Consumer complaint received 2025-06-14 00:00:00
Product: Money transfer, virtual currency, or money service — Domestic (US) money transfer
Issue: Fraud or scam — 
Company: JPMORGAN CHASE & CO.
State: CA

Complaint narrative:
XXXX XXXX XXXX XXXX XXXX, XXXX XXXXXXXX XXXX XXXX XXXX, CA XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXXXX/XX/XXXX To : Consumer Financial Protection Bureau XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Dear CFPB, Re : RESPONSE TO J.P. MORGAN CHASE BANKS STATEMENT REGARDING CFPB COMPLAINT I write to respectfully but urgently dispute the wholly inadequate and disingenuous response submitted by JPMorgan Chase Bank , N.A . ( Chase ) concerning my CFPB complaint. Chase 's response fails to address serious issues of elder financial abuse, institutional negligence, and compliance failures under both federal guidelines and Californias Elder Abuse and Dependent Adult Civil Protection Act ( EADACPA ), which imposes heightened duties on financial institutions interacting with XXXX 
Chases blanket assertion that this matter involved only customer-initiated transactions is a dangerous oversimplification of what federal regulators and California law recognize as a growing epidemic of elder financial exploitation, often masked by the victims own unwitting involvement under manipulation by bad actors. EADACPA explicitly defines such exploitation, where property is obtained from an elder for a wrongful use or with intent to defraud, as financial abuse ( XXXX ), irrespective of superficial " authorization '' obtained through deception. 
Below are several compelling legal and regulatory deficiencies in Chases handling of this matter, warranting immediate regulatory scrutiny : 1. Failure to Act on Clear Warning Signs in Violation of Interagency Guidance JPMorgan Chase 's assertion that these were merely " customer-initiated transactions '' dangerously ignores the critical obligations financial institutions owe under federal guidelines and EADACPAs imposition of a heightened " duty of care '' for businesses interacting with XXXX, especially when serving vulnerable populations such as XXXX  clients. The XXXX Interagency Guidance on Privacy Laws and Reporting Financial Abuse of Older Adults, issued jointly by the CFPB, Federal Reserve, FDIC, OCC, and other federal regulators, provides specific expectations for financial institutions when encountering signs of elder financial exploitation. This includes unusual transaction patterns, sudden changes in banking activity, or other behavior that deviates markedly from a customers established history. 
In this case, Chase was not only presented with multiple warning signs but failed to escalate them appropriately. As a long-standing Chase customer, my banking behavior prior to Fall XXXX showed no pattern of large, repeated transfers. Suddenly, and without precedent, I began initiating high-value transfers totaling more than {$200000.00} to multiple recipients. This stark deviation from my historical activity constituted clear undue influence and wrongful use of funds under EADACPA 15610.30 and should have triggered Chases fraud detection systems or, at minimum, internal review. 
The fact that I am a XXXXXXXX XXXX  citizen, and that these transactions were allegedly conducted with unfamiliar entities for opaque business purposes, only reinforces the necessity for elevated scrutiny under federal elder financial protection protocols and EADACPAs mandate to protect elders from precisely this form of exploitation. These red flags are precisely the scenarios envisioned by the Interagency Guidance and EADACPA, which stress that even customer-permitted transactions may constitute exploitation when the elder is manipulated by external bad actors.

By not investigating these anomalies thoroughly or escalating them to a higher level of scrutiny, Chase failed in its duty to follow regulatory best practices and breached its statutory duty of care under EADACPA. In fact, Chases failure to act on these irregularities may reflect systemic deficiencies in its internal compliance and elder protection protocols. The CFPB has emphasized that financial institutions are on the front lines of identifying and stopping fraud before irreversible harm occurs. In this instance, Chase not only failed to prevent harm, but it also enabled it through passivity and noncompliance. 
This is not merely a matter of hindsight. The Interagency Guidance was published over a decade ago, and EADACPA has imposed clear duties on institutions since its enactment. Chase, as one of the largest banks in the country, can not credibly claim ignorance. The banks negligence created the perfect environment for the fraud to proceed unchecked. If Chase had intervened when the anomalies first emergedas their federal obligations requirethe ensuing financial devastation could have been mitigated or entirely prevented.

I therefore urge the CFPB to investigate whether Chase has violated the Interagency Guidance standards, failed to uphold its fiduciary responsibilities and EADACPA duties, and whether these systemic failures represent a pattern of institutional neglect toward elder clients vulnerable to financial exploitation. Enforcement action is warranted to compel Chase to adopt necessary corrective measures and redress the harm caused by its inaction. 

