Consumer complaint received 2025-11-21 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Closing your account — Company closed your account
Company: CITIBANK, N.A.
State: TX

Complaint narrative:
CFPB Rebuttal Referencing FCRA, ECOA, Adverse Action, and Anti-Retaliation Principles I am submitting this rebuttal because Citi Cards CBNA has engaged in a continuing pattern of conduct that raises significant concerns under the Fair Credit Reporting Act ( FCRA ), the Equal Credit Opportunity Act ( ECOA ), and applicable adverse action and anti-retaliation principles. Citis actions remain unresolved, harmful, and suggest systematic bad-faith behavior. 
1. Citi Has Not Explained the Source of the False Bankruptcy Notification Citi claims my account was closed because they received a bankruptcy notification, yet no bankruptcy exists on any of my credit reports and I have never filed for bankruptcy.

Under FCRA 623 ( a ) ( 1 ) ( A ), a furnisher of information must not report information it knowsor has reasonable cause to believeis inaccurate.

Closing my account based on unverified, false bankruptcy information indicates that Citi : Failed to conduct reasonable procedures to assure maximum possible accuracy, as required by FCRA 1681s-2 ( a ), Took adverse action based on information that was either negligently or recklessly misinterpreted, and Can not demonstrate the source or reliability of the data used to justify the closure.

No explanation has been provided regarding the origin of this serious and damaging error.

2. Citi Took Adverse Action Without Complying With ECOA Notice Requirements Closing a credit account or lowering a credit line constitutes an adverse action under ECOA ( 15 U.S.C. 1691 ( d ) ) and Regulation B ( 12 CFR 1002.2 ( c ) ).

ECOA requires creditors to provide : A clear, specific reason for the adverse action, A notice of the consumers rights, and Disclosure of the information used in making the decision.

Citi did not provide accurate or complete reasons for the closure, nor did they meaningfully disclose the source of the bankruptcy claim. Vague or pretextual explanationssuch as expiration of card or other generic excusesdo not satisfy ECOA 's requirements for adverse action notices.

3. Retaliatory Conduct After CFPB Complaint and During Active Litigation Following my initial CFPB complaint and ongoing litigation against Citi, the company has : Permanently closed the Citi AAdvantage card they previously claimed to have reopened, citing expiration date as the reason Repeatedly and systematically reduced the limit on my Citi-issued
Dillards card Refused to correct or reinstate the Citi Macys American Express accountthe account with the highest credit limit Failed to correct the cascading harm caused to my accounts with other creditors Although federal consumer-protection laws do not explicitly codify a retaliation statute for credit card issuers, courts and regulators have routinely held that punitive or adverse actions taken in response to a consumer exercising their rights may constitute : Bad-faith conduct Unfair or deceptive practices under the CFPB UDAAP authority ( unfair, deceptive, or abusive acts or practices ) Violations of ECOA, when adverse actions appear to be tied to a consumer exercising a protected right to dispute or challenge information Citis selective reopening of a low-limit account, followed by later closure and ongoing punitive behavior, supports the reasonable inference of retaliatory intent.

4. Unauthorized Inquiry and Continued Mishandling Under FCRA Citi conducted a credit inquiry that I did not authorize. Their responsereclassifying it as a non-display or soft inquirydoes not resolve the issue.

Under FCRA 604 ( a ), a permissible purpose must exist at the time the inquiry is initiated.

Recasting a hard inquiry after the fact does not cure the absence of permissible purpose at the moment it was pulled.

Citi failed to : Explain why the inquiry was conducted Provide evidence of permissible purpose Remove the inquiry entirely This constitutes a continued violation of my rights under the FCRA.

5. Continuing Credit Damage Created and Amplified by Citis Own Misconduct Because Citi initiated a false bankruptcy flag, other creditors received inaccurate signals about my creditworthiness. As a result : Credit limits were lowered Accounts were reassessed My credit score was damaged My overall credit profile has suffered long-term harm Citi has not corrected the downstream impact on my credit filedespite being the cause of the erroneous information.

Under FCRA 623 ( b ), once a consumer disputes information, the furnisher must : Conduct a reasonable investigation Review all relevant information Delete all negative information across all reporting channels Citi has not fulfilled these obligations.

6. Requested CFPB Action Given the ongoing nature of Citis misconduct, I request that the CFPB require Citi to : Disclose the source, evidence, and internal documentation supporting the false bankruptcy claim. I am also sending request.

Provide a legally compliant ECOA adverse action notice for each closure and limit reduction.

Removenot reclassifythe unauthorized inquiries and certify that no unauthorized access continues.

Restore or the Citi Macys American Express account reflecting a XXXX balance with the same credit limit due to their mistake and any related internal coding. 
Reverse all retaliatory reductions and closures, or provide verifiable documentation justifying each decision under ECOA. 
Delete all negative information on my credit reports and notify all affected furnishers. 
Explain why the account they claimed to reopen was later closed on a pretextual basis. 
Provide a timeline of corrective actions with documentation. 
Citis conduct reflects a pattern of noncompliance, adverse actions imposed without proper notice, and behavior that strongly suggests retaliation against a consumer for exercising their rights under federal law.

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