Consumer complaint received 2025-07-07 00:00:00
Product: Mortgage — Home equity loan or line of credit (HELOC)
Issue: Applying for a mortgage or refinancing an existing mortgage — Application denials
Company: NAVY FEDERAL CREDIT UNION
State: NJ

Complaint narrative:
To : Consumer Financial Protection Bureau ( CFPB ) Subject : Formal Complaint Against Navy Federal Credit Union Deceptive HELOC Practices and Possible Discrimination Dear CFPB, I am writing to file a formal complaint against Navy Federal Credit Union ( NFCU ) regarding their deceptive, inconsistent, and potentially discriminatory practices during my attempt to apply for a Home Equity Line of Credit ( HELOC ). 

The application process was marked by misleading information, contradictory instructions, and shifting justifications for denial, suggesting a pattern of evasiveness and possible intentional discrimination. Heres a summary of the events and concerns : 1. Contradictory Application Instructions Initially, I was advised by a Navy Federal representative that my application was incomplete. After contacting a different representative, I was told to complete an entirely different set of paperwork. I followed their guidance and submitted the required documents. Days later, I received a denial letter citing. See attached. insufficient time with the credit union as the reasonan excuse that had never been previously mentioned. This could be grounds for a deeper investigation and possible civil legal proceedings. 

2. Inconsistent Denial Justifications Each time I provided documentation or followed their guidance, a new denial reason emerged. For example : One representative mentioned a credit score issue, stating the minimum was XXXX, and mine was slightly below that. 
Yet when that was addressed, another reason was presented regarding membership duration. 
This shifting of criteria created a frustrating and unclear process and suggests subjective and inconsistent decision-making. 
3. Misrepresentation by Executive Relations When I spoke with a representative from Executive Relations, she claimed the decision-making process was not automated and that a human reviewed the file. However, later in the same conversation, she contradicted herself, referring to the AI-driven nature of the underwriting system. She also stated the company never sent out a denial letter advising that the applicants were not part of the credit union long enough. Seen in the second line of the response as to the reason for the denial. This inconsistency raises concerns about transparency and truthfulness in their communications. It appears to be deceptive practices and values to only protect the credit union as a whole. Our conversation with the executive relations representative also found that while they may have said we did not complete the process. We did and had a conversation with one CSR as to what we were looking for. She advised that we should apply under a different program, and we did. However, we found out that NFCU left the two applications open and on file. This could be damaging if we applied for any other HELOCS. As any other organization would see an open file or application with someone else. This was unprofessional and possibly damaging. All conversations are recorded and should be listened to and interpreted as such. Damaging! 

4. Lack of Support and Solutions At no point during this process did any representative offer constructive advice, such as : Ways to improve our eligibility, Alternative product options, Or personalized financial guidance.

This level of disengagement and indifference is not in line with NFCUs stated mission of supporting its membersespecially military families and veterans. 

XXXX. Pattern of Discriminatory Behavior Its important to note that Navy Federal Credit Union has a history of complaints and legal action regarding discriminatory lending practices. In recent years, they have faced criticism and lawsuits tied to : Racial disparities in loan approval rates, Discriminatory marketing practices, And failure to fairly serve minority communities. 
Given the lack of transparency, shifting excuses, and dismissive behavior I experienced, I believe there is a potential violation of the Equal Credit Opportunity Act ( ECOA ) or other fair lending regulations. The entire experience has felt arbitrary, if not deliberately obstructive, and raises concerns that similar tactics may be used disproportionately against minority applicants.

Requested Resolution : I ask the CFPB to investigate the inconsistencies and misrepresentations made by Navy Federal Credit Union in my case.

Determine whether discriminatory practices or violations of fair lending laws have occurred. 
Require Navy Federal to provide a clear, documented policy on HELOC eligibility criteria and how those are communicated to applicants.

Require Navy Federal to undergo a compliance review for patterns of rejection based on non-financial factors.

I am submitting this complaint in good faith and am requesting formal action to ensure this institution is held accountable for deceptive and potentially discriminatory conduct. 


Sincerely, XXXX and XXXX XXXX XXXX XXXX XXXX, XXXX NJ XXXX XXXX XXXX XXXX

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