crux of the matter lies in the inconsistency of NFCUs application of its own policies, which are ostensibly designed to ensure equitable service to all customers regardless of their status, including those who are permanently XXXX. 

XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  mandates that individuals with XXXX receive equitable opportunities in all areas of public life. The treatment I have experienced raises significant concerns regarding compliance with XXXX provisions that prohibit discrimination against individuals based on XXXX. 

XXXX. * * Fair Credit Billing Act ( FCBA ) * * : Under 15 U.S.C. 1666, consumers are entitled to provisional credit during the investigation of billing disputes. NFCUs failure to provide such credit contravenes federal law, especially when they have already acknowledged possession of the funds recovered from the merchant. 

XXXX. * * Regulation E ( 12 C.F.R. Part 1005 ) * * : Notably, Section 1005.11 establishes requirements for creditors regarding provisional credit. NFCUs refusal to issue provisional credit or disclose the chargeback filing date constitutes a violation of this regulation, as they have not provided valid grounds for withholding funds that are rightfully mine. 

XXXX. * * Equal Credit Opportunity Act ( ECOA ) * * : The ECOA, found at 15 U.S.C. 1691, prohibits discrimination in credit transactions. The regulatory framework outlined in 12 C.F.R. 1002.4 reinforces this prohibition by requiring creditors to abstain from any form of discrimination based on arbitrary characteristics. The disparity in how NFCU handles disputes potentially contravenes these standards and suggests a pattern of discriminatory practice that undermines fundamental tenets of equitable treatment. 

XXXX. * * Unfair and Deceptive Acts and Practices ( UDAAP ) * * : The actions of NFCU in withholding funds while acknowledging their existence provide a basis for a claim of engaging in unfair or deceptive practices. This behavior has resulted in an ongoing injury, given that I, as a permanently XXXX individual, am being denied access to funds that are crucial for my day-to-day living. 

XXXX. * * Common Law Principles * * : Recognized principles of good faith and fair dealing necessitate that financial institutions operate in a manner that upholds the trust and confidence placed in them by their clients ( UCC 1-302 ). The disproportionate treatment of my case by NFCU signals a potential breach of this duty, raising questions about their commitment to ethical banking practices. 

* * Conclusion and Request for Remedial Action : * * In light of the outlined legal infractions and ethical considerations, it is evident that Navy Federal Credit Union has violated my rights as a permanently XXXX consumer by withholding funds, failing to provide necessary documentation, and not affording me the equitable treatment mandated by law. Therefore, I seek immediate remediation, including the release of the withheld funds, provision of all requested documentation about my case, and an assurance that NFCU will re-evaluate its practices to ensure compliance with applicable laws and regulations in the future. 

The persistence of these issues necessitates an urgent and thorough review of NFCUs operational policies and their alignment with federal consumer protection laws, particularly those aimed at safeguarding the interests of individuals with XXXX. 

Navy Federal Credit Unions Repeated Denial of Equitable, Standard, and Treatment of a Permanently XXXX Individual, Refusal to Provide Documents of Policy, Procedures, and Standard Operating Protocols, and Ineffective, Dismissive, and Uninformative Communications : This complaint presents distinct and novel issues that are not merely duplicative of existing complaints. The concerns arise specifically from Navy Federal Credit Unions actions after XX/XX/year>, where it wrongfully withheld funds that had already been retrieved from the merchant, coupled with a glaring lack of transparency regarding its processes. Such conduct constitutes new violations that have inflicted additional harm, thereby distinguishing this complaint from my initial grievance. 
Key Facts ( New Developments ) : On XX/XX/year>, Navy Federal informed me that it had already debited the merchants bank ( initiated chargeback ). 
At the same time, Navy Federal stated it would not credit my account and was only waiting to see if the merchant disputes. 
As of XX/XX/year>, Navy Federal continues to withhold the funds, despite acknowledging that it already controls the money. 
Why This Is a Separate Violation : My first complaint covered the missed XXXX provisional credit deadline under 12 C.F.R. 1005.11 ( c ) ( 2 ).

This complaint concerns Navy Federals XXXX XXXX conduct : XXXX. Refusing to release funds already recovered from the merchants bank. 
XXXX. Refusing to disclose the chargeback filing date, the merchants response deadline, or any merchant documentation, in violation of 12 C.F.R. 1005.11 ( d ).

3. Engaging in an unfair and deceptive practice ( UDAAP ) by admitting it has the funds but denying me access, creating an ongoing injury. 

