Consumer complaint received 2026-05-19 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Problem with a purchase shown on your statement — Card was charged for something you did not purchase with the card
Company: CITIBANK, N.A.
State: NC

Complaint narrative:
Citi denied my dispute of a {$3600.00} unauthorized charge by XXXX XXXX without meaningfully addressing it under the applicable Truth in Lending Act, Fair Credit Billing Act, and Regulation Z standards, including the unauthorized-use standard and billing-error procedures. Citi instead applied a credit-card-fraud standard and concluded the charge could not be fraudulent because I had previously provided card information to the merchant for an earlier, authorized transaction ( see Ex. 1 and Ex. 2 ). That is not the correct test for unauthorized use. Citi continued to apply this incorrect framework in its XX/XX/XXXX response even after I expressly identified XXXX as the applicable standard in my XX/XX/XXXX letter ( Ex. 3 ) and my XX/XX/XXXX CFPB feedback in XXXX # XXXX. The most direct evidence that the XX/XX/XXXX charge was unauthorized is XXXX own contemporaneous billing conduct. Between XX/XX/XXXX and XX/XX/XXXX, XXXX repeatedly demanded payment for the same {$3600.00}, including a XXXX XXXX billing statement marked PAST DUE PLEASE REMIT ( Ex. 10 ) and two emails with online payment links instructing us to Make an Online Payment ( Ex. 13 and Ex. 14 ). On XX/XX/XXXX, three days after the most recent pay online email, XXXX charged my card {$3600.00} without notification, without a receipt, and without my authorization. A merchant operating under standing card authorization does not send a PAST DUE notice and two pay online emails and then unilaterally charge the card three days later. I first sent Citi the PAST DUE statement as an attachment to an email sent XX/XX/XXXX ( Ex. 9 ; the PAST DUE statement is separately filed as Ex. 10 ) and sent it numerous times afterwards, including on XX/XX/XXXX ( Ex. 5 ), XX/XX/XXXX ( XXXX. XXXX ) and XX/XX/XXXX ( Ex. 6 ). The XX/XX/XXXX email included other XXXX emails from XXXX requesting payment. I also explained my unauthorized-use theory tied to them. Citi has never addressed this contradiction. Background This matter involves two XXXX XXXX charges of {$3600.00} each, billed to my Citi account on XX/XX/XXXX and XX/XX/XXXX. The XX/XX/XXXX charge was authorized when I provided card information for the first installment in connection with the merchants written estimate ( Ex. 12 ). As of XX/XX/XXXX, XXXX itself acknowledged in writing that the final invoice amount was not settled. In an email from XXXXXXXX XXXX XXXX XXXXXXXX XXXX ( Ex. 15 ), the merchant agreed to credit {$190.00} toward the final invoice ( {$99.00} for hotel reimbursement and {$100.00} for inconvenience ). Eleven days later, on XX/XX/XXXX, XXXX charged my card the full undiscounted {$3600.00}, without applying the credits it had agreed to and without my authorization. The XX/XX/XXXX charge was not authorized. I was not present when the charge was made, did not provide my card, did not authorize the charge by phone or in writing, and did not receive a receipt. I discovered the charge on XX/XX/XXXX, while reviewing my Citi account. On XX/XX/XXXX, I filed a single dispute covering both the unauthorized XX/XX/XXXX charge and XXXXXXXX XXXX defective work ( Citi assigned Case ID XXXX ). Because Citi 's online dispute form required me to select a single category, I selected goods/services not delivered as expected the sewer system was not working and that issue was foremost in my mind. I clarified in writing two days later that the XX/XX/XXXX charge was also unauthorized, in a XX/XX/XXXX email to XXXX ( XXXX. XXXX ). Regulation Zs billing-error procedures ( 12 C.F.R. 1026.13 ) cover both unauthorized use and disputes involving goods/services, and my written notice cured any ambiguity well within the 60-day FCBA window. In XX/XX/XXXX, after additional defects in XXXX XXXX work emerged, I filed a separate dispute as to the XX/XX/XXXX charge ( Citi assigned Case ID XXXX ). This CFPB complaint concerns only the first dispute, the XX/XX/XXXX unauthorized charge under Case ID XXXX. Scope of This Complaint My first CFPB complaint, Case # XXXX, was filed because Citi was not engaging substantively with my dispute. At that time, Citi had repeatedly requested documentation