Consumer complaint received 2025-04-21 00:00:00
Product: Student loan — Private student loan
Issue: Getting a loan — Denied loan
Company: College Ave Student Loan Servicing, LLC
State: NC

Complaint narrative:
I respectfully dispute the assertion that my concerns have been adequately addressed, as your response fails to comply with applicable federal consumer protection laws. Specifically : 1. Failure to Provide a Reasonable Opportunity to Verify Identity ( FCRA XXXX XXXX XXXX Violation ) While you cite identity verification procedures under XXXX XXXX XXXX ( Bank Secrecy Act Customer Identification Program ), that regulation does not override or eliminate obligations under the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681m and 12 CFR 1022.43.

Under FCRA and Regulation V, I am entitled to : Notice of Adverse Action with meaningful details about the reason for denial ; A reasonable opportunity to verify or correct identity-related information ; The right to dispute inaccurate or incomplete information used to make the decision. 

Your denial letter provided no such process, nor did it instruct me on how to submit verification documents ( e.g., government ID, utility bill, or other CIP-compliant materials ).

This lack of due process constitutes a failure to provide a consumer with a reasonable method of identity verification, and a denial without recourse is inconsistent with federal consumer protection principles.

2. Use of Proprietary, Undisclosed Data to Deny a Consumer Without Accountability You state that the third-party vendor ( Accertify ) used proprietary data and is not a credit reporting agency. However, that does not relieve you of your duty under FCRA to provide the consumer : The basis of the adverse action, and The opportunity to contest or correct information that affects a credit decision.

Invoking proprietary data to justify denialwhile refusing to disclose even the category of mismatch ( e.g., name, XXXX, address ) creates a system of unreviewable, opaque decisions that violate the spirit and likely the letter of 15 U.S.C. 1681m ( a ).

3. Misuse of Prior Identity Theft Report Without Basis You reference a 2023 identity theft report submitted in an unrelated matter as the rationale for flagging my XX/XX/XXXX application as suspicious. However : The mere existence of a prior identity theft report does not legally justify automatic denial of future applications using valid information. 

FCRA 1681c-2 provides consumers the right to block information resulting from identity theft, not to be indefinitely punished by institutions for past victimization.

The use of my past identity theft report to justify present-day denialwithout opportunity for explanation or rebuttalraises serious concerns about pretextual denials based on unverified assumptions, in violation of due process.

4. No Appeal or Reconsideration Process Offered in Violation of Due Process and Fairness You claim that a Senior Management review was conducted. However : No written appeal process, evidence review opportunity, or chance to submit corrective documentation was ever communicated to me. 

A silent internal review with no consumer involvement does not satisfy the fair dispute and resolution standards expected under the FCRA and CFPB guidelines.

Company response to consumer: Closed with explanation