Consumer complaint received 2025-11-21 00:00:00
Product: Money transfer, virtual currency, or money service — Domestic (US) money transfer
Issue: Fraud or scam — 
Company: UNITED SERVICES AUTOMOBILE ASSOCIATION
State: TX

Complaint narrative:
Subject : Complaint Against USAA Federal Savings Bank Improper Denial of Fraud Claim Under Regulation E ( XXXX Scam ) Financial company : USAA Federal Savings Bank Type of product : Checking account / XXXX ( P2P transfer ) Account ending : XXXX Dispute/Claim ID : XXXX -- - What happened On XX/XX/year>, I was the victim of a bank-impersonation scam involving a fraudulent XXXX transfer of {$1000.00} from my USAA checking account. 

I received a call from someone who claimed to be from USAAs fraud department. They stated there was suspicious activity on my account and that I needed to follow their instructions to secure my funds. Relying on their representation that they were USAA, I followed their directions. As a result, a XXXX transfer of {$1000.00} was sent from my account to XXXX XXXX ( a recipient controlled by the scammer ). 

I did not receive any goods, services, or benefit from this transaction. This was not a legitimate purchase or payment I intended to make to a merchant or known party. It was the result of deception and impersonation of my bank. 

I reported the fraud to USAA on XX/XX/year>. USAA opened a dispute and initially issued a temporary/provisional credit for the {$1000.00}. 

On or about XX/XX/year>, USAA sent me a letter stating that they had completed their investigation and were denying my claim. As part of that denial, the provisional credit of {$1000.00} was actually withdrawn twice, resulting in a total negative impact of {$2000.00} instead of just the original {$1000.00} fraudulent transfer. In other words, not only did USAA refuse to permanently restore the original {$1000.00}, but their handling of the provisional credit created an additional {$1000.00} debit to my account. 

This has left me in a worse financial position than before I reported the fraud. 


-- - What the bank said In a written letter, USAA stated ( paraphrased and quoted ) : They had completed their investigation and determined that no error occurred. 

Funds were sent as requested. 

They referenced XXXX Terms of Service and said that the sender is responsible for resolving disputes with the recipient, including for goods or services. 

They stated that the external bank declined to return the funds. 

They concluded the investigation and stated that no further action would be taken and that the temporary credit would be debited from my account. 


USAA is treating this as if I voluntarily paid someone for goods/services and am now unhappy, instead of acknowledging it as fraud and a bank-impersonation scam. In addition, USAAs own handling of the provisional credit has effectively resulted in a double withdrawal. 


-- - Why I believe this violates Regulation E and CFPB guidance This situation is an unauthorized electronic fund transfer ( EFT ) under the Electronic Fund Transfer Act ( EFTA ) and Regulation E ( 12 C.F.R. 1005 ).

Regulation E, 12 C.F.R. 1005.2 ( m ) defines an unauthorized electronic fund transfer as a transfer from a consumers account initiated by a person other than the consumer without actual authority and from which the consumer receives no benefit.

In this case, a third party impersonated my bank, deceived me, and caused the transfer. I received no benefit, and the scammer had no actual authority.

The CFPBs own guidance/FAQs on electronic fund transfers and P2P payments explain that : A credit-push P2P transfer ( such as a XXXX payment ) is considered an EFT even if initiated by a third party that fraudulently obtained access to a consumers account, and that such a transfer is an unauthorized EFT when done without the consumers actual authority and without benefit to the consumer.

Despite this, USAA denied my claim by : 1. Treating the transaction as if it were a legitimate, authorized payment sent as requested ; 2. Citing XXXX  Terms of Service and saying the sender is responsible and must resolve it with the recipient ; 3. Ignoring the fact that this was a bank-impersonation scam, not a dispute over goods or services ; 4. Failing to correct what appears to be an internal error that caused the provisional credit to be withdrawn twice, resulting in a total of {$2000.00} in debits tied to a {$1000.00} fraudulent transaction. 



XXXX terms of service can not override federal protections under Regulation E. USAAs position appears contrary to EFTA and CFPB interpretations regarding unauthorized EFTs and bank-impersonation scams, and its handling of the provisional credit appears to be an additional error.

Additionally, under 12 C.F.R. 1005.11 ( b ) ( d ), USAA is required to : Conduct a reasonable investigation of an alleged error ; Determine whether an error occurred ; Provide a provisional credit if they can not complete the investigation within 10 business days ; Correct any bank errors and provide written explanation and, if requested, the documentation used in making its determination.

USAAs letter is generic and relies on XXXX network response and terms of service, rather than a proper Regulation XXXX analysis of an unauthorized transfer caused by fraud and impersonation, and it does not address the double debit of the provisional credit. 


-- - What I am asking the CFPB to do I am requesting that the CFPB : 1. Review USAAs handling of my claim under Regulation E/EFTA and CFPB guidance on P2P fraud and bank impersonation scams ; 2. Require USAA to properly treat this as an unauthorized electronic fund transfer, not a goods/services dispute or no error ; 3. Require USAA to refund the original {$1000.00} that was taken from my account as a result of this scam, 4. Require USAA to correct the additional {$1000.00} debit that occurred when the provisional credit was withdrawn twice, so that I am not penalized beyond the original fraudulent amount ; 5. Reverse any related fees or negative consequences applied to my account due to these debits ; 6. Ensure USAA provides me with the documentation and evidence they relied on in denying the claim ( call logs, internal notes, any risk analysis, communications with the receiving bank, etc. ) ; 7. Review whether USAAs general policies and practices concerning XXXX and impersonation scams comply with Regulation E and CFPB guidance.

This scam has caused me significant financial and emotional stress. I relied on my bank to protect me and to follow federal law, and instead I feel I have been victimized twiceonce by the scammer and then again by the banks refusal to recognize this as fraud and by the double withdrawal of the provisional credit.

Thank you for your time and assistance. 

Name : XXXX XXXX Address : XXXX XXXX XXXX XXXXXXXX XXXX, TX XXXX Phone : XXXX Email : XXXX 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