Consumer complaint received 2025-10-14 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Other features, terms, or problems — Other problem
Company: NAVY FEDERAL CREDIT UNION
State: TX

Complaint narrative:
1. Background I am a member of Navy Federal Credit Union ( since XXXX ). 

In XX/XX/XXXX, I applied for a credit limit increase. 

My credit history with Navy Federal shows no. I also have not delinquencies on any of reports with XXXX XXXX XXXX XXXX. These were my approximate credit scores as the time with no no negative entries : Credit score : XXXX XXXX XXXX XXXX XXXX XXXX. 

I have maintained positive payment behavior, including paying loans months in advance. 

Other institutions ( XXXX, XXXX ) have approved increases under the same financial circumstances. 

2. Timeline of Interactions with Navy Federal XX/XX/XXXX My initial request for reconsideration NFCU denied my request citing delinquent performance with Navy Federal. 
This is factually incorrect, as I have never been delinquent with NFCU. 

XX/XX/XXXX NFCU response They reiterated denial and claimed recent late payments but admitted they were not 30+ days past due. 

XX/XX/XXXX My escalation request I asked for manager review and demanded specific evidence of the alleged late payments. 

XX/XX/XXXX NFCU response They admitted : While your accounts have not been over 30 days past due, they do have history of the payments not being made by the due date. 
No dates, products, or specifics were provided. 

XX/XX/XXXX My formal ECOA/Reg B request I invoked 12 CFR 1002.9 ( a ) ( 2 ) and requested : Specific accounts relied upon Dates and billing cycles in question The internal standards applied XX/XX/XXXX NFCU response Management confirmed review but again denied my request, citing only vague credit performance criteria. 

XX/XX/XXXX NFCU final response They stated only : We regret that a more favorable reply could not be made, refusing to provide specifics. 

3. Regulatory Violations Failure to Provide Specific Adverse Action Reasons Under 12 CFR 1002.9 ( a ) ( 2 ), creditors must provide a statement of specific reasons for adverse action. 
NFCUs reliance on vague phrases ( internal performance, credit criteria ) does not meet this standard. 

Use of Opaque Internal Criteria Instead of disclosing valid underwriting factors, NFCU appears to use generalized language to shield non-transparent decision-making. 

Potential Consideration of Government Employment ( Shutdown Impact ) As a federal government employee, I am concerned that NFCU considered employment source or the government shutdown as a negative factor. 
If true, this constitutes an unlawful underwriting factor under ECOA, and disproportionately affects minorities and military families raising disparate impact concerns. 

Pattern of Discrimination NFCU has already been the subject of public fair lending and discrimination cases in mortgage lending. 
Their continued use of vague and non-compliant underwriting explanations suggests that systemic discriminatory issues may extend beyond mortgages into other credit products. 

4. How this harms me : Denial of access to increased credit despite a positive history. 

Arbitrary denial while other institutions approved increases under the same conditions. 

Potential reputational harm from being incorrectly characterized as delinquent. 

Possible higher utilization ratios and reduced financial flexibility due to denial. 

I am disputing Navy Federals denial of my credit limit increase because the decision is not supported by any valid or specific reason. My accounts are current, I have never been 30+ days late, and I have maintained positive payment behavior, including paying loans months in advance. Other major institutions ( XXXX, XXXX ) have approved my requests for credit line increases under the same circumstances. 

Navy Federals denial can not be reasonably explained except by opaque internal performance criteria, which raises the concern that hidden or inappropriate underwriting factors such as my employment status as a federal government employee during a shutdown are influencing decisions. This lack of transparency, combined with Navy Federals history of discriminatory mortgage lending, raises significant concern that similarly unfair or discriminatory standards are being applied to other credit products. 

The following is the original Interaction with NFCU : Your MessageXXXX recently applied for an increase and the reason was I was denied was " Delinquent Performance with Navy Federal. '' I have never had any delinquencies with Navy Federal. Additionally I do not have any delinquencies on any of my credit reports. I would like to have the request reconsidered. 