I had already submitted, was issuing inconsistent communications, and had not provided a written explanation of its determination. On XX/XX/XXXX, in feedback submitted through that case, I expressly narrowed my claim against Citi to the XX/XX/XXXX, charge of {$3600.00} only ( Ex. 24 ). My feedback stated : I am not asking Citi to reverse both charges through the billing dispute process. My primary claim against Citi is that the XX/XX/XXXX, charge was unauthorized under 15 U.S.C. 1643 and should be reversed ( {$3600.00} ), along with any interest or fees that accrued on the disputed balance and correction of any adverse credit reporting. I reserved all other claims against the merchant for defective workmanship, consequential damages, and unpaid credits, which I am pursuing through the North Carolina Attorney Generals Consumer Protection Division and the XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Contractors. Citis XX/XX/XXXX response did not address the narrower claim I presented in the XX/XX/XXXX feedback. The XX/XX/XXXX letter continued to refer to two disputed charges from a plumbing merchant and relied in part on the argument that the total of the two charges also matched the total price on the merchants initial estimate. Citi was on notice of both the narrowed scope of my claim and the XXXX framework as of XX/XX/XXXX, and its XX/XX/XXXX response engaged with neither. This complaint concerns only Citis failure to properly investigate and its failure to respond to my unauthorized-use claim regarding the XX/XX/XXXX charge. Procedural History and Citis Repeated Documentation Requests The relevant procedural history is as follows : XX/XX/XXXX I filed the dispute the day I discovered the unauthorized charge. XX/XX/XXXX I emailed XXXX expressly stating that I did not authorize the second charge ( Ex. 7 ). XX/XX/XXXX I submitted Citis dispute form ( Form ID XXXX ) with a detailed dispute summary and timeline ( Ex. 8 ). The dispute summary listed Unauthorized Charge. XXXX charged my credit card on XX/XX/XXXX, without my authorization as Claim # 1, followed by additional numbered claims regarding workmanship. Paragraph I on page 7 further addresses the unauthorized credit charge, as does XXXX XXXX XXXX on the timeline. My submission included multiple attachments, including the XXXX Estimate ( Ex. 12 ), the XXXX Statement marked PAST DUE PLEASE REMIT dated XX/XX/XXXX ( Ex. 10 ), and the XX/XX/XXXX email from XXXX XXXX acknowledging the agreed credits ( Ex. 15 ). In response to Citis question on its form about how the charge was made, I wrote : Not in person or on phone. I do not know how they charged my card for the second payment. I had not authorized them to do so and did not give them my card. I did not receive a receipt. I only learned they charged my card when I noticed it on my Citi account. ( Ex. 8 ). XX/XX/XXXX I emailed Citi under dispute ID XXXX and expressly advised that much of the documentation I had submitted related to the other XXXX dispute XXXX XXXX. I wrote : If possible, could you please combine the files or review them together so the full context is clear? ( Ex. 16 ). This put Citi on notice that the two XXXX disputes involved overlapping facts, documents, and context. Citi did not substantively respond to that request. XX/XX/XXXX I emailed Citi clarifying that there was both defective service and a credit card charge that we did not approve, again stating that XXXX charged my credit card without authorization. XX/XX/XXXX Citi issued one letter stating that it was unable to identify or determine that a billing error occurred and reversing the conditional credits ( Ex. 21 ). Although Citis records may reflect that two letters were issued on this date, one for each of the two XXXX case IDs, I received only one such letter on or about XX/XX/XXXX, as evidenced by the screenshot of my Citi customer portal ( Ex. 19 ). This was for XXXX XXXX. XX/XX/XXXX I called Citi the day after I received the XX/XX/XXXX denial letter. The Citi representative on that call told me that Citis notes reflected that the merchant had never responded to Citis dispute submission. I again stated that I did not authorize the XX/XX/XXXX charge. Following that conversation, Citi reopened the investigation. XX/XX/XXXX / XX/XX/XXXX Citi sent two parallel Billing Dispute Update Important Information letters, one for each