Consumer complaint received 2025-10-03 00:00:00
Product: Money transfer, virtual currency, or money service — International money transfer
Issue: Other transaction problem — 
Company: AMERICAN EXPRESS COMPANY
State: SC

Complaint narrative:
Failure to Conduct Proper Investigation Violation of FCBA and Regulation E Introduction & Summary of Complaint I am formally escalating my dispute regarding the improper handling of a payment in the amount of {$11000.00}, tied to my American Express account American Express acknowledged receipt of my dispute under Dispute Reference Number XXXX and issued correspondence dated XX/XX/XXXX ; XX/XX/XXXX ; and XX/XX/XXXX. In these letters, American Express claimed that it had conducted an investigation into my billing dispute. However, the review performed was inadequate and non-compliant with the requirements of the Fair Credit Billing Act ( FCBA, 15 U.S.C. 1666 ) and Regulation E ( 12 CFR Part 1005 ).

2. Issuing Bank Responsibility Under Regulation E The CFPB Supervisory Highlights, Issue 37 ( Winter 2024 ) explicitly reaffirm that consumers have a
reasonable expectation that their issuing bank will comply with Regulation E and honor valid stop-payment requests. American Express itself acknowledged in its XX/XX/XXXX letter that it is the issuing bank. 

As such, AmEx is directly obligated to : Ensure compliance with 1005.10 ( c ) regarding stop-payment rights ; Prevent unauthorized or misexecuted debits ; Conduct a reasonable investigation when a billing error or dispute is raised.

3. Failure to Conduct a Reasonable Investigation The investigation described in AmExs correspondence does not satisfy FCBA or Reg E standards because : 1. No Merchant Verification : The record shows no evidence that AmEx contacted the merchant to validate or deny the authorization of the disputed transaction. Internal review alone does not constitute a reasonable investigation under federal law. 2. Improper Dismissal of Payment Instrument : AmEx claimed the payment coupon appeared to have been modified and therefore rejected it as a payment
instrument. However, this conclusion was reached without confirming whether the coupon or related transaction was properly processed through its merchant or processor channels.

3. Processor Accountability : If XXXX or any other third-party PIN-debit processor was involved in the handling of this payment, AmExas the issuing bankis legally responsible for their compliance failures.

4. CFPB Findings on Improper Practices The CFPB has already found in Supervisory Highlights that : Network operators and ODFIs have engaged in improper re-presentment and failure to monitor ACH transactions, causing substantial consumer injury.

Issuing banks have an obligation to ensure stop-payment requests are honored and to prevent unauthorized or improperly re-processed transactions.

By refusing to honor my dispute and failing to properly investigate, AmExs actions fall squarely within the unfair or deceptive acts or practices ( UDAAP ) identified by CFPB supervision.

5. Remedy Requested I hereby demand that American Express : 1. Immediately correct my account by reversing the disputed amount of {$11000.00}.

2. Confirm in writing that all interest, late fees, penalties, or adverse credit reporting related to this dispute will be removed.

3. Provide documentation of all communications with the merchant and/or processors relating to this transaction, as required under FCBA/Reg E .

4. Preserve all records relating to this dispute for review by the CFPB.

6. Notice of CFPB Filing This letter is being submitted concurrently to the Consumer Financial Protection Bureau for independent review. The CFPB has jurisdiction over violations of FCBA and Regulation E and has already identified similar practices as unlawful.

7. Conclusion American Express, as the issuing bank, can not meet its federal obligations by limiting its investigation to an internal review. Without merchant-level verification and proper adherence to Regulation E stop-payment rules, the investigation performed is inadequate and unlawful.

Company response to consumer: Closed with explanation