2. Violation of California Law ( Cal. Welf. & Inst. Code 15630.1 ) The State of California has some of the strongest protections in the country against elder abuse, including financial exploitation. Cal. Welf. & Inst. Code 15630.1 ( d ) ( 1 ) provides as follows : Any mandated reporter of suspected financial abuse of an elder or dependent adult who has direct contact with the elder or dependent adult or who reviews or approves the elder or dependent adult 's financial documents, records, or transactions, in connection with providing financial services with respect to an elder or dependent adult, and who, within the scope of his or her employment or professional practice, has observed or has knowledge of an incident, that is directly related to the transaction or matter that is within that scope of employment or professional practice, that reasonably appears to be financial abuse, or who reasonably suspects that abuse, based solely on the information before him or her at the time of reviewing or approving the document, record, or transaction in the case of mandated reporters who do not have direct contact with the elder or dependent adult, shall report the known or suspected instance of financial abuse by telephone or through a confidential Internet reporting tool, as authorized pursuant to Section XXXX, immediately, or as soon as practicably possible. If reported by telephone, a written report shall be sent, or an Internet report shall be made through the confidential Internet reporting tool established in Section XXXX, within XXXX working days to the local adult protective services agency or the local law enforcement agency. 

Under Cal. Welf. & Inst. Code 15630.1, financial institutions are required to report suspected financial abuse of an elder or dependent adult immediately, or as soon as practically possible, by telephone, followed by a written report within two working days. Critically, this duty to report is mandatory, not discretionary, and applies even when the elder customer denies being defrauded, as many victims of manipulation often do. Furthermore, EADACPA provides a civil cause of action against entities that " take, secrete, appropriate, or retain property for a wrongful use '' ( 15610.30 ) or fail in their duty to prevent such exploitation. Chases failure to report and intervene exposed it to liability under both statutes.

In this case, Chase Bank has already acknowledged that at least one branch-level employee questioned me about the nature of the high-value transactions. The bank alleges that I confirmed the transactions were business-related. However, the statute does not require certainty or confirmation of abuse to mandate reporting. It only requires reasonable suspicion. The law specifically anticipates scenarios where an elder may not recognizeor may even denythat they are being exploited, due to manipulation, shame, or lack of full understanding. EADACPA expressly recognizes that financial abuse occurs when an elder is deceived into " voluntarily '' surrendering assets through undue influence, fraud, or coercion ( 15610.30 ( a ) ( 3 ) ).

Chase failed to act when it mattered most. If their employee had enough concern to question me, then they had more than enough basis to initiate a mandatory report under California law. Instead, Chase did not report the activity until well after my funds were depleted, and only after it became too late to protect me. This dereliction of duty directly enabled the continuation of fraudulent withdrawals and significantly contributed to my financial devastation. This failure constitutes per se negligence under EADACPA, potentially entitling me to compensatory damages, punitive damages, attorneys fees, and court costs ( XXXX  ). 
Moreover, Cal. Welf. & Inst. Code 15630.1 ( c ) explicitly mandates training for bank employees to recognize warning signs of XXXX abuse and to act on them without hesitation. The failure by Chase to recognize the red flags, despite a clear deviation from my account history, repeated high-value transfers, and XXXX status, reflects a systemic breakdown in their compliance and training programs. Chases late reporting, after the damage was done, further confirms the banks disregard for its statutory duties and its breach of EADACPAs duty of care. 
It is especially troubling that this failure occurred in multiple branches and over a sustained period. This indicates a lack of internal checks, oversight, or escalation protocolseach of which is expected under Californias regulatory framework. When one branch fails to act, it may be negligence. When multiple locations enable suspicious conduct repeatedly over months, it suggests institutional noncompliance warranting punitive damages under EADACPA XXXX for recklessness, oppression, fraud, or malice. 
Furthermore, Chases failure to report extended to a separate XX/XX/XXXX incident where I was defrauded through a XXXX business loan scam. In my attempt to meet the scammers demands, I paid approximately {$5000.00} to fraudulent agents and made XXXX payments via Chase to XXXX XXXX ( {$1300.00} on XX/XX/XXXX, {$1700.00} on XX/XX/XXXX, {$250.00} on XX/XX/XXXX, and {$1000.00} on XX/XX/XXXX ). 
I reported this fraud in person to a Chase official named XXXXXXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX, CA ) branch on XX/XX/XXXX, XXXX, and XXXX, XXXX. No action was taken, and XXXX was not notified as required. In a XX/XX/XXXX call, Chase confirmed these visits and my contact with XXXX but admitted no notes were taken. 
Even worse, Chase delayed reporting to XXXX for months, only acting after I filed this CFPB complaint. XXXX agent XXXX XXXX received a referral ( bank unnamed ) on XX/XX/XXXX, and visited my home on XX/XX/XXXX, weeks after my final fraudulent transfer ( XX/XX/XXXX ) and only after regulatory pressure. This pattern of belated reporting underscores institutional disregard for statutory duties. 
Chases failure to act upon observable patterns of exploitation violates not only state law but also undermines the very intent of elder financial protection policies. The consequence of this failure has left me financially destitute, emotionally distressed, and physically vulnerable. 