of the two XXXX XXXX case IDs ( XXXX for the XX/XX/XXXX charge and XXXX for the XX/XX/XXXX charge ) ( Ex. 18 ). The letters bore a XX/XX/XXXX date and demanded additional documentation by XX/XX/XXXX. Both letters stated that [ o ] nce this information is received, we will be happy to continue our investigation further. Citi also sent email requests dated XX/XX/XXXX and XX/XX/XXXX in a thread titled Citi Billing Dispute : XXXX XXXX XXXX XXXX : {$3600.00}, {$3600.00} : XXXX ( Ex. 5 ). The email body likewise stated that Citi was investigating the amount of {$3600.00}, {$3600.00}, but the email listed only one reference number, XXXX. Citi therefore used one email thread/reference number to request information about both related {$3600.00} XXXX charges. Although the letters were dated XX/XX/XXXX, they were not delivered through my portal until XX/XX/XXXX a seven-day delay confirmed by the portal screenshot, which shows a 'Date Sent ' of XX/XX/XXXX for both letters ( Ex. 19 ). The XX/XX/XXXX response deadline therefore gave me only seven days to respond, not the fourteen contemplated by the letters ' XX/XX/XXXX date. The timing is also notable in relation to Citi 's XX/XX/XXXX 'final denial ' : Citi dated the letters nine days after that denial and delivered them sixteen days after it, and Citi 's own XX/XX/XXXX letter confirms that the disputes were not formally reopened until XX/XX/XXXX three days after the letters reached me. XX/XX/XXXX I responded to Citis XX/XX/XXXX email request ( Ex. 5 ) with multiple attachments, including the XXXX Estimate ( Ex. 12 ), the XXXX Statement marked PAST DUE PLEASE REMIT ( Ex. 10 ), and other billing documents. In my response I wrote : I have two disputes related to the same amount. First, XXXX charged my card on XXXX [ XXXX ] without authorization. I again stated that the work was still disputed. Also on XX/XX/XXXX, I separately emailed Citis Legal Department ( XXXX XXXX ) and Executive Response Unit ( XXXX XXXX ) directly, copying the billing disputes team ( Ex. 17 ). In that email, I identified both dispute IDs ( XXXX and XXXX ) and explained that my initial XXXX dispute concerned an unauthorized charge, while a later XXXX dispute concerned the same merchant and defective services. I requested escalation to ensure that the dispute is being properly investigated and handled in accordance with applicable consumer protection laws. My email documented in writing that, in the XX/XX/XXXX phone call, the Citi representative had stated the bank had not even received a response from the merchant regarding the charge. I again asked Citi to confirm ( 1 ) that the dispute remained open and under review, ( 2 ) the deadline for submitting additional materials, and ( 3 ) that I would receive a written explanation of the final determination. Citi did not directly acknowledge or respond to this XX/XX/XXXX email. XX/XX/XXXX Citi reopened the disputes, as later confirmed in Citis XX/XX/XXXX letter ( Ex.2 ), which states that when the disputes were reopened on XX/XX/XXXX, the amounts were temporarily suspended. The same day, I emailed Citis Executive Response Unit and mentioned again that XXXX had charged my card on XX/XX/XXXX without authorization ( Ex. 20 ). I again asked three specific procedural questions : ( 1 ) whether Citi had all of the information I previously submitted regarding the billing disputes on XX/XX/XXXX and XX/XX/XXXX, ( 2 ) the deadline for submitting any additional materials, and ( 3 ) whether I would receive a written explanation of the final determination ( Ex. 20 ). My XX/XX/XXXX email noted : I have asked these questions regarding my billing dispute numerous times since XX/XX/XXXX and have yet to receive a response. Instead, I just get more requests asking me to send information that I have already submitted. Citi did not directly acknowledge or respond to my XX/XX/XXXX email, and the written determinations Citi eventually issued on XX/XX/XXXX and XX/XX/XXXX, did not address the procedural questions I had asked. XX/XX/XXXX I responded to Citis XX/XX/XXXX letter ( made available XX/XX/XXXX ) by the XX/XX/XXXX deadline with a written response and multiple attachments ( Ex. 22 ). My response opened by flagging the delivery timing : I am writing in response to your letter dated XX/XX/XXXX. Please note that although your letter is dated XX/XX/XXXX, I did not receive it until