Consumer complaint received 2026-03-09 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Installment loan
Issue: Getting the loan — 
Company: FIRST TECHNOLOGY FEDERAL CREDIT UNION
State: GA

Complaint narrative:
Consumer Financial Protection Bureau Formal Complaint Submission Complaint Details Institution : Digital Federal Credit Union ( DCU ) Institution Address : XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, XXXXXXXX XXXX XXXXXXXX Complainant : XXXX XXXX XXXX, XXXX XXXX XXXX, XXXXXXXX XXXX XXXX XXXXXXXX Denied Application No. : XXXX Conditionally Approved Application No. : XXXX Product Type : Consumer Loan / Credit Application Statutes Violated : ECOA ( 15 U.S.C. 1691 ( d ) ) ; FCRA ( 15 U.S.C. 1681m ( a ) ) ; BSA/CIP ( 31 C.F.R. 1020.220 ) ; UDAAP ( 12 U.S.C. 5531 ) DCU denied my loan application citing false pretextual reasons while concealing that its automated system flagged me as deceased based on a Social Security Administration error that had already been corrected in writing. I am a single parent and the sole caregiver for my minor son, XXXX XXXX ( XXXX XX/XX/XXXX ), who has documented medical disabilities Migraines and Major Depressive Disorder under an active Section XXXX Accommodation Plan ( XXXX XXXX XXXX, XXXX ). I applied for a consumer loan with Digital Federal Credit Union ( DCU ) to meet financial obligations directly connected to my sons medical and educational needs, including securing a new treating physician after his prior provider was no longer available. On XX/XX/XXXX, DCU sent me an email confirming that my XXXX Score was XXXX classified as Exceptional. Days later, DCUs automated underwriting system issued an adverse action notice on Application No. XXXX, denying my loan and citing only XXXX reasons : " Unable to verify credit references '' and " Unable to verify identity. '' No consumer reporting agency was named. No consumer rights disclosures were provided. Immediately after receiving that denial, I submitted a second application No. XXXX. DCUs system conditionally approved this application. The sequential approval of a second application, submitted within the same time window with the same identity and creditworthiness, proves conclusively that my denial was not based on any legitimate credit concern. It was caused by a defect in DCUs automated verification process. The true cause of the denial which DCU concealed entirely was its automated systems reliance on a false " deceased '' indicator associated with my Social Security number. On XX/XX/XXXX, the Social Security Administration confirmed in writing ( BN # XXXX ) that this error had been identified and corrected. DCU failed to disclose this in its adverse action notice, failed to implement any manual review when its system produced a result inconsistent with an Exceptional credit profile, and failed to provide any of the legally required disclosures under ECOA or FCRA. SECTION 2 : SPECIFIC FEDERAL VIOLATIONS Violation 1 ECOA / Regulation B : Deficient Adverse Action Notice The Equal Credit Opportunity Act ( 15 U.S.C. 1691 ( d ) ) and Regulation B ( 12 C.F.R. 1002.9 ) require that an adverse action notice state the specific, principal reasons for denial. The reasons DCU provided Unable to verify credit references and Unable to verify identity are vague, conclusory, and pretextual. They do not identify the actual reason for denial ( a false SSA deceased flag ), do not satisfy the specificity requirements of 12 C.F.R. 1002.9 ( b ) ( 2 ), and do not conform to the model notice forms in Appendix C to Regulation B. This is a textbook ECOA violation. Violation 2 FCRA 1681m ( a ) : Missing Consumer Disclosures When adverse action is based in whole or in part on information from a consumer report or third-party data source, 15 U.S.C. 1681m ( a ) requires the creditor to : ( 1 ) identify the consumer reporting agency ; ( 2 ) state that the CRA did not make the adverse decision; and ( 3 ) notify the consumer of the right to a free copy of the report and the right to dispute. DCUs adverse action notice contained none of these disclosures. To the extent DCUs system queried any SSA Death Master File cross-reference, identity verification service, or credit bureau and that data contributed to the denial every element of the FCRA disclosure obligation was triggered and violated. A pattern of omitting these disclosures constitutes a willful violation under 15 U.S.C. 1681n, carrying statutory damages of {$100.00} {$1000.00} per violation plus punitive damages. Violation 3 BSA/CIP Rule : No Discrepancy Resolution Procedure Federal credit unions are required under 31 C.F.R. 1020.220 ( a ) ( 2 ) ( ii ) to maintain Customer Identification Program ( CIP ) procedures that include specific steps for resolving identity discrepancies. DCUs automated system denied my application without flagging the anomaly for human review despite the fact that a XXXX XXXX score is fundamentally inconsistent with a legitimate identity verification failure. This constitutes a XXXX compliance deficiency that XXXX and XXXX have supervisory authority to examine and sanction. Violation 4 UDAAP : Deceptive and Unfair Practice DCUs conduct meets the CFPBs established tests for both a deceptive and an unfair act or practice under 12 U.S.C. 5531. It is deceptive because the adverse action notice created a false impression about why I was denied misleading a reasonable consumer who can not know to challenge concealed SSA data. It is unfair because the denial caused substantial harm ( denial of credit I was plainly qualified for ) that I could not reasonably avoid, caused by DCUs own system defect. SECTION 3 : HARM AND IMPACT This denial did not happen in a vacuum. It directly harmed a single parents ability to meet documented medical obligations for a disabled minor child. My son XXXX is enrolled in an active Section 504 Accommodation Plan under the Rehabilitation Act of 1973. His plan documents primary impairments of XXXX and XXXX XXXX XXXX, with accommodations including extended time, small reset breaks for decompression, fidget tools, and flexible assignment scheduling to manage XXXX episodes. His plan specifically notes that his prior treating physician was no longer available and that I was actively seeking a new provider. XXXX wrongful denial caused the following concrete harms : Denial of a loan for which I was fully qualified, based solely on a government data error already corrected in writing ; Financial disruption affecting my ability to obtain new medical care for a minor child with documented disabilities ; Significant loss of time and emotional distress spent investigating the true cause of a denial DCU was legally required to disclose ; Forced submission of a second application to confirm what should have been apparent from the first that I am a creditworthy borrower. SECTION 4 : RESOLUTION REQUESTED I am requesting the CFPB take the following actions : Compel DCU to immediately fund Application No. XXXX ( conditionally approved ) without further delay or penalty to me ; Compel DCU to issue a corrected, legally compliant adverse action notice for Application No. XXXX, identifying all specific reasons, the data source that generated the false deceased indicator, and all required FCRA consumer disclosures ; Compel DCU to produce the complete application files for both applications, all third-party vendor data, and a copy of its written CIP discrepancy-resolution procedures ; Investigate DCUs adverse action notice practices for systemic ECOA and FCRA compliance failures affecting other consumers ; Refer DCUs CIP deficiencies to NCUA and FinCEN for BSA examination ; Assess all available civil money penalties for willful violations of FCRA and UDAAP. SECTION 5 : SUPPORTING DOCUMENTS ATTACHED Document 1 : DCU Email confirming XXXX XXXX Score ( XX/XX/XXXX ) Document 2 : DCU Adverse Action Notice, Application No. XXXX Document XXXX : DCU Conditional Approval, Application No. XXXX Document XXXX : SSA Correction Letter, BN # XXXX ( XX/XX/XXXX ) Document XXXX : Section 504 Accommodation Plan, XXXX XXXX XXXX XXXX Schools ( XXXX ) /Medical Documents Document 6 : Formal Demand Letter sent to DCU ( XX/XX/XXXX, via Certified Mail ) I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXXXXXX XXXX XXXX Date XXXX XXXX XXXX XXXX XXXX

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