XXXX. Failure to Follow Its Own Risk Controls and Duty of Care JPMorgan Chase Banks handling of the transactions at issue reflects a deep institutional failure to uphold its fiduciary duty, adhere to its own internal risk controls, and apply industry-standard safeguards for elder clients in violation of EADACPAs imposition of a duty of care ( XXXX ). As one of the largest financial institutions in the United States, Chase has long touted its robust fraud detection systems, Know Your Customer ( KYC ) protocols, and customer-first policies. However, none of these safeguards were applied meaningfully in my case. 
As a Chase customer for many years, my account had established, predictable activity : modest, consistent monthly balances and no history of high-volume business-to-business wire transfers. Beginning in Fall XXXX, I initiated large, repeated transfers to unfamiliar recipients. These transactions totaled over {$200000.00} and represented a XXXX departure from my historical activity. Chases internal fraud systems, which are designed to flag anomalous behavior, failed to detect or act on these changes. This failure constitutes a breach of its duty of care to a vulnerable elder under XXXX XXXX. 
Banking institutions are not passive conduits of customer will. They have both a legal and operational obligation to assess the legitimacy of unusual financial activity, particularly when the customer is XXXX. This is not an abstract or novel standard. It is enshrined in federal anti-fraud frameworks and industry best practices. Chase had both the technology and the duty to identify the fraud scheme in progress. Its failure to do so demonstrates a systemic breakdown or a negligent disregard for customer protection. 
The duty of care is heightened when the bank is dealing with an elderly, long-term account holder showing signs of financial irregularity. Even according to Chases own XXXX Account XXXX ( XXXX ), which encourages customers to review statements for irregular activity, the bank still retains the right and responsibility to block, investigate, or flag suspicious transactions. Chase did none of those things. Its inaction facilitated the " taking '' and " wrongful use '' of my property, meeting XXXX 's definition of financial abuse ( XXXX ). 
Chases excuse that the transactions were customer-initiated ignores the regulatory and ethical requirement to investigate when multiple high-risk markers are triggered. This includes ( XXXX ) account holder age, ( XXXX ) sudden transaction volume spikes, ( XXXX ) recipient accounts newly added, ( XXXX ) opaque business purposes, and ( XXXX ) known fraud patterns such as pig butchering scams. Had any of these markers alone been investigated, the fraud might have been interrupted. In combination, they formed an unmistakable profile of financial exploitation requiring intervention under XXXX. 
Additionally, no XXXX ever required additional verification or approval, despite the fact that these transactions were not typical for my account and would have represented high-risk events under even the most lenient fraud detection models. This suggests that Chase either failed to employ such models or chose not to act on the information they produced. 
The impact of this failure is not theoretical, it is quantifiable, deeply personal, and devastating. I have lost my savings, my credit is in ruins, and I am now facing mortgage pressure and potential bankruptcy. Chases indifference in the face of its own data, policy obligations, and duty of care can not be excused and warrants the full range of remedies available under XXXX, including restitution, compensatory damages, and attorneys fees. 
The CFPB should treat this matter as a demonstration of Chases systemic noncompliance and evaluate whether their risk control protocols meet federal expectations for fraud mitigation, especially when elder exploitation is at stake. A failure to investigate and act must result in institutional accountability. 

