Consumer complaint received 2025-08-05 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Getting a credit card — Delay in processing application
Company: NAVY FEDERAL CREDIT UNION
State: GA

Complaint narrative:
DETAILED TIMELINE REPORT : NFCU CREDIT CARD APPLICATION DISPUTE Name : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXXXXX Subject : Navy Federal Credit Union ( NFCU ) Credit Card Applications ACCT #.... XXXX Dispute Timeline Prepared for : Consumer Financial Protection Bureau ( CFPB ) Date Prepared : XX/XX/scrub>XXXX XXXX XXXX XXXX XX/XX/year> Initial Submission Two completed credit card applications submitted to Navy Federal Credit Union : XXXX XXXX XXXX XXXX  Requested Credit Limit : {$50000.00} XXXX XXXX XXXX XXXX XXXX  Requested Credit Limit : {$80000.00} Each application included an attached Addendum affirming : o Lawful authority of the applicant as agent for the principal, XXXX XXXX XXXX Reservation of rights under UCC 1-308, and express refusal of consumer underwriting o Clarification that the income is derived from asset-backed collateral held in trust, not wages Applications were signed and included controlled language, including voiding of Page 2 disclosures, with clear lawful reservations attached. 
XX/XX/year> Initial NFCU Online Submission and Confirmation Applications with XXXX uploaded via secure messaging portal. 
Online confirmation message received. 
System status later showed application status as processing, but Page 2 not displaying properly in NFCU system. 
Applicant submitted first rebuttal letter titled Reaffirmation of Legal Standing and Addendum Validity reiterating : o Power of attorney authority o Right to contract with lawful reservation o Page 2 redaction is lawful under UCC and does not nullify submission o NFCU has no right to compel waiver of disclosure as condition of credit consideration. 
XX/XX/year> Inquiry and Discrepancy Identified Applicant contacted NFCU support after automated message asked to re-upload applications. 
Representative stated the system showed an error and that Page 2 was missing.

Applicant confirmed Page 2 was submitted and included explicit revocation of consumer credit disclosures.

Upon attempted re-upload, system returned a Page 2 not accepted or blank field error.

Applicant verified submissions, but both signature pages ( Page 2 ) were missing from NFCUs system display, likely filtered due to voided language.

Submitted second rebuttal letter titled Constructive Denial by Refusal to Process Complete Application referencing : o Federal Reserve Act Section 16 ( application of credit via lawful instrument ) o Equal Credit Opportunity Act 1691 ( d ) : requirement of written notice of adverse action o NFCUs rejection without review as bad faith contracting o Lawful source of income via trust asset and not conventional employment XX/XX/year> NFCU Response : Incomplete Application NFCU messaged : > Your additional information provided is not required and will not be accepted Page two of the application is not complete and signed.

NFCU demanded applications without modification, denying lawful Addenda.

Stated the applications could not be processed due to missing disclosure signatures. 
XX/XX/year> Legal Clarification Submitted Applicant replied to NFCU through secure portal, stating : o Addenda and lawful disclaimers are part of the signed application o Reservation of rights and revocation of Page 2 language is non-negotiable o NFCUs refusal to process a complete application constitutes a constructive denial under ECOA XX/XX/year> Conditional Resubmission with Numeric Income Applicant complied with NFCUs directive to include a numerical income value on the application. 
Clarified that this figure was provided for office processing only, not as a waiver of legal position. 
Asserted again that income derives from secured trust-based collateral. 
NFCU representative confirmed that : o The modified application and addendum were received o A Member Reference Code ( MRC ) was created o Application was expected to process through the system in 24 hours ( 1 business day ) o Applicant was advised to follow up on XX/XX/year> for confirmation XX/XX/year> System Review Pending Follow-up call made to verify processing status. 
NFCU stated application was still undergoing review, with no confirmation of Page 2 acceptance. 
XX/XX/year> Phone Call with XXXX XXXX XXXX called NFCU to confirm submission status. 
XXXX XXXX stated : o NFCU would not accept any application with voided legal disclosure section o Applications would not be processed further o NFCU would not issue any approval, denial, or formal rejection letter When asked to confirm refusal in writing, Supervisor declined and disconnected the call. 
This was the last direct communication with NFCU as of XX/XX/year>. 
XX/XX/year> Final NFCU Position and Documented Refusal NFCU issued final statement : XXXX Additional information provided is not required and will not be accepted applications are incomplete. 
Reiterated Page 2 must be signed without edits, despite lawful standing of Addendum.

