Consumer complaint received 2025-11-12 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Earned wage access
Issue: Unexpected fees — 
Company: WELLS FARGO & COMPANY
State: TX

Complaint narrative:
COMPLAINT Plaintiff : Original Lienholder Defendant ( s ) : Wells Fargo Bank, N.A., Wells Fargo Dealer Services, and XXXX XXXX XXXX Case No. : XXXX I. INTRODUCTION This is a complaint for violations of the Federal Truth in Lending Act ( TILA ), 15 U.S.C. 1601 et seq., and related state consumer protection laws arising from fraudulent misrepresentation, concealment of finance charges, and unauthorized conversion of a motor vehicle retail installment sales contract under the guise of legitimate financing.

Plaintiff documents that Wells Fargo Bank, N.A., Wells Fargo Dealer Services, and XXXX XXXX XXXX jointly engaged in deceptive, unfair, and unlawful consumer credit practices designed to conceal the true cost of credit, misrepresent interest and finance charges, and unlawfully profit from unauthorized motor vehicle finance transactions. 

II. PARTIES 1. Plaintiff is an individual consumer residing in XXXXXXXX XXXX 

2. Defendant Wells Fargo Bank , N.A . is a XXXX banking XXXX operating under federal charter with its principal place of business in XXXX XXXXXXXX XXXX 

3. Defendant Wells Fargo Dealer Services is a division or subsidiary of Wells Fargo Bank engaged in auto finance and loan servicing. 

4. Defendant XXXX XXXX XXXX is a motor vehicle dealership located in XXXX, XXXX  operating under franchise agreement with XXXX XXXX XXXX, XXXX. 

III. JURISDICTION AND VENUE 5. This Court has subject matter jurisdiction pursuant to 15 U.S.C. 1640 ( e ) and 28 U.S.C. 1331 and 1367, as this case arises under the Federal Truth in Lending Act.

6. Venue is proper in this district because the unlawful conduct occurred within this jurisdiction and the defendants conduct regular business here. 

IV. FACTUAL BACKGROUND 7. On or about XXXX - XXXX Plaintiff entered into a motor vehicle retail installment sales contract at XXXX XXXX XXXX for the purchase of a motor vehicle financed through Wells Fargo Dealer Services. 

8. The sales and finance representatives represented to Plaintiff that the contract reflected accurate finance charges, interest rates, and payment terms under federal and state lending laws.

9. Upon later review, Plaintiff discovered that the finance charge, interest calculation, and principal balance were manipulated, misrepresented, and concealed to inflate the amount financed and misstate the annual percentage rate ( APR ). 

10. The contract also contained unauthorized fees, add-ons, and dealer reserves, disguised as legitimate charges but, in fact, representing unlawful dealer participation payments between XXXX XXXX XXXX and Wells Fargo Dealer Services XXXX 

11. The acts described constitute a deceptive scheme to extract unlawful profits through misrepresentation of credit terms in violation of the Truth in Lending Act and the Federal Trade Commission Act prohibiting unfair and deceptive business practices. 

12. Plaintiff did not receive accurate disclosures as required by Regulation Z ( 12 C.F.R. 1026 ), including : The actual finance charge and APR ; The itemization of the amount financed ; The total of payments and payment schedule ; and The clear identification of the creditor and assignee. 

13. Upon information and belief, Defendants intentionally falsified, concealed, or omitted key information to induce Plaintiff into signing the installment sales contract under false pretenses.

14. As a direct result, Plaintiff sustained financial injury, credit damage, and loss of equity in the vehicle. 

V. CAUSES OF ACTION Count 1 Violation of the Truth in Lending Act ( 15 U.S.C. 1601 et seq. ) 15. Defendants failed to make accurate and complete disclosures of credit terms as required under TILA. 

16. Defendants actions were willful, knowing, and in reckless disregard of Plaintiffs rights under federal law. 

Count 2 Consumer Credit Fraud / Deceptive Trade Practices 17. Defendants, through concealment and misrepresentation, engaged in consumer credit fraud by manipulating retail installment data and withholding accurate financial information. 

18. This conduct violates state deceptive trade practices statutes and constitutes fraudulent inducement.

Count 3 Conversion/ Theft by Deception 19. Defendants unlawfully converted funds and misappropriated proceeds from Plaintiffs transaction through the unauthorized collection of inflated finance charges, fees, and interest. 

VI. DAMAGES 20. Plaintiff seeks : Statutory damages under 15 U.S.C. 1640 ( a ) ; Actual damages in the amount of overpaid finance charges and unlawful fees ; Punitive damages for willful and malicious conduct ; Attorneys fees and costs ; and Rescission or reformation of the contract.

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