Representatives from NFCU, including XXXX frontline staff and a supervisory agent, have dismissed my inquiries, claiming that NFCU is not obligated to provide provisional credit or documentation regarding our decisions. This stance represents a clear violation of the Fair Credit Billing Act ( FCBA ), specifically 15 U.S.C. 1666, which affirms the consumer 's entitlement to provisional credit during the investigation of disputes related to unauthorized charges. Furthermore, as stipulated in 12 C.F.R. 1026.13, creditors are required to grant provisional credit unless they can unequivocally establish a favorable resolution within the mandated investigation period. NFCU 's non-compliance with this regulatory obligation is both unlawful and untenable. 
There is compelling evidence that NFCU has handled similar disputes in a manner that reflects bias and potential discriminatory practices. The Equal Credit Opportunity Act ( ECOA ), 15 U.S.C. 1691, prohibits discrimination in any aspect of credit transactions. The relevant regulatory framework, as outlined in 12 C.F.R. 1002.4, requires creditors to refrain from engaging in discrimination based on arbitrary factors. The inconsistent application of policies observed at NFCU raises serious concerns about their adherence to the ECOA and suggests a troubling disregard for principles of fairness and equitable treatment. Moreover, common law principles regarding good faith and fair dealing require financial institutions to treat their customers fairly ( see UCC 1-302 ). The evident inconsistencies in NFCU 's treatment of disputes underscore a potential breach of this fiduciary duty, which threatens the trust fundamental to the banking relationship. 
Navy Federal Credit Union XXXX NFCU ) violated federal law and consumer protection by withholding funds already recovered from the merchants bank while refusing to disclose relevant dates or documentation, thereby breaching obligations under Regulation E ( 12 C.F.R. Part 1005 ), engaging in unfair or deceptive practices, and imposing inequitable treatment on a XXXX consumer. This complaint differs materially from my earlier CFPB filing ; however, it is not precluded in its entirety. In combination with all the facts, NFCU conducts its business practices recklessly, autonomously guided by its own interests, openly undermining regulatory and governmental oversight. Representatives from NFCU, including XXXX frontline employees and a supervising agent, dismissed my inquiries with the assertion that NFCU is not required to provide provisional credit ( XXXX ) or documentation regarding our decisions. This dereliction is a clear violation of the Fair Credit Billing Act ( FCBA ), especially 15 U.S.C. 1666, which establishes the consumer 's right to receive provisional credit while disputes concerning unauthorized charges are under investigation. According to 12 C.F.R. 1026.13, creditors are mandated to issue provisional credit unless they can conclusively demonstrate a resolution favoring their position within the stipulated investigation timeframe. NFCU 's refusal to adhere to this regulatory requirement is both unlawful and indefensible. 
I have formally submitted XXXX requests for documentation that elucidates the rationale behind NFCUs decisions regarding my dispute. To date, the responses received have been markedly insufficient and evasive. As stipulated by 12 C.F.R. 1026.13 ( b ), a creditor is obligated to provide documentation once it determines that the charge in question is not erroneous. NFCU 's vague assertions that decisions are made internally without corresponding documentation are wholly unacceptable and represent an apparent infringement of consumer rights. I hereby demand immediate remedial action to address these violations. I expect a comprehensive response from NFCU, including all pertinent documentation that justifies its actions, along with the prompt issuance of the provisional credit that is due to me, inclusive of all fees paid for returned items during the period from XX/XX/year>, through XX/XX/year>. Should there be a continued failure to meet these requests, I will be compelled to explore further legal remedies. 

There is compelling evidence that NFCU has handled similar disputes in a manner that reflects bias and potential discriminatory practices. The Equal Credit Opportunity Act ( ECOA ), 15 U.S.C. 1691, prohibits discrimination in any aspect of credit transactions. The relevant regulatory framework, as outlined in 12 C.F.R. 1002.4, requires creditors to refrain from engaging in discrimination based on arbitrary factors. The inconsistent application of policies observed at NFCU raises serious concerns about their adherence to the ECOA and suggests a troubling disregard for principles of fairness and equitable treatment.

Moreover, common law principles regarding good faith and fair dealing require financial institutions to treat their customers fairly ( see UCC 1-302 ). The evident inconsistencies in NFCU 's treatment of disputes underscore a potential breach of this fiduciary duty, which threatens the trust fundamental to the banking relationship.

VII. Conclusion : In conclusion, the actions and policies of Navy Federal Credit Union in relation to my dispute reveal significant failures in their adherence to consumer protection laws and in providing equitable treatment to their members. The glaring inconsistencies in their practices, lack of transparency, and potential bias require immediate action. I demand a comprehensive review of my case, focusing on consumer rights, equitable procedures, and strict adherence to applicable legal standards, to address these issues and rectify any discriminatory practices, thereby ensuring fairness in financial services for all consumers. 

XXXX. XXXXlectronic Fund Transfer Act ( EFTA ), 15 U.S.C. 1693 et seq. Implemented by Regulation E ( 12 C.F.R. Part 1005 ), engaging in unfair or deceptive practices, and imposing inequitable treatment on a XXXX consumer. 
XXXX. 12 C.F.R. 1005.11 ( d ) : If the institution determines no error occurred, it must provide an explanation and copies of documents relied upon. 
XXXX. Unfair, Deceptive, or Abusive Acts or Practices ( UDAAP ), 12 U.S.C. 5531, 5536.