XX/XX/XXXX. I was given only seven days to respond, not the fourteen days contemplated by the letters XX/XX/XXXX date. My response expressly stated that ( 1 ) the services were not properly completed and the plumbing system failed shortly after the work was declared finished, and ( 2 ) the charge to my credit card on XX/XX/XXXX was made without my authorization while the work remained actively disputed. I noted that I had previously submitted much of the requested information on XX/XX/XXXX and XX/XX/XXXX. The attachments included the XXXX Estimate ( Ex. 12 ), the XXXX Statement marked PAST DUE PLEASE REMIT ( Ex. 10, marking the third submission of that document to Citi ), and the detailed dispute summary and timeline that listed Unauthorized Charge as Claim # 1 ( Ex. 8 ). My XX/XX/XXXX response also asked Citi to confirm in writing ( 1 ) whether Citi had all of my previously submitted materials, ( 2 ) the deadline for submitting additional materials, and ( 3 ) whether I would receive a written explanation of the final determination. Citi did not provide written answers to any of these procedural questions. XX/XX/XXXX Citis Billing Dispute team emailed me yet another set of documentation questions, stating : In response to your recent communication with us. We needed specific details to continue with our investigation to resolve the dispute in your favors ( Ex. 5, see also Ex. 6 ). This XX/XX/XXXX email was part of the same Citi-created email thread that listed both {$3600.00} XXXX charges in the subject line and body but included only one reference number, XXXX. I responded the same day with a detailed written argument and multiple attachments ( Ex. 6 ). My response expressly distinguished the first {$3600.00} charge, paid on XX/XX/XXXX, from the second {$3600.00} charge, made on XX/XX/XXXX. I wrote that the second charge was made even though I did not authorize this charge, nor did they send a receipt nor notify me that they were charging my card. I also explained : On XX/XX/XXXX, XXXX sent a Past Due notice even though the system had not been inspected and the pipes were still exposed ; On XX/XX/XXXX, XXXX sent my husband an email with a statement and invoice reflecting the XX/XX/XXXX payment ; and On XX/XX/XXXX, XXXX again emailed my husband requesting payment of the remaining balance. I then stated : the fact that they sent emails on XX/XX/XXXX and XXXX asking for payment further confirms that XXXX did not have authorization to charge my card. My response also stated : I intentionally did not pay the remaining balance because the system was not functioning when XXXX claimed the job was complete. I expressly invoked the Fair Credit Billing Act, asking Citi to confirm that this dispute is being handled in accordance with applicable billing dispute requirements under the Fair Credit Billing Act, and confirm that I will receive a written determination. My XX/XX/XXXX attachments included XXXX Invoice # XXXX by name ( Ex. 11 ), the XX/XX/XXXX email from XXXX to my husband ( Ex. 13 ), the XX/XX/XXXX email from XXXX to my husband ( Ex. 14 ), and the XXXX Statement marked PAST DUE PLEASE REMIT ( Ex. 10 ). XX/XX/XXXX I submitted a complaint with CFPB ( XXXX ), seeking a clear status update, confirmation that Citi has all necessary documentation, and a written determination consistent with applicable billing dispute requirements ( Ex. 24 ). XX/XX/XXXX Citi issued a written determination ( Reference Number XXXX ) declining credit ( Ex. 2 ). The determination characterized the issue as XXXX of credit card fraud, concluded that the XX/XX/XXXX charge can not be considered fraudulently transacted because I had provided your account information to the merchant for billing purposes, stated that a copy of the actual invoice was not provided, and stated that the disputed amounts would now accrue interest. Citis statement that a copy of the actual invoice was not provided is factually incorrect : on XX/XX/XXXX, I provided XXXX Invoice # XXXX to Citi ( Ex. 11 ), the PAST DUE PLEASE REMIT Statement ( Ex. 10 ), and the emails to my husband with invoices attached ( Ex. 13 and Ex. 14 ). Citis XX/XX/XXXX determination did not address the XXXX Statement marked PAST DUE PLEASE REMIT ( Ex. 10 ), which I had submitted to Citi four separate times ( XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX ) and which is the single most direct