Consumer complaint received 2026-02-21 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Problem with a purchase shown on your statement — Credit card company isn't resolving a dispute about a purchase on your statement
Company: AMERICAN EXPRESS COMPANY
State: AR

Complaint narrative:
CFPB COMPLAINT / FORMAL DISPUTE ESCALATION Company : American Express National Bank Consumer : XXXX XXXX : XXXX XXXX XXXX  XXXX XXXX XXXX, AR XXXX Accounts : XXXX XXXX XXXX ( ending XXXX / XXXX ) ; Business Gold ( ending XXXX ) Issue : Regulation Z Billing Error Investigation and Procedural Compliance COMPLAINT NARRATIVE This complaint concerns American Express 's repeated closure of documented billing disputes based solely on a " XXXX '' timing assertion, without addressing certified written notices, merchant coding irregularities, or previously established knowledge of the disputed activity. 

The issue presented is not whether a charge was processed through the payment network, but whether American Express complied with its investigation obligations under the Fair Credit Billing Act ( 15 U.S.C. 1666 ) and Regulation Z ( 12 C.F.R. 1026.13 ).

American Express has issued multiple form letters stating : " Because this dispute was reported more than 60 days after your statement date, we weren't able to investigate it. '' This statement mischaracterizes the regulatory framework.

I. THE 60-DAY PROVISION DOES NOT ELIMINATE INVESTIGATIVE AUTHORITY 12 C.F.R. 1026.13 ( b ) ( 1 ) defines when certain statutory protections are automatically triggered upon timely written notice. It does not prohibit investigation outside 60 days, nor does it remove creditor authority to evaluate billing errors. 


The repeated use of a categorical " unable to investigate '' position suggests a procedural policy rather than an individualized review of the dispute. 
The complaint requests CFPB review of whether American Express is : Treating the XXXX provision as a jurisdictional bar, Or using it to decline review despite documented written notice and knowledge.

II. EARLY KNOWLEDGE AND REPEATED WRITTEN NOTICE American Express received written notice of these disputed transactions in early XX/XX/year>. Additional certified correspondence followed. 

Once a creditor receives notice of a potential billing error, Regulation Z requires a reasonable investigation and written explanation of findings ( 1026.13 ( f ) ).

Despite this knowledge trigger, subsequent dispute closures in XX/XX/year> relied solely on the XXXX language without addressing : The certified mail receipts, The evidence submitted, Or the timeline of prior notice. 

The concern is whether internal records reflecting earlier notice were considered before closing the disputes. 

III. MCC MISCODING AND STATEMENT ACCURACY The merchants involved ( XXXX, XXXX XXXXXXXX XXXX XXXX XXXXXXXX ) operate as sweepstakes-gaming platforms. The transactions were processed under merchant category codes ( MCCs ) that did not reflect the restricted MCC 7995 typically associated with gambling activity.

Improper MCC coding and obscured trade names may constitute billing errors under : 12 C.F.R. 1026.13 ( a ) ( 3 ) ( incorrect amount or description ) 12 C.F.R. 1026.13 ( a ) ( 6 ) ( statement inaccuracies ) These issues are independent of whether an authorization code was generated. The periodic statement must accurately reflect the nature of the transaction. 

The complaint requests review of whether American Express evaluated the coding discrepancy as part of its investigation.

IV. FAILURE TO ADDRESS CERTIFIED MAIL NOTICE Formal written notices were transmitted via certified mail consistent with FCBA requirements. American Express 's dispute-closure letters do not reference : The certified mail tracking, The dates of delivery, Or the contents of the written submissions. 

Section 1026.13 ( f ) requires a written explanation of findings after investigation. A generic reference to " 60 days '' does not address the substance of a written billing error notice. The concern is whether the investigation obligation was bypassed rather than fulfilled.

V. DIGITAL WALLET PROVISIONING IS NOT DISPOSITIVE If reliance is placed on Apple Pay provisioning or the presence of an authorization code, that information alone does not establish that : The statement was accurate, The transaction description was proper, Or that no billing error exists. 

Provisioning demonstrates device enrollment - not necessarily accurate merchant classification or legal authority of the underlying charge. 

VI. INCONSISTENT APPLICATION OF THE 60-DAY POSITION American Express has , in prior instances, investigated disputes submitted beyond XXXX days. If the XXXX window is discretionary in practice, it should not function as a categorical bar in this instance. This raises a compliance consistency concern appropriate for supervisory review.

Company response to consumer: Closed with explanation