Consumer complaint received 2025-12-23 00:00:00
Product: Checking or savings account — Checking account
Issue: Problem with a lender or other company charging your account — Transaction was not authorized
Company: BANK OF AMERICA, NATIONAL ASSOCIATION
State: VA

Complaint narrative:
This is for the same issue that I asked to be investigated before. I have received no response and no acknowledgment from when I asked them to read why they are required by law to treat milestone claims as one continuous transaction. They simply approved two and denied six CONNECTED charges, then closed it due to timeframes, which is not allowed according to their own rules that I will re-list below. 

This is a project that the merchant never delivered on after two years of milestone payments and nine missed deadlines. They have taken over {$38000.00} from me and delivered nothing. 


This is for claims : XXXX, XXXX, XXXX, XXXX, XXXX, and XXXX. 

( Transactions XXXX and XXXX were already refunded. The connected charges were not even looked into because bank employees were unfamiliar with the bank 's timeline procedure for milestone payments ). 


I would also like to note that on at least one of the complaints, a bank employee incorrectly spelled XXXX XXXX as XXXX XXXX XXXX. I had asked it to be fixed, but I don't believe anyone did anything. 


I am disputing the procedural closure of my claims and requesting immediate reopening. The bank improperly applied standard transaction timeframes without addressing delayed discovery, continuous merchant representations, and the fact that all disputed charges arise from one ongoing service contract that resulted in complete non-delivery. 

Banks often deny older disputes by citing standard chargeback windows, but those windows DO NOT apply when : 1. The merchants non-performance was not reasonably discoverable until later 2. Multiple charges are part of a single, continuous contract 3. The merchant retained funds while representing that work was ongoing 4. The consumer made good-faith efforts to resolve directly 5. The product was never delivered All of these apply to my case. They are explicit exceptions in card-network and regulatory guidance.

CFPBs Fair Credit Billing Act, which is federal law, supports this. The key principle is that billing errors include charges for goods or services not delivered as agreed. Most critically, the 60-day notice applies to the initial notice and should not bar investigation when the error was not reasonably discoverable. 

CFPB also repeatedly states that banks must consider ongoing merchant misrepresentation, which is what has been denied to me. In the investigation, all charges were treated as separate but they were all for the same, ongoing project. Since two have been investigated and granted on the grounds of non-delivery, legally, it means the other six related/connected charges should have also been approved.

According to the CFPB supervision manual, the bank must not rely on procedur
al shortcuts such as timeframe does not apply when the facts support ongoing merchant misconduct where one or more of those related purchases is within the timeframe. If one of the charges is in, then ALL connected charges are legally considered within the timeframe.

Denying six connected charges without addressing the relationship between them was a mistake on the Banks part, but a common one that I will ask them to rectify. 

XXXX XXXX XXXX state that that no-delivery equals an ongoing service. It also states that multiple transactions can form one service agreement. This means that the dispute timeframe may be calculated from the date the consumer became aware of non-delivery, not the transaction date. 

According to the Connected Transaction Doctrine, if the payments are milestone-based, all tied to one contract, to the same merchant, and paid with the same promised end product, these charges are REQUIRED to be evaluated together as one purchase, not chopped up to approve some and deny others. Since two of the charges were approved and refunded ( thank you for that ), the other six are also LEGALLY REQUIRED to be refunded due to their milestone connection. 

Due to this, I will formally assert procedural failure on the grounds that the bank improperly closed these disputes. They did so without addressing delayed discovery, continuous merchant representations, and the fact that all disputed charges were part of a single, ongoing service contract that resulted in complete non-delivery.

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