evidence that the merchant did not have standing authorization to charge my card. Later the same day ( XX/XX/XXXX ), I sent Citi a written response identifying specific factual and legal errors in Citis determination and asking two direct questions : ( 1 ) whether Citi evaluated my unauthorized-use claim under 15 U.S.C. 1643 and what evidence supported its conclusion that the XX/XX/XXXX charge was authorized, and ( 2 ) whether Citi considered Sweetwaters XX/XX/XXXX PAST DUE PLEASE REMIT statement in evaluating authorization ( Ex. 3 ). XX/XX/XXXX I submitted CFPB feedback in Case # XXXX narrowing my claim against Citi to the XX/XX/XXXX charge only and expressly identifying 15 U.S.C. 1643 as the applicable standard. ( Ex. 24 ). XX/XX/XXXX Citis Executive Response Unit acknowledged receipt of my XX/XX/XXXX letter ( my letter to Citi is Ex. 3 ), assigned Citi Reference Number XXXX, stated that my communication will receive a deliberate and thorough review, and stated that a response was anticipated within 15 calendar days ( Ex. 4 ). XX/XX/XXXX Citis Executive Response Team issued a letter ( Ex. 1 ) that did not answer either of my XX/XX/XXXX questions. The XX/XX/XXXX letter did not address XXXX, did not identify any evidence that I authorized the XX/XX/XXXX charge, did not address the PAST DUE PLEASE REMIT statement, did not address Sweetwaters XX/XX/XXXX and XX/XX/XXXX emails to my husband, did not address my XX/XX/XXXX written argument tying those documents to the unauthorized-use issue, did not acknowledge the narrowed scope of my claim, and did not engage with the substance of my XX/XX/XXXX correspondence or XX/XX/XXXX feedback. Instead, the letter referred to me internally as the cm, summarized Citis prior position, reiterated the credit-card-fraud framing, directed me to contact the merchant directly, and reaffirmed that the disputed amounts would now be subject to interest. Why Citis Fraud Framing Does Not Answer the Authorization Issue Citis XX/XX/XXXX and XX/XX/XXXX letters analyze the XX/XX/XXXX charge under a credit-card-fraud standard and conclude that the charge can not be fraudulent because I had previously provided card information to the merchant. That is not the test. My claim is not that an unknown third party stole my card. My claim is that XXXX was not authorized to charge my card on XX/XX/XXXX. I made the applicable legal standard and the supporting facts explicit in writing on XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX. Citi nonetheless continued to apply the wrong framework. Providing card information for XXXX authorized transaction does not constitute authorization for all future charges. Sweetwaters own contemporaneous billing conduct demonstrates that XXXX was not acting under standing authorization. Citi had the XX/XX/XXXX PAST DUE statement in its possession from XX/XX/XXXX onward. Although the two XXXX disputes had separate reference numbers, I expressly asked Citi on XX/XX/XXXX to combine the files or review them together ( Ex. 16 ), and Citis own XXXX email thread treated the two disputes as related by listing both {$3600.00} charges. Citi had the XX/XX/XXXX and XX/XX/XXXX payment-link emails and my written explanation tying them to the unauthorized-use issue from XX/XX/XXXX onward : On XX/XX/XXXX, XXXX sent a billing statement marked PAST DUE PLEASE REMIT for {$3600.00}, demanding that I remit payment ( Ex. 10 ). I submitted this statement to Citi on XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX. On XX/XX/XXXX, XXXX Plumbing emailed my husband a Statement and Invoice with the instruction See payment link here : Make an Online Payment ( Ex. 13 ). I submitted this email to Citi on XX/XX/XXXX. On XX/XX/XXXX, three days before the unauthorized charge, XXXX XXXX emailed my husband Invoice # XXXX with the subject line Your Invoice from XXXX XXXX, the statement The job is complete. Please find your invoice from XXXX XXXX attached below! and the instruction Pay online at : Make an Online Payment ( Ex. 14 ). I submitted this email to Citi on XX/XX/XXXX. On XX/XX/XXXX, with no further communication, no receipt, and no notification, XXXX charged my card {$3600.00}. A merchant operating under standing card authorization does not send a Past Due Please Remit statement, then send the customer pay online payment-link emails twice in five days, and then unilaterally charge the card