Consumer complaint received 2024-12-16 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Personal line of credit
Issue: Getting a line of credit — 
Company: ENOVA INTERNATIONAL, INC.
State: TN

Complaint narrative:
XX/XX/XXXXXXXX  To : Consumer Financial Protection Bureau XXXX XXXX XXXX XXXX, IA XXXX Subject : Formal Complaint Regarding Denial of Credit Applications- Case Numbers XXXX, XXXX, and XXXX Dear Consumer Financial Protection Bureau , I am filing this complaint against XXXXXXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX by NetCredit, for what I believe are violations of federal consumer protection laws, including the Equal Credit Opportunity Act ( ECOA ), Fair Credit Reporting Act ( FCRA ), and other related statutes. My credit applications were denied on XX/XX/XXXXXXXX XXXX XXXX XXXX XXXX, for reasons that are vague, non-material, and possibly discriminatory, specifically citing an issue with my bank account routing number. 

Key Violations 1. Violation of the Equal Credit Opportunity Act ( ECOA ) - 15 U.S.C. 1691 The ECOA prohibits creditors from making adverse credit decisions based on arbitrary or non-material factors. Denying my application due to a bank account routing number fails to provide a legitimate, material basis for evaluating my creditworthiness. This reasoning violates my rights under the ECOA, which ensures fair and equitable access to credit. 
Regulation B ( 12 C.F.R. 1002.9 ) mandates that creditors provide specific, accurate, and legally sound reasons for adverse actions. The explanation provided in my denial notices does not meet these standards and raises concerns about the integrity of NetCredits decision-making process. 
2. Violation of the Fair Credit Reporting Act ( FCRA ) - 15 U.S.C. 1681 The denial notices state that information from third-party consumer reporting agencies influenced the decision. However, they fail to adequately disclose the nature, relevance, and accuracy of this data. This violates my right under the FCRA to : Be informed about the specific role this data played in the adverse decision ( 15 U.S.C. 1681m ). 
Dispute inaccuracies in the credit reports used to evaluate my application. 
Receive clear and complete explanations of the creditors use of external data. 
3. Failure to Comply with Transparency Requirements The notices fail to adequately explain how my banking information ( specifically a routing number ) was deemed relevant to assessing my credit risk. This lack of transparency appears to violate both the ECOA and FCRA and leaves me unable to meaningfully contest or address the reasoning behind the denial.

4. Potential Violation of the Dodd-Frank Wall Street Reform and Consumer Protection Act Under the Dodd-Frank Act ( 12 U.S.C. 5531 ), creditors are prohibited from engaging in unfair, deceptive, or abusive acts or practices ( UDAAP ). Denying credit based on arbitrary criteria, such as a routing number, is unfair and potentially abusive, as it misrepresents the factors legitimately used to evaluate creditworthiness. 
Furthermore, creditors must have clear and justifiable criteria to avoid misleading consumers about the basis for credit decisions. 
5. Discriminatory Practices and Disparate Impact While NetCredit claims to assess applications fairly, relying on non-material factors such as a routing number disproportionately impacts consumers from underserved financial backgrounds. This practice could perpetuate discriminatory outcomes and conflicts with the Consumer Financial Protection Act ( 12 U.S.C. 5481 ). 
6. Potential Breach of the Truth in Lending Act ( TILA ) Denials citing unclear or non-material reasons could indicate a failure to comply with TILAs mandate for accurate, consistent, and transparent credit disclosures. Misrepresenting or obscuring the basis for a credit denial creates confusion and undermines the consumers ability to make informed financial decisions.

Request for Investigation and Action In light of these violations and inconsistencies, I respectfully request that the CFPB : 1. Investigate NetCredits Compliance with Federal Consumer Protection Laws Evaluate their credit decision-making practices and adherence to the ECOA, FCRA, and related statutes. 
Assess whether the use of banking information as a material factor has a disparate or discriminatory impact on certain consumers. 
2. Require Corrective Actions Direct NetCredit to provide a detailed explanation of how my banking information ( specifically my routing number ) was material in determining my creditworthiness. 
Ensure NetCredit implements policies that align with federal guidelines for equitable and transparent lending practices. 
3. Issue Sanctions or Remedies If violations are confirmed, enforce penalties to ensure compliance with federal law. 
Require NetCredit to review its adverse actions against applicants who may have been unfairly denied credit based on similar practices. 
4. Provide Guidance for Resolution Clarify how I may challenge the accuracy and relevance of the data used to deny my applications. 

Supporting Documents Copies of the denial letters for applications XXXX, XXXX, and XXXX. 
My formal reconsideration request to NetCredit dated XX/XX/XXXX, detailing the violations. 

Conclusion The denial of my applications reflects systemic issues in NetCredits decision-making process, which may adversely affect other consumers. I urge the CFPB to take immediate action to safeguard the rights of consumers and ensure compliance with federal laws. 

I look forward to your response and am willing to provide any additional documentation or information required for your investigation. 

Sincerely, XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX, TN XXXX Phone : [ Insert Phone Number ] Email : XXXX XXXX

Company response to consumer: Closed with explanation