NFCUs continued refusal to accept or review application is a violation of : o 15 U.S.C. 1691 ( d ) Requirement to issue written notice of credit denial or adverse action o Truth in Lending Act ( 15 U.S.C. 1601 et seq. ) Prohibition against unfair or deceptive practices in credit agreements o Federal Reserve Act Section 16 Recognition of lawful obligations backed by collateral as tender for value o UCC 1-308, UCC 3-419 , and UCC 3-603 ( b ) Preservation of rights without prejudice and dishonor of a valid instrument ________________________________________ Legal Authority and Violations Equal Credit Opportunity Act ( ECOA ) 15 U.S.C. 1691 et seq.

It is unlawful for a creditor to discriminate against an applicant based on : - Income derived from non-wage or public assistance sources- Lawful refusal to waive rights under consumer law - Good faith assertion of any rights under the Consumer Credit Protection Act Regulation B 12 C.F.R. 1002.6 ( b ) ( 5 ) Creditors must evaluate income from any lawful source and may not disregard asset-based or trust income when determining creditworthiness.

Notification Requirement 15 U.S.C. 1691 ( d ) If a creditor refuses, delays, or denies a credit application, they must issue a written statement explaining the adverse action within 30 days. NFCU refused to issue any such notice despite repeated requests.

Federal Reserve Act Section 16 ( 12 U.S.C. 411 ) Federal Reserve notes, to be issued at the discretion of the Board of Governors of the Federal Reserve System for the purpose of making advances to Federal Reserve banks through the Federal Reserve agents as hereinafter set forth and for no other purpose, are authorized. The said notes shall be obligations of the United States and shall be receivable by all national and member banks and Federal Reserve banks and for all taxes, customs, and other public dues. They shall be redeemed in lawful money on demand at the Treasury Department of the United States, in the city of Washington , District of Columbia, or at any Federal Reserve bank.

Section 16 ( 2 ) Obligations Backed by Collateral Any Federal reserve bank may discount notes, drafts, and bills of exchange arising out of actual commercial transactions ; that is, notes, drafts, and bills of exchange issued or drawn for agricultural, industrial, or commercial purposes, or the proceeds of which have been used, or are to be used, for such purposes, the Federal Reserve Board to have the right to determine or define the character of the paper thus eligible for discount within the meaning of this Act.

At no point shall any Federal Reserve bank refuse the full value of a lawful credit obligation applied for, provided the collateral security or lawful basis of value has been affirmed.

This interpretive clause, read in conjunction with other Federal Reserve and UCC provisions, establishes that a credit request presented with legitimate security and lawful tender basis must be processed in good faith by the financial institution. Navy Federal Credit Unions refusal violates this principle.

Truth in Lending Act 15 U.S.C. 1601 et seq.

Prohibits deception, omission, or denial of credit based on refusal to consent to standard form language. NFCUs blanket refusal to evaluate modified forms may constitute deceptive and anti-consumer practices.

Uniform Commercial Code - UCC 1-308 Reservation of rights without prejudice - UCC 3-419 Instrument treated as dishonored or converted when not returned or evaluated - UCC 3-603 ( b ) Tender of payment discharges obligation unless returned or rejected with explanation ________________________________________ Summary : NFCU received two complete credit applications with XXXX establishing the secured partys position, legal disclaimers, and income terms. Despite repeated clarifications, resubmissions, and conditional accommodations, NFCU has refused to process the applications unless the applicant waives protected rights and removes lawful reservations. This refusalcoupled with denial to issue a written determinationconstitutes constructive denial, bad faith, and violation of federal lending statutes. 
Submitted by XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Without Prejudice UCC 1-308

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