XXXX. Obfuscating Liability Through XXXX Chase Banks core defense that the fraudulent transactions in question were customer-initiated and therefore not subject to reimbursement grossly misrepresents the legal and regulatory landscape concerning authorized fraud and elder financial exploitation. This defense reflects not only a misapplication of fraud classifications but also an intentional obfuscation of Chases institutional responsibilities in preventing scam-induced transactions, especially when the customer is elderly and vulnerable. 
The banks position relies on a narrow, self-serving interpretation of what constitutes fraud. While it is true that under Regulation XXXX of the Electronic Fund Transfer Act, unauthorized transactions typically trigger reimbursement requirements, this case does not fall cleanly into that framework. Instead, it concerns a scenario the CFPB has extensively documented and warned the public about : scams involving social engineering and psychological manipulation that lead victims to " authorize '' their own financial ruin. These are widely recognized as authorized fraud cases, where the transaction is technically permitted by the account holder, but only because the customer has been deceived, coerced, or manipulated. 
In this situation, I was targeted through a pig butchering scheme that gradually manipulated me into believing I was entering a legitimate business venture. Like thousands of similarly situated scam victims, I was coaxed into making large transfers to what I believed were authentic business recipients. The banks involved, including Chase, facilitated these transactions without adequate internal scrutiny or protective friction, even when my transactional activity drastically diverged from my prior account history. 
Importantly, Chases claim that these were voluntary transactions and thus beyond its responsibility is not supported by federal guidance on elder financial abuse. The CFPB, XXXX, and the FTC all recognize that elders are uniquely susceptible to XXXX  exploitation and often do not recognize fraud until it is too late. It is precisely for this reason that financial institutions are held to higher standards of vigilance and intervention when sudden, anomalous activity arises in an elder customers account. 
Furthermore, Chases own fraud protection policies in other jurisdictions undermine its defense here. As I previously noted, Chase XXXX offers fraud protection for authorized fraud transactions, recognizing the ethical and reputational harm in allowing vulnerable customers to be financially destroyed while the bank takes no responsibility. That Chase XXXX disclaims this obligation, despite operating under the same brand, ethos, and customer trust, highlights a troubling inconsistency that must be addressed by U.S. regulators. 
Chase can not escape liability by hiding behind contract language and technical definitions of authorization. When its fraud detection systems fail, when its staff observe but do not act upon irregularities, and when its customer is an elderly individual experiencing manipulation, the bank has crossed from neutrality into complicity. These are not merely business decisionsthey are failures of care, compliance, and conscience. 
The CFPB should treat this definitional shell game for what it is : a regulatory avoidance strategy. It must be rejected. Chase must not be allowed to benefit from its refusal to modernize its fraud protections in light of emerging scam typologies, especially those that exploit XXXX 

5. Institutional Liability for Enabling Fraud Infrastructure JPMorgan Chase Banks role in this case goes beyond passive negligence, it actively enabled the infrastructure that allowed this fraud scheme to succeed. By approving and maintaining multiple recipient business accounts that received illicit transfers from my account, Chase facilitated the operation of a pig butchering scam targeting a vulnerable XXXX The presence of this infrastructure within the banks own system exposes it to institutional liability for allowing its platform to be used in the commission of financial elder abuse. 
Pig butchering scams often rely on a network of recipient accounts created for the sole purpose of laundering funds extracted from victims. These accounts are typically opened under legitimate-sounding business names, but their true purpose is fraudulent. In my case, I was instructed to transfer funds from my Chase business account to other Chase business accounts allegedly belonging to parties involved in an herbal product supply agreement. I later learned these accounts were set up under false pretenses and were used to funnel money to international actors as part of a fraud ring. Chases facilitation of these transfers constitutes " aiding and abetting '' the financial abuse of an elder under EADACPA principles. 
At no point did Chase question the legitimacy of these recipient accounts, despite the fact that they were receiving large and sudden transfers from a XXXX customer with no prior history of high-volume transactions. It is the responsibility of financial institutions to monitor not only outgoing transactions but also inbound flows to newly created accounts, especially when they fit well-documented fraud profiles. This failure reflects a reckless disregard for its duty to prevent exploitation under EADACPA XXXX

Moreover, many of the recipient accounts receiving these transfers were opened at different Chase branches across the U.S., suggesting a broader pattern that should have triggered internal fraud alerts. This activity is precisely what modern anti-money laundering ( AML ) systems are designed to detect, yet Chase failed to act. If one Chase branch is enabling high-volume deposits into a newly opened business account, and another Chase branch is facilitating suspicious outgoing transfers to it from an elderly customer, the banks systems should correlate these events and escalate for review. That did not happen here. This systemic failure makes Chase liable for permitting the financial abuse to occur. 
Chases failure to flag and investigate the destination accounts makes it more than a bystanderit became a conduit. As courts have increasingly recognized, when banks provide the financial rails used by fraudsters and fail to take preventive action despite obvious red flags, they may be liable for aiding and abetting or negligently enabling fraud. This is particularly true when the victim is part of a protected class, such as an elderly consumer under California law.