Message from Navy FederalXXXXThank you for your message. Every member is important to us and we value your membership. We conducted a second review of your credit limit increase application for reconsideration. However, upon further review, we have determined that our original decision will remain in effect. Our records show that there was some recent late payments on your consumer loan. Any payments that are not received by your due date is considered late. The maintenance of your account is also reviewed at the time of the application. We regret that we are not able to reach a more favorable decision at this time. If we can be of any further assistance, please let us know. 

Your MessageXXXX am requesting that this matter be escalated to a manager immediately ; otherwise, this will be a CFPB complaint. If you are going to say you have record illustrate those records because I not been late on anything. I do not accept you just saying without proof specifically stating the product and the occurrence. 

Message from Navy FederalXXXX. XXXX thank you for your eMessage. While your accounts have not been over 30 days past due, they do have history of the payments not being made by the due date advised on your monthly credit statements. We value your membership and consider it a privilege to serve you. If you have any further questions, you may contact us any time toll-free at XXXX. '' Your MessageXXXXThank you for your previous response. I am following up to formally invoke my rights under the Equal Credit Opportunity Act and Regulation B. 1. Request for Specific Reasons Under 12 CFR 1002.9 ( a ) ( 2 ) Your statement that my request was denied due to internal credit performance does not meet the legal requirement for providing specific reasons for adverse action. I am hereby requesting, in writing, the precise and detailed basis for the denial of my credit limit increase, including : Any account ( s ) relied upon The dates and billing cycles in question The specific internal standard or policy applied Generalized references to internal history are not sufficient under federal law. 2. Escalation Request In my prior message, I requested escalation to a manager. That request was not acknowledged. I am restating that request and expect a response from the appropriate level of management. 3. Clarification of Payment History Assertions You acknowledged that I have not been 30 days past due. If you are stating that payments not being made by the due date was a material factor, you must identify each instance with date and product so that I may review your assertions. Regulatory Notice If there is a further failure to ( a ) escalate this request through the proper chain of command, and ( b ) respond in a manner consistent with the requirements of ECOA and Regulation B, I will have no choice but to proceed with a regulatory complaint. This type of correspondence is contrary to the type of relationship I want to build with NFCU. I am doing everything I can to build a positive relationship with your institution, so I am trying to understand what I have done so egregious that it would warrant a denial of a credit history meanwhile I was approved by an increase with XXXX and XXXX. I am paying of my balances regularly and my loan is paid months in advance. What additional risk are you taking that other credit unions havent? I look forward tonyour response. 

Message from Navy FederalXXXX XXXX XXXX, thank you for your follow-up regarding your credit limit increase request. Your request for escalation has been acknowledged, and this response has been reviewed and approved by management. After careful consideration of your account history and credit performance criteria, we are unable to approve the request at this time. We understand your comparison to other institutions and appreciate your transparency. Each lender applies its own underwriting standards, which may result in different outcomes. We recognize this may be disappointing and value your continued relationship with Navy Federal. 

Your MessageXXXXThank you for your reply and for confirming management review. However, your most recent response still does not comply with the Equal Credit Opportunity Act ( ECOA ) and Regulation B. Under 12 CFR 1002.9 ( a ) ( 2 ), I am entitled to a statement of specific reasons for adverse action. General references to account history or credit performance criteria are not legally sufficient. I am again requesting the exact basis for your denial, including the specific accounts, dates, and standards used in your decision. Failure to provide a compliant response will leave me no choice but to proceed with a formal regulatory complaint, including reference to your repeated refusal to provide the information required by law. This is my final request for a proper statement of reasons. 

Message from Navy FederalXXXX. XXXX, thank you for your follow-up eMessage. We regret that a more favorable reply could not be made to your request.

Company public response: Company believes it acted appropriately as authorized by contract or law
Company response to consumer: Closed with explanation