Consumer complaint received 2026-02-12 00:00:00
Product: Prepaid card — General-purpose prepaid card
Issue: Trouble using the card — Trouble using the card to spend money in a store or online
Company: Foris DAX, Inc.
State: FL

Complaint narrative:
I. Statement of Facts On XX/XX/year>, I filed a dispute regarding unauthorized electronic fund transfers associated with my Crypto.com prepaid debit card. 

On XX/XX/year>, Foris DAX, Inc. issued written notice that my account had been provisionally credited for disputed amounts. The written notice explicitly stated : These temporary credits are being provided while we investigate your claim You will have full use of these funds while we complete our investigation. 

Subsequently, my virtual card was restricted. I was informed via chat support that : A routine review had been performed. 
I would no longer be able to perform card purchases or apply for a new card. 
The restriction applied to card functionality. 
I must wait until the investigation is completed. 
The matter had been escalated internally. 
No written explanation was provided specifying the legal or contractual basis for the restriction. 

As a result of this restriction : I can not use my card for purchases. 
I can not apply for a replacement card. 
I can not access the provisionally credited funds through the only instrument authorized for such access. 
I was unable to use my funds during an emergency. 

The company has provided provisional credit but has simultaneously XXXX access to the only mechanism by which the funds may be used.

II. Regulatory Framework Implicated A. Electronic Fund Transfer Act ( EFTA ) 15 U.S.C. 1693f The EFTA requires that when a consumer reports an unauthorized electronic fund transfer, the financial institution must : 1. Conduct a good faith investigation ; 2. Provisionally credit the consumers account within 10 business days if the investigation can not be completed ; 3. Permit the consumer to use the funds during the investigation.

Denying practical access to provisionally credited funds undermines the statutory purpose of the provisional credit requirement.

B. Regulation E 12 C.F.R. 1005.11 ( c ) ( 2 ) ( i ) When provisional credit is provided, the financial institution must : Provisionally credit the consumers account for the amount of the alleged error, including interest where applicable. 

Official Interpretations clarify that provisional credit must allow the consumer meaningful access to the funds pending investigation. 

Issuing provisional credit while simultaneously disabling card functionality prevents meaningful access and defeats the purpose of provisional credit protections.

C. Consumer Financial Protection Act ( CFPA ) 12 U.S.C. 5531 Unfair Acts or Practices An act or practice is unfair if it : 1. Causes or is likely to cause substantial injury ; 2. The injury is not reasonably avoidable ; and 3. The injury is not outweighed by countervailing benefits.

Providing provisional credit while freezing the instrument required to access those funds : Causes substantial financial injury, Is not reasonably avoidable by the consumer, Provides no apparent countervailing consumer benefit, Particularly where the institution has expressly represented in writing that the consumer will have full use of the funds.

D. Potential Adverse Action / Account Restriction Concerns The company has restricted card privileges without providing : A written explanation of the specific basis for restriction, Notice of adverse action, if applicable, Clear disclosure of whether this restriction is tied to fraud review, compliance review, or dispute activity.

The lack of transparency raises additional compliance concerns.

III. Core Compliance Issue The central issue is this : Foris DAX , Inc. explicitly stated in writing that I would have full use of provisionally credited funds during the investigation. 

However, they simultaneously restricted card functionality and prevented access to those funds. 
This action renders the provisional credit functionally inaccessible and inconsistent with the protections provided under Regulation E and the Electronic Fund Transfer Act.

IV. Harm Experienced Inability to access funds during an emergency Financial hardship due to inability to use credited funds Lack of clear written explanation Ongoing uncertainty regarding access to funds

Company response to consumer: Closed with explanation