Consumer complaint received 2025-10-03 00:00:00
Product: Checking or savings account — Checking account
Issue: Opening an account — Unable to open an account
Company: NAVY FEDERAL CREDIT UNION
State: MO

Complaint narrative:
I am filing this complaint against Navy Federal Credit Union ( NFCU ) due to repeated, automatic, and unexplained denials of my applications to open and maintain a standard consumer banking account. Despite multiple attempts to establish a membership and account relationship with Navy Federal, I have consistently been turned away without adequate disclosure of the underlying reasons, codes, or data driving these adverse actions. 

Each time I submitted an application, I provided valid identification and the necessary documents required of any consumer. Yet, Navy Federal has treated me as ineligible, while failing to provide the proper written adverse action notices mandated by the Equal Credit Opportunity Act ( ECOA ) and its implementing regulation, Regulation B. These denials have not been tied to any actual misconduct on my part, but instead appear to rely on inaccurate, outdated, or fraudulent information being circulated through third-party consumer reporting systems such as XXXX XXXX XXXX XXXX, and the nationwide credit bureaus. 

As a result, I have been denied fair access to financial services, cut off from the opportunity to bank with an institution that advertises itself as a trusted resource for consumers, and subjected to reputational and financial harm. 

Pattern of Denials Every time I attempt to open an account with Navy Federal Credit Union, the process halts abruptly, and I am informed verbally that I am not eligible or that my application can not be approved. However, I have not been given clear explanations in writing, nor the adverse action notices that I am entitled to under XXXX. These notices are critical because they disclose the exact information a creditor relied upon in making its decision. Without them, I am unable to effectively dispute or correct any errors. 

Likely Use of Flawed Third-Party Data From my own investigations and correspondence with the credit reporting agencies, I am aware that my consumer files contain inaccurate and fraudulent entries. For example, unverified derogatory accounts continue to appear on Equifax and TransUnion. My files also contain numerous hard inquiries that were not authorized by me, including from XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, and XXXX. These inquiries lack permissible purpose under FCRA 604. 

Because Navy Federal Credit Union participates in networks such as XXXX XXXX XXXX and XXXX I have reason to believe that they are relying on these flawed data sets in making their account-opening decisions. However, instead of investigating or providing me with documentation to support their decisions, they have denied me outright. This amounts to negligence and a failure of their duty to ensure the accuracy of information they rely upon when evaluating consumer applications. 

Violations of Law Navy Federals repeated denials and refusal to provide transparency constitute violations of multiple federal statutes.

1. Equal Credit Opportunity Act ( ECOA ) : Navy Federal is required to provide an adverse action notice any time it denies an application for credit or financial services. These notices must specify the principal reasons for
denial. By refusing to provide me with these disclosures, Navy Federal has violated 15 U.S.C. 1691 ( d ) and Regulation B.

2. Fair Credit Reporting Act ( FCRA ) : By relying on inaccurate consumer report information without giving me the ability to review or dispute it, Navy Federal is failing to uphold the accuracy and fairness standards built into 15 U.S.C. 1681 et seq. If they relied on XXXX XXXX or the big three CRAs, they had a duty to provide me with the name and contact information of the reporting agency. This has not been done. 
3. Consumer Financial Protection Act ( CFPA ) : Denying me access to banking without transparency or due process is both unfair and abusive under 12 U.S.C. 5531. Navy Federals refusal to explain or investigate its own decision-making effectively traps me in a cycle of financial exclusion.

4. Uniform Commercial Code ( UCC ) : As a financial institution engaged in commercial transactions, Navy Federal is bound by UCCs obligations of good faith and fair dealing. Denying a consumer based on secret or flawed internal codes without disclosure undermines good faith and violates the spirit of commercial fairness. 

Harm Caused These actions have caused measurable harm. Because of the repeated denials, my ability to bank has been curtailed. I have been unable to establish a secure account, direct deposits, or access to credit products that would allow me to build financial stability. The stigma of being denied by a major credit union has damaged my financial reputation. My credit scores have also suffered due to inaccurate reporting and unauthorized inquiries, dropping by more than XXXX points. The result is exclusion from financial services that are essential for everyday life. 
Requested Relief I request that the CFPB investigate Navy Federal Credit Unions account denial practices in detail. Specifically, I request : Full disclosure of the internal denial codes, criteria, or systems Navy Federal uses to evaluate consumer applications, including any reliance on XXXX XXXX XXXX XXXX, or other CRAs. 
A requirement that Navy Federal provide me with a proper adverse action notice for each denial, as required by ECOA and FCRA. 
A directive that Navy Federal stop relying on flawed or disputed data without conducting reasonable investigations. 
Deletion of any inaccurate or unverifiable data that Navy Federal has used to justify denials.

Oversight by CFPB to ensure that Navy Federals future practices comply with federal consumer protection law.

Company public response: Company believes it acted appropriately as authorized by contract or law
Company response to consumer: Closed with explanation