Consumer complaint received 2025-11-19 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Installment loan
Issue: Getting the loan — 
Company: Upstart Holdings, Inc.
State: TX

Complaint narrative:
To whom it XXXX concern or Compli.ance XXXX at Upstart. This dispute resolution letter is about the " Adverse Action Denial '' notice I just received dated XXXX XXXX. I have detected " multiple '' deficiencies/inefficiencies with your " adverse action '' notice. A mi.nimum of at least XXXX to be exact. 
Violation # XXXX. Reasons are vague/overbroad and use check ( ist language rather than specific principal reasons -the notice lists broad categories ( e.g., " high number of recent inquiries, '' " high balance utilization, '' " unable to determine abilityto repay '' ) without tying any XXXX lending partner 's decision to the single or principal factor ( XXXX ) that actually drove the denial Violation # XXXX. Multiple score types and many " key factors '' listed without prioritization or limiting to principal factors -the notice supplies XXXX different scores and long lists of adverse " key factors '' for each score but does not identify the principal reason ( XXXX ) for the adverse action or expla in which factor ( XXXX ) were decisive. 
Violation # XXXX. Failure to provide Lender-specific statement of reasons automatically the notice says you must request each lending partner 's statement of principal reasons within 60 days ratherthan providing the statement proactive " y when adverse action was taken, which XXXX be inconsistent with Regulation XXXX timing/availability expectations for specific reasons. Violation # XXXX. XXXX XXXX of XXXX XXXX and XXXX principal-reason XXXX -the letter mixes FCRA score disclosures ( score XXXX and many score key factors ) with Regulation XXXX style checklist items in ways that obscure which specific underwriting inputs caused denial under ECOA/Regulation XXXX and which items XXXX merely score-related under FCRA. Violation # XXXX. Lack of individualized, specific principal reason ( XXXX ) Linked to the creditor/underwriting model used -where complex algorithms or credit-risk assessments are used, CFPB guidance requires specific reasons XXXX tthat " relate to and accurately describe the factors actually considered or scored by a creditor '' ; the notice appears to rely on generalized samplerform language instead. 
The regulators, namelythe Consumer Financial Protection Bureau ( CFPB ) have made perfectly clear. In the most recent CFPB XXXX and adverserdction guidance and an adverse-action overview, " When using artificial imelligence or complex credit modets. 
Financial Institutions and creditors XXXX not rely on the checktlst of reasons provided jn the sample forms ( currently codified in Regulation a ) to satisfytheir obligations under XXXX if those reasons do not " specificatry and accurately '' indicate the principal reason ( XXXX ) for the adverse action. Nor, as a genera ( matter, XXXX creditors rely on overly broad, " XXXX '', orvague reasons to the extent that they obscure the specific and accurate reasons relied upon. 
Federal rules LikoLv imDLfcatod and statutor\r citations : A. Equal Credit Opportunity Act ( XXXX ) XXXX U.S.C. XXXX ( d ) ( XXXX ) : creditor must provide a statement of specific principal reason ( XXXX ) for adverse action. a. Regulatlol. XXXX ( imptomentlng EcOA ) XXXX C.F.B. 
XXXX ( b ) ( XXXX ) : requires specific reasons that indicate the principal reason ( XXXX ) and relate to factors actuatry considered ; timing rules in XXXX C.F.R. XXXX ( a ) also apply. XXXX CFPB XXXX XXXX ( interprotive guidance ) -clarifies that creditors XXXX not rely on checkust/samplerform reasons when they do not specificauy and accurately identify principal reasons, especiauy when complex models/AI are used. XXXX Fair Credit Reporting Act XXXX ) XXXX U.S.C. XXXX in ( a ) ( XXXX ) and XXXX g ( f ) : when adverse action is based in whole or in part on a consumer report and a XXXX XXXX is used, the user must disclose the XXXX XXXX, the range, and the key factors that adversely affected the score ( and those key factors should be the relevant elements affecting the score ). * * * The nctiee appears to attempt FORA score disclosure compuance but does not satisfy the separate ECOA/Reg B XXXX ) eclflclty requirement. 
I hereby request, within the time allowed dy law accordingto FORA Section XXXX ( b ). please Provide the corrected notices and supporting disclosures by certified mailto the address above and by XXXX XXXX XXXX Furthermore, I hereby reject and Opt Out to # XXXX " Disputes '' ( XXXX ) " Arbitration Agreement '' of your Terms and Conditions '' in its entirety. 
Per your instructions under " letter XXXX XXXX to XXXX XXXX " of the conditions. Please treat this communication as a demand for a corrected adverse action notice and production of the requested XXXX V XXXX. I reserve all rights under XXXX, Regulation XXXX, FCRA, Regulation V, and all applicable federal or state law

Company response to consumer: Closed with explanation