Consumer complaint received 2025-05-25 00:00:00
Product: Prepaid card — Government benefit card
Issue: Trouble using the card — Problem with direct deposit
Company: BANK OF AMERICA, NATIONAL ASSOCIATION
State: CA

Complaint narrative:
I am submitting this complaint regarding the Bank of America IRP ( Independent Review Process ) for prepaid debit card holders. This is now my second experience facing the same systemic issue being wrongly denied financial harm compensation that I am entitled to.Despite submitting documentation that proves my vehicle was repossessed during the eligible window of XX/XX/XXXX to XX/XX/XXXX, I was told the documents do not show repossession or repossession-related activity. This mirrors my previous IRP denial, where I was told to submit documents for XXXX XXXX XXXX only to later discover that the automated system used by XXXX XXXX was set to recognize documents only between XX/XX/XXXX and XX/XX/XXXX, excluding critical proof. Bank of America and XXXX XXXX appear to be using a System Automation Review to filter and evaluate submitted documents.This system rejects valid evidence unless it meets rigid format or keyword expectations, even if it clearly supports financial harm due to blocked access to funds.Such use of automation to make eligibility determinations violates the spirit of the CFPB consent orders, which require fair and transparent review processes. XXXX XXXX, the alleged independent third party overseeing the XXXX, holds a {$900.00} XXXX senior secured credit facility arranged by BofA XXXX XXXX XXXX a subsidiary of Bank of America ( XXXX XXXX XXXX, XX/XX/XXXX ) .This relationship compromises the neutrality of the XXXX XXXX process, casting doubt on the fairness of decisions made by XXXX.It is misleading and unethical for Bank of America to present XXXX XXXX independent while maintaining such substantial financial leverage over the firm. The continued use of a biased, opaque automation system and the undisclosed financial conflict with XXXX XXXX are violations of prior CFPB consent orders.I experienced actual damages from my account being frozen, including vehicle repossession, loss of credit, and emotional and financial distress yet automation and financial entanglement are preventing meaningful review or resolution. This is the second time I have experienced a wrongful denial of my valid XXXX  claim for compensation related to financial harm that occurred when Bank of America froze access to my XXXX prepaid account during the XXXX pandemic. 
Despite submitting documentation showing that I experienced a vehicle repossession caused by missed payments during the time Bank of America froze my funds, I was told my documents do not show repossession or repossession-related activity during the required timeframe. However, my entire payment history clearly shows that I missed payments during the period my funds were unavailable due to the automated account freeze system used by Bank of America. Let me be clear : I was never late on my car payments until Bank of America froze my XXXX funds using an automated system that they were later forbidden to use under CFPB consent orders. Once my funds were cut off, I missed car payments and was never able to recover or bring the account current. 
This caused me to be XXXX days behind at all times, accumulating additional interest and penalties.This financial snowball eventually led to the repossession of my vehicle not because of inability to pay, but because of Bank of America 's actions. My repossession occurred outside the exact freeze period, but was directly caused by the payment disruption that began during it.I submitted a repossession discharge letter, full payment history, and supporting documentation clearly showing this chain of events. The XXXX  rejection of this evidence is both factually wrong and procedurally unfair. 
It is also highly concerning that XXXX XXXX the XXXX of this XXXX  is not independent. In XX/XX/XXXX, XXXX announced a {$900.00} XXXX credit facility arranged by a syndicate of banks that includes BofA XXXX XXXX XXXX, a subsidiary of Bank of America. This establishes a financial conflict of interest between the reviewing administrator and the party being investigated. This makes it impossible to consider the XXXX a neutral or fair process, especially when decisions are being filtered through a System Automation Review that appears to replicate the very automated account-blocking behavior the CFPB previously prohibited. Having already been wrongfully denied once under this program due to a document scanning system that only recognized records from XX/XX/XXXX to XX/XX/XXXX I now see the same flawed automation is being used again, only now disguised within the XXXX via XXXX XXXX have been going back and forth with XXXX XXXX and Bank of AMERICA for over a year now trying to be compensated for my damages caused by bank of americas account freeze as i have the right to ordered by CFPB consent ordered BANK of AMERICA to do.If this request is denied by XXXX XXXX again, I will withdraw my XXXX submission and begin a full litigation in the amount of {>= $1,000,000} for damages including repossession-related loss, credit damage, and emotional harm and all legal fees as well as bring this information public to inform anybody else who may have denied there request via major news outlets and social media enough is enough BANK OF AMERICA XXXX it seems BofA 's unethical tactics are now starting to smear off on its business associates or maybe it because a handful of XXXX XXXX execs. were prior Bof A execs.another reason for my concerns on the decision on XXXX XXXX  being a THIRD PARTY INDEPENDENT ADMINISTRATOR and not a sister company!

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