Additionally, the lack of any meaningful Know Your Customer ( KYC ) due diligence in approving these accounts further supports institutional liability. Chase has never explained what steps, if any, it took to verify the legitimacy of the recipient entities or to track the outflow and inflow of substantial sums across its business customer network. This lack of diligence directly facilitated the " taking '' and " wrongful use '' of my property, satisfying EADACPAs definition of financial abuse ( XXXX ). 
I respectfully request that the CFPB investigate Chases onboarding, monitoring, and internal control procedures for business accounts involved in this and similar elder-targeting scams. If one victim like me can be exploited through Chases network of accounts, there are likely others. This matter demands systemic review, and Chase must be held accountable for enabling financial exploitation through its own commercial platform.

6. Ongoing Harm, Distress, and Financial Ruin What distinguishes XXXX financial abuse from other forms of fraud is not just the monetary lossit is the cascading and often permanent damage to the victims emotional, physical, and financial well-being. In my case, the unchecked and unchallenged fraud facilitated by JPMorgan Chase Bank has left me not only destitute but also psychologically traumatized, on the brink of bankruptcy, and living with the grim consequences of a breach of trust by the very institution tasked with safeguarding my assets. EADACPA exists precisely to address such devastating outcomes and provides for comprehensive remedies, including compensatory damages for economic losses and emotional distress, punitive damages for reckless conduct, attorneys fees, and costs ( XXXX  ). 
I am a XXXXXXXX XXXX  who lived a financially modest but stable life. I was targeted not just because I had money, but because I was perceived, accurately, as someone vulnerable to manipulation. The fraud scheme I fell victim to was not an isolated incident ; it was part of a larger pattern of what experts now classify as pig butchering scams. These scams deliberately isolate victims, use social and professional deception, and create the illusion of opportunity. They are especially dangerous to older adults, who often trust authority and may lack the digital literacy to identify spoofed communications or fake platforms.

As a direct result of this fraud, enabled by Chases inaction, I have lost over {$200000.00}. The financial devastation is only the beginning. I now face mounting debt obligations, including mortgage pressures that threaten my housing stability. My credit rating has been irreparably harmed, impacting my ability to finance essentials or obtain emergency resources. The emotional fallout has been no less severe. The shame, XXXX XXXX XXXXXXXX stemming from this exploitation have become part of my daily reality. Compounding this, Chase Bank has closed my account due to fraud, making it impossible to independently assess the full transaction history or quantify the total losses. 
According to studies cited in the Interagency Guidance on XXXX  abuse, victims of financial exploitation are three times more likely to die prematurely than similarly situated individuals. This is not an exaggeration, it is a warning rooted in public health data.

Worse still, Chase has offered no meaningful recourse. The bank 's response not only denied reimbursement but also ignored the evident trauma I have endured. Its refusal to acknowledge its role in facilitating the abuse and in failing to act when warning signs were visible, has added to my distress. Instead of being treated as a client in crisis, I was treated as a procedural burden. 
I have also experienced a lack of empathy and urgency from Chase 's internal systems. It was only after the damage was complete that Chase filed a delayed report to Adult Protective Services, resulting in a home visit from XXXX  last week. But that action came far too late to prevent my financial ruin. This delay underscores the very problem I have outlined throughout this complaint : Chase had opportunities to act earlier but chose not to.

The CFPB has repeatedly acknowledged the seriousness of XXXX  financial abuse and its societal toll. This case is a vivid example of the damage that results when a major banks duty of care collapses under the weight of procedural shortcuts, profit priorities, or regulatory complacency. I implore the Bureau not to treat this as an individual complaint but as a test case for broader enforcement. If this can happen to me, it can happen to countless others. 
Only meaningful regulatory pressure, penalties, and structural reforms will restore trust, and only full restitution will begin to repair the damage I have suffered. In consideration of the foregoing, I respectfully urge the CFPB to exercise its regulatory oversight and : a. Formally investigate Chase Banks conduct in this matter for possible violations of elder protection laws and failure to adhere to CFPB-endorsed Interagency Guidelines ; b. Assess whether Chase violated the spirit or letter of Californias mandatory elder abuse reporting law, particularly Cal. Welf. & Inst. Code 15630.1 ; c. Mandate that Chase reimburse the fraudulently induced transfers, given its admitted failure to report suspected abuse and its violation of the duty of care ; d. Mandate that Chase reopen my bank account and grant me unfettered access to my account ; and e. Issue supervisory guidance or public enforcement actions aimed at improving institutional response to pig butchering and similar elder-targeted scams. 


Respectfully, XXXX XXXX XXXX XXXX J.P. Morgan Chase Bank, N.A. 
XXXX XXXX XXXX. 
XXXX XXXX, CA XXXX ( XXXX ) XXXX

Company response to consumer: Closed with explanation