Consumer complaint received 2026-02-19 00:00:00
Product: Money transfer, virtual currency, or money service — Domestic (US) money transfer
Issue: Fraud or scam — 
Company: UNITED SERVICES AUTOMOBILE ASSOCIATION
State: OK

Complaint narrative:
I am filing this complaint regarding USAAs improper denial of an unauthorized electronic funds transfer under Regulation E ( Electronic Fund Transfer Act ). On XX/XX/XXXX, I was contacted by an individual impersonating USAAs fraud department. The caller ID displayed XXXX XXXX, consistent with USAAs headquarters location. The caller possessed my personal identifying information and referenced recent account activity, including fabricated fraudulent transactions to create urgency and credibility. The caller stated that there was a fraudulent employee within USAA and instructed me that initiating an ACH transfer of {$19000.00} was necessary as part of an internal investigation. I was told the transfer would not actually go through and was being used to identify the bad actor. The impersonator also sent text messages containing verification links to further legitimize the interaction. Believing I was communicating with USAAs fraud department and acting to protect my account, I initiated the transfer. I did not knowingly authorize payment to a third party. I did not intend to permanently transfer funds. The transaction was induced through impersonation and deception as to its nature and purpose. I reported the fraud to USAA the same day ( XX/XX/XXXX ). USAA issued provisional credit that same day. On XX/XX/XXXX, USAA denied the claim. On XX/XX/XXXX, they reversed the provisional credit. On XX/XX/XXXX, they denied my appeal, stating that because authenticated credentials were used and no additional attempts occurred, the transaction was not fraud. This reasoning is inconsistent with Regulation E. The mere use of authenticated credentials does not establish valid authorization where the consumer was deceived by a bank impersonator and did not intend to transfer funds to the recipient. Regulation E defines an unauthorized electronic fund transfer as one initiated by a person other than the consumer without actual authority. A transfer induced by impersonation and deception does not constitute valid authorization. USAA has failed to provide : The documentation relied upon in denying the claim The evidence supporting their determination Copies of call recordings or internal notes A specific regulatory basis for denial USAAs position effectively shifts the burden of sophisticated impersonation fraud onto the consumer, contrary to the consumer-protective purpose of Regulation E. I am requesting that USAA : 1. Reopen and properly conduct a Regulation E investigation 2. Reimburse the {$19000.00} 3. Provide the complete investigative file 4. Provide the specific statutory and regulatory basis for denial I reported the fraud immediately and acted in good faith. This transaction was induced through impersonation of the bank and constitutes an unauthorized electronic fund transfer under federal law. ________________________________________ EXHIBIT A Chronological Timeline of Events Account Holder : XXXX XXXX Institution : USAA Disputed Amount : {$19000.00} Transaction Date : XX/XX/XXXX ________________________________________ XX/XX/XXXX Initial Contact and Transfer Received phone call from individual impersonating USAA fraud department. Caller ID displayed XXXX XXXX, consistent with USAA headquarters location. Caller possessed personal identifying information and referenced recent account activity, including fabricated fraudulent transactions. Caller stated there was a fraudulent employee within USAA. Caller instructed that an ACH transfer of {$19000.00} was necessary as part of an internal bank investigation. I was told the transfer would not actually go through and was being used to identify the bad actor. Text messages containing verification links/codes were sent to my phone to legitimize the interaction. Believing I was acting under USAAs direction to protect my account, I initiated the transfer. Upon realizing the fraud, I reported the transaction to USAA the same day. USAA issued provisional credit on XX/XX/XXXX. ________________________________________ XX/XX/XXXX Initial Denial USAA notified me that my fraud claim was denied. Reason given : No evidence of fraud. ________________________________________ XX/XX/XXXX Provisional Credit Reversed USAA reversed the {$19000.00} provisional credit. ________________________________________ XX/XX/XXXX XXXX XXXX I was informed that because there were no additional attempts on my account, USAA determined it was not fraud. I called to reopen the investigation. ________________________________________ XX/XX/XXXX Formal Regulation E Request I formally requested investigation under Regulation E ( 12 C.F.R. 1005 ). I clarified that : o This was bank impersonation fraud. o I did not knowingly authorize payment to a third party. o The transaction was induced through deception. o I would never willingly pay money to a scammer. ________________________________________ XX/XX/XXXX Appeal Denied USAA denied the appeal. Reason given : Authenticated credentials were used ; therefore, the transaction was not fraud. ________________________________________ Key Observations 1. Fraud was reported the same day as the transaction. 2. Provisional credit was issued, indicating initial Reg E treatment. 3. The denial relies solely on the use of authenticated credentials. 4. The transfer was induced through impersonation of the bank. 5. I did not intend to permanently transfer funds to the recipient. 6. I did not knowingly authorize payment to a scammer. Authentication Context Verification texts were sent during the fraudulent interaction. Caller ID spoofed a XXXX XXXX number consistent with USAA presence. The impersonator demonstrated knowledge of account details and PII. The transaction was initiated under the belief it was a security measure directed by USAA.

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation