Consumer complaint received 2025-11-03 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Problem using a debit or ATM card
Company: NAVY FEDERAL CREDIT UNION
State: MD

Complaint narrative:
My name is XXXX XXXX XXXX, and I am XXXX years old. I have been a loyal Navy Federal Credit Union member for many years. 

On XX/XX/XXXX, I received an official letter from Navy Federal ( Ref # XXXX ) stating that my debit card ending XXXX was suspended on XX/XX/XXXX and will remain suspended for a full year until XX/XX/XXXX because my debit-card history demonstrates a violation of the Debit Card Disclosure. ( See XXXX XXXX XXXX XXXX XXXX, XX/XX/XXXX ). 

This action has left me without electronic access to my own money and has placed me in an immediate financial crisis. 

What Happened I am an XXXXyear-old retiree living on a fixed income. My Social Security, pension, and retirement deposits are routed through my Navy Federal account. I have always been diligent and immediately reported every fraudulent transaction that appeared on my account.

Like millions of Americans, my personal information has been compromised in national data breaches that were completely beyond my control. I was the victim not the cause of those fraudulent events.

Despite my full cooperation with Navy Federals fraud department, the credit union has revoked my debit-card privileges for one year and has refused to provide any alternative means of reasonable access. 

On XX/XX/XXXX, I spoke with a Navy Federal supervisor who suggested I could use a prepaid card instead. I explained that, at my age, I am not technologically savvy and do not understand app-based or reloadable systems. That solution still prevents me from safely retrieving or managing my funds and does not meet the needs of an elderly consumer. 

Because of this restriction, I must now travel to a branch in person simply to withdraw cash. The branch is not easily accessible, so I must pay for rides to and from the location. This is physically exhausting, financially burdensome, and unsafe. Carrying cash home each time exposes me to serious risk of theft or loss. 

It will take at least two pay cycles to transfer my pension and retirement deposits to a different institution. Until then, I am effectively locked out of my income, unable to pay bills or purchase necessities safely. 

Violations and Regulatory Concerns 1. Electronic Fund Transfer Act ( EFTA, 15 U.S.C. 1693 et seq. ) Navy Federals own Debit Card Disclosure ( 6 Liability for Failure to Complete Electronic Fund Transfers ) promises to complete authorized transfers correctly By disabling my card for a year, Navy Federal has denied me the ability to perform lawful electronic fund transfers, violating the EFTAs guarantee of consumer access to electronic payments.

2. Unfair and Abusive Practice ( 12 U.S.C. 5531 ; CFPB UDAAP Standards ) A blanket one-year debit-card suspension for a verified fraud victim causes substantial, unavoidable harm and serves no legitimate purpose. It is an unfair and abusive act, especially when applied to an XXXX consumer who acted responsibly and cooperated fully. 

XXXX. Breach of Good Faith and Fair Dealing ( 11 Ownership and Cancellation ) While Navy Federal reserves the right to revoke cards at any time, that discretion must still be exercised in good faith. Enforcing a year-long ban without review or accommodation is arbitrary, punitive, and contrary to the implied covenant of fair dealing. 

XXXX. Age-Based Disparate Impact ( Equal Credit Opportunity Act, 15 U.S.C. 1691 ) Younger members who experience fraud are routinely reissued cards after verification. Denying an XXXX senior a replacement constitutes age-based disparate treatment, intentional or not. 

XXXX. Elder Financial Exploitation and Accessibility ( CFPB Bulletin 2016-07 ) Federal guidance directs financial institutions to protect not endanger older adults. Forcing me to handle cash and rely on unfamiliar technology increases my exposure to theft, fraud, and hardship, directly contradicting CFPB elder-protection policy. 

Why Immediate Action Is Required I can not survive for two months without safe, convenient access to my income. I depend on my debit card to purchase groceries, medication, and essential items.

Navy Federals actions are unreasonable, harmful, and discriminatory. Leaving an elderly woman without a debit card for a year is indefensible and places me at serious financial and personal risk.

Requested Relief I respectfully request that the Consumer Financial Protection Bureau require Navy Federal Credit Union to : Immediately reinstate my debit-card access or issue a new monitored, low-limit, or chip-protected card within 10 business days.

Provide a written explanation detailing the justification and policy authority for a one-year suspension.

Offer reasonable senior accommodations that do not depend on prepaid or app-based tools.

Reimburse documented transportation or service costs incurred while accessing funds during this restriction.

Conduct a policy review ensuring Navy Federals fraud-prevention measures comply with EFTA and do not unfairly impact elderly or vulnerable members.

In conclusion, This matter is urgent. Navy Federal has knowingly placed an XXXX consumer in financial jeopardy by denying access to her own funds for a year, despite clear evidence that she was the victim of data breaches and not the cause of fraud. 

I ask the CFPB to intervene immediately, enforce compliance with federal consumer-protection laws, and compel Navy Federal Credit Union to restore my debit-card access without delay. 

Thank you for your prompt attention and protection of senior consumers like me.

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