Financial institutions supervised by the CFPB are prohibited from engaging in unfair or deceptive practices, including failing to provide clear disclosures or withholding funds without a valid legal justification. 
XXXX. Equal Credit Opportunity Act ( ECOA ), 15 U.S.C. 1691 ; ADA, 42 U.S.C. 12101. 
Require financial institutions to provide fair and equal treatment without discrimination, including to XXXX consumers relying on public assistance. 
XXXX. Common Law Duty of Good Faith and Fair Dealing. 
Financial institutions must act fairly, reasonably, and in good faith when dealing with members and their funds. 
B. Lack of Transparency Despite repeated requests, NFCU has not disclosed : o The date the chargeback was filed, o The merchants deadline to respond, or o Any documentation received from the merchant. 
Under 12 C.F.R. 1005.11 ( d ), NFCU must explain and provide supporting documentation if it denies a consumers claim. The lack of disclosure is noncompliant and deceptive. 
XXXX Withholding Funds Already Retrieved NFCU admits it already recovered funds from the merchants bank. 
Holding these funds without crediting them to the consumer lacks any statutory or contractual basis. 
This constitutes an unfair practice under the CFPBs UDAAP authority and a breach of the duty of good faith and fair dealing. 
XXXX Disparate Impact on XXXX XXXX As a permanently XXXX consumer on a fixed income, denial of access to lawfully protected funds imposes disproportionate harm. 
NFCUs refusal to apply standard protections may implicate ECOA and XXXX principles of equity and nondiscrimination, especially if such practices are applied inconsistently across consumer classes. 
Formal Request for Action Against Navy Federal Credit Union : XXXX ) Immediate Release of Recovered Funds : We demand that Navy Federal Credit Union promptly release the funds successfully retrieved from the merchants banking institution. The credit union must uphold its obligation to expedite the reinstatement of these funds to the appropriate account, as this is a fundamental expectation and a critical aspect of its fiduciary duties to its members. Additionally, an immediate refund of all return fees charged during the period from XX/XX/year>, through XX/XX/year>. Following XX/XX/XXXX, I have been systematically denied access to funds that Navy Federal has already recovered. This situation transcends mere delays ; it constitutes an ongoing deprivation of funds to which I have a rightful claim. As a permanently XXXX individual reliant on a fixed income, the compounded effects of this inability to access my resources exacerbate my financial hardship, creating new challenges that are separate from the initial violation regarding provisional credit. 
XXXX ) Documentation of Chargeback Process : We require Navy Federal to furnish a comprehensive account of the chargeback process in writing. This documentation must include the date on which the chargeback was filed, the deadline for the merchants response, and all relevant documentation received throughout the process. Our request is firmly grounded in consumer protection laws that mandate transparency in dispute processes, including the Fair Credit Billing Act and essential provisions of Regulation E. 
XXXX ) Clarification of Fund Retention Practices : We insist that Navy Federal provide a clear and thorough explanation as to why it continues to withhold funds after acknowledging their retrieval. Additionally, we demand an immediate response regarding the refusal to provide the requested documentation that supports its determinations related to the chargeback. This lack of transparency is unacceptable and potentially violates consumer protection statutes and internal compliance standards. Navy Federal must articulate the legal basis for its actions and demonstrate how they align with established regulatory frameworks, particularly Regulation E. 
XXXX ) Review of Dispute-Handling Policies for Compliance : We call for an immediate and comprehensive review of Navy Federals dispute resolution policies to ensure their compliance with Regulation E and applicable fairness standards. This review aims to determine whether Navy Federal 's practices meet regulatory expectations regarding the timely processing of accounts, clear communication, and the ethical treatment of account holders. Evaluating these policies against industrys best practices is essential to protecting consumer rights and maintaining transparency throughout the dispute resolution process. Further, NCUA summarily dismissed my first complaints against NFCU, Conclusion : If NFCU refuses equitable opportunities and fairness to a permanently XXXX individual, and repeatedly, on a " provisional credit, '' twenty-four days after the dispute was filed, XXXX days after they draw down funds from another bank, having denied me my initial provisional credit twice, and then states they are " in-waiting '' for the other bank to dispute, and as you will witness attached, offers not a single date, time, estimation, and all while acting and treating me in a manner that clearly is a discriminatory, biased, non-documented lawful or internal policy, when I can not even receive medicine, then by what reasonable discernment does the CFPB believe they operate based on fairness and equitable, uniform and standard treatment? I am requesting a review of NFCU 's internal policies and procedures, which will be analyzed by the actual compliance team. I am requesting that Navy Federal provide me with all the documents, including the reasons why I have been repeatedly denied. every request ever made, while protecting vendors of other banks. Navy Federal has, in a rapid period of time, declined substantially, and I am betting there are thousands of classes of of similar treatment who would love to take action.

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