Consumer complaint received 2025-08-16 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Personal line of credit
Issue: Charged fees or interest you didn't expect — 
Company: Avant Holding Company, Inc.
State: PA

Complaint narrative:
CFPB Complaint Against Avant , LLC Subject : Misrepresentation of Consumer Credit Transaction, TILA/Regulation Z Violations , and Inaccurate Credit Reporting To Whom It May Concern : I am submitting this complaint against Avant , LLC regarding serious violations of the Truth in Lending Act ( TILA ), Regulation Z, the Fair Credit Reporting Act ( FCRA ), and related accounting and banking regulations.

1. Misrepresentation of the Nature of the Transaction The agreement with Avant is styled as a loan, but in substance it is a consumer credit transaction. Under TILA ( 15 U.S.C. 1602 ( f ) ) and Regulation Z ( 12 C.F.R. 1026.2 ( a ) ( 14 ) ), the transaction falls within the definition of consumer credit. My signature on the application and contract constituted a negotiable instrument and was recorded as an asset on Avants books under the Uniform Commercial Code as adopted in Pennsylvania ( 13 Pa. Cons. Stat. 3104, 3303 ).

Avant extended credit based on this instrument but misrepresented the transaction as a loan of money. No actual funds were lent by Avant, making the contract void for misrepresentation.

2. Finance Charge and TILA/Regulation Z Violations The contract discloses a finance charge. Pursuant to 15 U.S.C. 1605 and 12 C.F.R. 1026.18 ( d ), the finance charge must represent the total cost of credit, disclosed at the outset. 

Avant continues to charge ongoing interest in addition to the disclosed finance charge. 

This constitutes double-charging and a failure of proper disclosure under TILA and Regulation Z.

3. Improper Credit Reporting and Charge-Off Handling Avant has reported the account to consumer reporting agencies in a manner that conflicts with federal law : Under FCRA, 15 U.S.C. 1681s-2 ( a ) ( 1 ) ( A ), furnishers must not report information they know or should know is inaccurate.

OCC Bulletin 2000-20 and the Federal Reserve Accounting Manual ( FRAM, 5.2, Charge-Offs ) require that once an account is charged off, it must be reported with a XXXX balance. 

Avants continued reporting of a balance after charge-off is inaccurate and unlawful.

4. Request for Regulatory Action Avants practicesmisrepresenting a consumer credit transaction as a loan, misapplying the definition of finance charges, and furnishing inaccurate post-charge-off dataare deceptive, misleading, and unlawful.

I respectfully request that the CFPB : Investigate Avants use of consumer applications as negotiable instruments without disclosure.

Review Avants compliance with TILA/Regulation Z finance charge disclosure requirements.

Order Avant to delete all negative credit reporting related to this account, including any charge-off notations, as the account was never properly validated.

Require Avant to provide full accounting records showing how my signed application was treated on its books and records, including any transfer, sale, or monetization of the instrument.

Company response to consumer: Closed with explanation