Consumer complaint received 2025-10-30 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Problem when making payments — Problem during payment process
Company: CLGF Holdco 1, LLC
State: GA

Complaint narrative:
FORMAL COMPLAINT AND REQUEST FOR INVESTIGATION Against Concora Credit Inc. ( Servicer ) and XXXX XXXX XXXX XXXX ( Issuer ) CFPB Case : # XXXX Complainant : XXXX XXXX XXXX XXXX XXXX 
XXXX Bridge XXXX XXXX XXXX, XXXX XXXX XXXX, GA XXXX Phone : ( XXXX ) XXXX : XXXX Date : XX/XX/year> I. Summary of Complaint This filing supplements and expands upon my earlier CFPB complaint concerning Concora Credit Inc., servicer for the Milestone Mastercard issued by XXXX XXXX XXXX XXXX It presents new evidence that Concora : 1. Reversed a verified debit-card payment without notice or proof of decline ; 2. Reported the account as delinquent despite full and timely payment ; 3. Failed to investigate or substantiate its own claim when formally disputed ; and 4. Responded with irrelevant fee information instead of addressing the payment reversal.

These actions appear to form part of a systemic pattern designed to maintain subprime credit statuses and fee revenue at the expense of consumers credit scores. 

XXXX. Chronology of Events XXXX. XX/XX/year> XXXX XXXX : I made a payment of {$1100.00} via debit card to pay my Milestone Mastercard balance in full. Debit transactions are authorized in real time; had funds been unavailable, the payment would have been instantly declined. The payment was confirmed and accepted by Concora. 
XXXX. XX/XX/year> Unnotified Reversal : Concora internally reversed the payment 13 days later. I received no notice by email, text, phone, or mail from either Concora or my bank. My bank records show no return or decline of that debit transaction. 
XXXX. August 2122 2025 XXXX XXXX : Upon discovering the issue myself, I immediately made corrective payments of {$250.00} and {$620.00}, bringing the account current and paid in full. Concora representatives acknowledged the lack of notice and promised to waive fees. 
XXXX. XX/XX/year> Account XXXX : XXXX balance reached {$0.00}. The XX/XX/year> statement shows Payment Received Thank You, Refund of Late Fees, and Monthly Fee Refund. 
XXXX. XX/XX/year> Formal Written Dispute : I issued a written demand for correction and investigation under the FCRA 1681s-2 ( b ) and FCBA 161 ( b ), requesting documentation of any claimed payment rejection. 
XXXX. XX/XX/year> Concora XXXX : Concora closed the dispute stating the account information was accurate and complete, citing only a {$19.00} monthly maintenance fee unrelated to the dispute. No evidence of a debit-card decline or bank notice was provided. 
XXXX. XX/XX/year> Account Access Blocked : All three of my Concora-serviced accounts became inaccessible online, each showing Unable to Access Account. Screenshots attached. 

III. Violations of Law and Procedure 1. Failure to Provide Proof or Notice of Decline o No bank return documentation, authorization code, or merchant log verifying a decline.

o Violation of FCBA 161 ( b ) and Electronic Fund Transfer Act 1693f, requiring prompt notice and error resolution for electronic transactions.

2. False or Misleading Credit Reporting o Reporting a 30-day delinquency despite timely payment violates FCRA 1681s-2 ( a ).

3. Failure to Conduct a Reasonable Investigation o Ignoring key evidence and responding with unrelated fee data violates FCRA 1681s-2 ( b ) and 1681i ( a ) ( 1 ).

4. Failure to Disclose Method of Verification o Concora did not identify how or with whom verification was performed, violating FCRA 1681i ( a ) ( 7 ).

5. Potential Unfair, Deceptive, or Abusive Acts or Practices ( UDAAP ) o The combination of delayed reversals, absent notice, and irrelevant responses suggests a pattern of conduct designed to keep consumers credit scores artificially low, sustaining high-fee subprime card profitability. 

IV. Evidence of Systemic Harm Debit payments are verified instantly ; subsequent reversals are internal actions. 
XXXX statements showing fee refunds prove it recognized internal error. 
Their reinvestigation ignored all supporting documentation, focusing instead on an irrelevant {$19.00} fee. 
The business incentive aligns : lower credit scores continued subprime status continued monthly-fee revenue. 

V. Relief Requested I respectfully request that the CFPB and OCC : 1. Compel Concora Credit Inc. and XXXX XXXX XXXX XXXX to produce documentary proof of any debit-card decline or return notice from my bank. 
XXXX. Delete all derogatory reporting from the credit bureaus associated with the XX/XX/year> cycle. 
XXXX. Provide written confirmation that my account is current and paid in full. 
XXXX. Investigate XXXX internal procedures for debit-payment handling, reversals, and consumer notification. 
XXXX. Examine whether similar patterns exist across other Concora or Bank XXXX Missouri subprime portfolios to determine if these practices constitute a UDAAP or systemic compliance failure. 

ADDENDUM TO CFPB COMPLAINT FAILURE TO SUBSTANTIATE PAYMENT REVERSAL Complainant : XXXX XXXX XXXX XXXX. 
XXXX Bridge XXXX XXXX XXXX, XXXX XXXX XXXX, GA XXXX Date : XX/XX/year> CFPB Case # : XXXX I am submitting this addendum based on Concora Credit XXXX XX/XX/year> XXXX packet. The materials provided do not contain any documentary proof that my XX/XX/year> debit-card payment of {$1100.00} was declined or returned by my financial institution. 

The account ledger supplied by Concora shows that the debit payment was accepted and credited as Payment Received Thank You, then internally offset the same day with an Adjustment-Payments entry for the identical amount. Thirteen days later, on XX/XX/year>, Concora applied and then refunded a XXXX Check Charge {$30.00}. These are internal accounting actions, not bank-initiated reversals. 

XXXX packet also included a form letter verifying only a {$19.00} monthly maintenance fee and generic cardholder disclosures. It offered no bank return documentation, authorization decline, merchant XXXX record, or consumer notice of reversalall of which I specifically requested in my written dispute dated XX/XX/year>. My bank has confirmed there was no declined or returned debit transaction on or after XX/XX/year>. 

This constitutes a failure to conduct a reasonable investigation under FCRA 1681s-2 ( b ) and 1681i ( a ) ( 1 ), a failure to provide required verification information under 1681i ( a ) ( 7 ), and a violation of the FCBA 161 ( b ) and EFTA 1693f for lack of timely notice and documentation. 

XXXX response effectively verifies information it could not substantiate, resulting in continued false reporting of a 30-day delinquency. I request that regulators compel Concora and XXXX XXXX XXXX XXXX  to : Produce verifiable evidence from my financial institution that any debit-card decline occurred, or remove the derogatory tradeline from all credit bureaus. 

Provide written confirmation that my Milestone Mastercard account is current, paid in full, and in good standing. 

Refund all fees or charges connected to this reversal and ensure no retaliation or account restriction results from my dispute. 

Review internal payment-processing and dispute-handling procedures for compliance with FCRA, FCBA, EFTA, and UDAAP standards.

Concoras inability to produce evidence of a legitimate bank decline supports my contention that the reversal was initiated internally, not by my bank, and that the subsequent negative reporting is inaccurate and harmful.

Company response to consumer: Closed with explanation