Consumer complaint received 2025-07-22 00:00:00
Product: Vehicle loan or lease — Loan
Issue: Getting a loan or lease — Credit denial
Company: BANK OF AMERICA, NATIONAL ASSOCIATION
State: SC

Complaint narrative:
Name : XXXX XXXX Address : XXXX XXXX XXXX XXXX, XXXX, SC XXXX Date of Adverse Action : XX/XX/2025 Application Date : XX/XX/2025 Application Number : XXXX Entity Involved : Bank of America, N.A I am filing this complaint against Bank of America N.A in connection with the processing of a covered business application for consideration using my personal Social Security Number, without honoring my expressed intention to apply in a business credit transaction, I submitted application documentation and supporting financials for a covered credit transaction. According to ECOA as a qualified small minority-owned business that applied for covered credit transaction, However, Bank of America wrongfully treated the application as a consumer request and issued an adverse action based on consumer credit factorsviolating my rights under federal law. ( FCRA ) Violations Cited : 1. Equal Credit Opportunity Act ( ECOA ), 15 U.S.C. 1691 Under ECOA and Regulation B ( 12 CFR 1002.2 ( e ) ), I was an applicant entitled to fair, non-discriminatory access to credit. I feel I was discriminated against because My application was improperly evaluated based solely on personal credit data, despite my clear intention to apply in a business capacity. Bank of America failed to meet the standard of providing a meaningful explanation under 12 CFR 1002.9 ( a ) ( 2 ) and gave a generic denial referencing delinquency and credit usage without validating my application type or giving proper notice of adverse action. The ECOA purpose is To enable communities, governmental entities, and creditors to identify business and community development needs and opportunities of women-owned, minority-owned, and small businesses, and prohibits creditor practices that discriminate on the basis of any of these factors. The regulation also requires creditors to notify applicants of action taken on their applications ; to report credit history in the names of both spouses on an account ; to retain records of credit applications ; to collect information about the applicant 's race and other personal characteristics in applications for certain dwelling-related loans ; and to provide applicants with copies of appraisal reports used in connection with credit transactions. 2. Truth in Lending Act ( TILA ), 15 U.S.C. 1601. I was not given disclosures required under TILA before my SSN and credit report were used. This includes the Annual Percentage Rate ( APR ), total finance charges, and other key terms required under 12 CFR 1026.17 and 1026.18. This violates my right to informed consent in a credit transaction and denies transparency. 3. FTC Holder Rule ( 16 CFR 433 ) My application and supporting documents represent a contract offer, supported by consideration. Bank of America denial and failure to honor my offer violates the FTC Holder in Due Course Rule, which binds all finance companies to any claims or defenses a consumer could assert against the seller. This Rule also defines : ( b ) Consumer. A natural person who seeks or acquires goods or service for Personal, family, or household use. ( d ) Purchase money loan. A cash advance which is received by a consumer in return for a Finance Charge within the meaning of the Truth in Lending Act and Regulation Z. ( e ) Financing a sale. Extending credit to a consumer in connection with a Credit Sale within the meaning of the Truth in Lending Act and Regulation Z. ( f ) Contract. Any oral or written agreement, formal or informal, between a creditor and a seller, which contemplates or provides for cooperative or concerted activity in connection with the sale of goods or services to consumers or the financing thereof. ( i ) Consumer credit contract. Any instrument which evidences or embodies a debt arising from a Purchase Money Loan transaction or a financed sale as defined in paragraphs ( d ) and ( e ) of this section. Bank of America accepted my SSN and credit application, transmitted XXXX federal reserve XXXX and failed to disclose or release my considerationpotentially holding my personal credit data XXXX.

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