three days later without further communication. XXXX own pre-charge conduct is incompatible with any claim of standing authorization. Citi has had all of these documents for months. The XXXX PAST DUE statement and the XX/XX/XXXX email from XXXX XXXX acknowledging the agreed credits were submitted on XX/XX/XXXX with my initial dispute packet ( Ex. 10 and Ex. 15 ). Citi resubmitted its request for documentation on XX/XX/XXXX, and I again provided the PAST DUE statement, the XXXX Estimate, and additional billing documents again on XX/XX/XXXX ( Ex. 5 ). On XX/XX/XXXX I provided additional attachments, including XXXX Invoice # XXXX by name and the XX/XX/XXXX and XX/XX/XXXX merchant emails sending payment links to my husband ( Ex. 6, Ex. 11, Ex. 13, and Ex. 14 ). I expressly identified the Past Due notice and the XX/XX/XXXX merchant email in writing in my XX/XX/XXXX response. Citis XX/XX/XXXX determination nevertheless stated that a copy of the actual invoice was not provided. That statement is factually incorrect. The XX/XX/XXXX authorization was a one-time phone authorization. Technician XXXX XXXX called XXXX office, and I provided card information over the phone to a XXXX finance representative for a single installment payment of {$3600.00}. I did not provide my card to XXXX again, did not authorize any recurring or standing charges, did not sign any authorization document, and did not authorize the XX/XX/XXXX charge in any form. Notably, XXXX own Invoice # XXXX ( Ex. 11 ), which Citi has had since XX/XX/XXXX, records the XX/XX/XXXX payment method as XXXX. The XX/XX/XXXX payment was in fact made on my Citi XXXX XXXX XXXX, the same account on which Citi posted the disputed XX/XX/XXXX charge. The merchant 's own records therefore misidentify the network of the card it claims to have on file ( which is a material inaccuracy that undercuts any inference that XXXX possessed reliable standing authorization ), and the merchant 's records identifying a XXXX can not be the source of authorization on my XXXX account. Citi has had nearly five months to identify any signed authorization for the XX/XX/XXXX charge. It has not done so. Invoice # XXXX contains a pre-printed Customer Authorization block, but the signature lines on the copy in Citis possession are blank. Despite multiple submissions on XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX, and despite my explicit written articulation of the unauthorized-use theory on XX/XX/XXXX, Citi has never identified any signed authorization, receipt, recorded authorization, merchant submission/representment materials, transaction authorization data, internal notes, or other documentation showing that I gave actual, implied, or apparent authority for the XX/XX/XXXX charge. If Citi or the merchant possesses a signed authorization, I request that it be produced. Citis Procedural Conduct Citis procedural conduct throughout this dispute is itself relevant to whether Citi conducted a reasonable investigation under 12 C.F.R. 1026.13 ( f ). Four patterns stand out : First, Citi compressed deadlines on the consumer while extending its own timelines. Citis XX/XX/XXXX letters set a XX/XX/XXXX deadline based on the date of the letters, but my Citi customer portal shows the letters were not made available to me until XX/XX/XXXX ( Ex. 19 ). That gave me seven days to respond, not the fourteen contemplated by the letters XX/XX/XXXX date. Citi gave itself approximately two months from its XX/XX/XXXX 'final denial ' ( and seven weeks from the formal reopen on XX/XX/XXXX ) to issue the XX/XX/XXXX determination. Second, Citis own communications blurred the two disputes. On XX/XX/XXXX, I asked Citi to combine the files or review them together because the two XXXX disputes involved overlapping documentation ( Ex. 16 ). Citi did not substantively respond. Then, on XX/XX/XXXX and XX/XX/XXXX, Citi sent email requests in a thread identifying both {$3600.00} charges but only one dispute reference number, XXXX ( Ex. 5 ). I responded in that Citi-created thread. Citi later issued determinations on both disputes at the same time. Citi can not reasonably disregard the substance of my XX/XX/XXXX response merely because its own email thread listed only one of the two dispute numbers. Third, Citi sent two parallel we require additional documentation letters dated XX/XX/XXXX ( delivered through the portal