Consumer complaint received 2025-12-01 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Getting a credit card — Application denied
Company: BANK OF AMERICA, NATIONAL ASSOCIATION
State: NY

Complaint narrative:
I am filing this complaint because Bank of America issued an adverse action notice denying my application for the Bank of America XXXX XXXX XXXX XXXX XXXX credit card. The denial appears to have been made without a legally sufficient explanation, and I believe the bank failed to comply with federal credit laws, including the Equal Credit Opportunity Act ( ECOA ), Regulation B, the Fair Credit Reporting Act ( FCRA ), and the Truth in Lending Act ( TILA ). 
On XX/XX/year>, I received an Adverse Action Notice listing the following general reasons : Balance is too high relative to the credit limit on one or more of your revolving accounts XXXX since your oldest revolving card account opening Balance on revolving trade ( s ) One or more revolving account ( s ) recently opened These statements are vague, generic, and do not specify which accounts, balances, credit score factors, or underwriting criteria were used.

Under ECOA/Regulation B ( 12 CFR 1002.9 ), creditors must provide specific reasons for a denial. The reasons given do not satisfy this requirement. 

Furthermore, because Bank of America stated that the decision was based on information from a consumer reporting agency ( XXXX  ), I requested : The exact credit score used The key factors affecting that credit score The specific entries in the report relied upon A clear explanation of the underwriting criteria Under the Fair Credit Reporting Act ( FCRA ), a consumer has the right to this information when credit is denied based on a credit report. 

Bank of America has not provided this required information. 

In addition, I have requested formal reconsideration and requested approval with a reasonable credit limit between {$10000.00} - {$15000.00}, which aligns with my financial situation and would correct utilization issues that the bank itself cited as concern factors. 

I also provided Bank of America a written demand and gave them 30 days to provide a legally compliant response, including : A complete and detailed ECOA-compliant adverse action explanation Identification of the exact criteria used in the lending decision Reconsideration of my application A written decision consistent with federal law I am submitting this complaint because Bank of Americas denial letter does not appear to comply with ECOA, FCRA, or TILA transparency requirements, and the bank has not provided the required specific reasons or supporting information. This deprives me of my right to understand and verify the basis of the adverse credit decision.

I am requesting that the CFPB : Require Bank of America to issue a legally compliant adverse action explanation Require them to disclose the exact credit score and factors used Require them to disclose the specific underwriting data and credit report items used Require them to properly reconsider the application using correct procedures Ensure that Bank of America is in compliance with ECOA, FCRA, and TILA regarding transparency and nondiscrimination I am also attaching a copy of my written letter to Bank of America, which outlines the deficiencies and my formal requests. 
I am seeking a full explanation, proper reconsideration, and correction of any unlawful or non-compliant lending practices related to this application.

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