Consumer complaint received 2025-05-21 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Other features, terms, or problems — Other problem
Company: CAPITAL ONE FINANCIAL CORPORATION
State: ME

Complaint narrative:
To the Consumer Financial Protection Bureau, I am filing a complaint against Capital One regarding their denial of my request for a credit line increase on my XXXX Credit Card, which I believe may violate the Equal Credit Opportunity Act ( ECOA ). I received a denial letter stating that my request was declined because the " recent use of this accounts existing credit line has been too low, '' despite my responsible credit usage. To seek clarity, I called Capital One at XXXX XXXX  EST on XX/XX/year> to inquire further about why I was denied a reasonable credit line increase of an additional {$2000.00} on my existing credit line, and if they could provide more information on why I was denied and what they are looking for so I could be approved. 
I typically keep a balance of about 10-20 % carryover on my credit card to maintain a good credit score. I utilize the credit card considerately, as the customer service agent informed me that within my last period, I used about ~ {$1000.00} of my {$4000.00} limit, which is approximately ~25 % of my total line of credit I also make additional payments to avoid carrying over a high balance and to ensure positive credit reporting to the three credit bureaus. Despite this responsible behavior, Capital One denied my request, and I am concerned that their policies may unfairly penalize me and potentially violate the ECOA. I would like the CFPB to investigate the following issues : Disparate Impact on Protected Groups : Capital Ones policy of denying credit line increases for too low credit utilization may disproportionately affect protected groups, such as women, older adults, or minorities, who are more likely to keep balances lowlike my ~10-20 % usageto maintain good credit scores or avoid debt. If this policy limits their access to credit, it could violate the ECOAs disparate impact doctrine.

Inadequate Explanation of Adverse Action : The ECOA requires lenders to provide specific, actionable reasons for adverse actions. Capital Ones stated reas
on '' recent use of this accounts existing credit line has been too low '' is vague, even after my call for clarification. They did not specify what too low means ( e.g., a percentage or time frame ) or how my ~25 % utilization fails to meet their criteria, making it difficult for me to address the issue and potentially violating ECOA notification requirements.

Potential for Hidden Bias in Algorithms : If Capital One uses automated systems to evaluate credit line increase requests, these systems may inadvertently weigh factors like my low utilization in ways that correlate with protected characteristics, introducing bias. This could violate the ECOA if it results in discriminatory outcomes, even if unintentional.

Penalizing Responsible Financial Behavior : I maintain a low credit utilization of 10-20 %, with usage around 25 % in my last period, to protect my credit scorea widely recommended practice. Capital Ones policy penalizes me for this responsible
behavior by denying my credit line increase, which could restrict my financial flexibility for future purchases. If this policy disproportionately impacts protected groups who, like me, are more likely to maintain low utilization, it may contribute to a disparate impact under the ECOA.

I request that the CFPB investigate Capital Ones policies for potential ECOA violations, particularly regarding disparate impact and the fairness of penalizing low credit utilization. I have attached the denial letter from Capital One and can provide additional details if needed. Please advise on next steps.

Company response to consumer: Closed with explanation