XX/XX/XXXX ), one for each case ID, both requesting overlapping documentation that I had already submitted on XX/XX/XXXX and XX/XX/XXXX after Citis purported final denial and before Citi formally reopened the investigation on XX/XX/XXXX. Citi has not explained how the disputes could be both resolved and the subject of active documentation requests at the same time. Fourth, Citi did not answer specific procedural questions I asked in writing on multiple occasions. My XX/XX/XXXX email to Citis Legal Department and Executive Response Unit ( Ex. 17 ), my XX/XX/XXXX email to the Executive Response Unit ( Ex. 20 ), and my XX/XX/XXXX response to Citis documentation request ( Ex. 22 ) each asked Citi to confirm whether previously submitted materials had been received, the deadline for additional submissions, and whether I would receive a written explanation of the final determination. My XX/XX/XXXX letter ( Ex. 3 ) additionally asked Citi to confirm whether it had evaluated the XX/XX/XXXX charge under XXXX and what evidence it relied on. Citi did not directly acknowledge or answer any of these procedural questions. Citi eventually issued written determinations on XX/XX/XXXX and XX/XX/XXXX addressing the underlying dispute, but those determinations did not answer the specific procedural questions or identify the regulatory standard Citi applied. New Conduct Since the Closure of CFPB Case # XXXX Three pieces of new conduct since the prior CFPB case warrant attention : First, Citis XX/XX/XXXX letter ( Ex. 1 ) followed Citis XX/XX/XXXX commitment to a deliberate and thorough review of my XX/XX/XXXX letter ( Ex. 4 ), but it did not engage with the specific questions I posed, did not acknowledge the narrowed scope of my claim as expressed in my XX/XX/XXXX CFPB feedback ( Ex. 24 ), and did not address XXXX even though I had expressly identified it as the applicable standard. The letter did not address the PAST DUE PLEASE REMIT statement, did not address the invoice, did not address the XX/XX/XXXX and XX/XX/XXXX merchant pay online emails, did not address my XX/XX/XXXX written articulation of the unauthorized-use theory, and did not acknowledge the substance of my XX/XX/XXXX correspondence. It summarized Citis prior position, without addressing any of the specific points raised in my XX/XX/XXXX letter or XX/XX/XXXX feedback. This indicates that the response did not reflect the deliberate and thorough review Citi had promised. Second, Citis XX/XX/XXXX letter stated that, with the investigation complete, the disputed amounts would be included in the Balance Subject to Interest Charge, and Citis XX/XX/XXXX letter reaffirmed that interest would now accrue. I object to interest being assessed on the XX/XX/XXXX charge while Citi has not meaningfully addressed my claim under the applicable TILA, FCBA, and Regulation Z standards, including whether the charge was authorized and what evidence supports Citis determination. Citi acknowledges in its XX/XX/XXXX letter that the disputed amounts were properly excluded from interest accrual during the pendency of the dispute. An investigation that does not satisfy the reasonable-investigation requirements of 1026.13 ( f ), and that applied a credit-card-fraud standard rather than the unauthorized-use or billing-error standards required by 1026.13 ( a ) and 1643, does not entitle Citi to resume interest assessment on amounts that remain in dispute under 1026.13 ( g ). Third, Citis reversal of the conditional credits on XX/XX/XXXX and its decision to treat the disputed {$3600.00} as a valid balance has had a measurable adverse effect on my credit. My XXXX score declined from XXXX in XX/XX/XXXX to XXXX in XXXX and XX/XX/XXXX, which is a XXXXpoint drop ( Ex. 23 ). The decline tracks Citi 's XX/XX/XXXX reversal of the conditional credits, which inflated my reported credit utilization on the Citi account at a time when the underlying authorization question remained unresolved and the disputed {$3600.00} should not have been treated as a valid balance under 1666a. Until Citi evaluates the XX/XX/XXXX charge under the correct legal standard and produces evidence supporting any conclusion of authorization, the disputed {$3600.00} should not be reported as a valid balance, should not accrue interest, and should not be treated as a settled item on my account.

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