Consumer complaint received 2025-12-16 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Closing your account — Company closed your account
Company: GOLDMAN SACHS BANK USA
State: NY

Complaint narrative:
Subject : Apple Card account closure ( XX/XX/year> ) adverse action without specific reasons ( ECOA / Regulation B ), full credit reporting disclosures, specific contractual basis, and account history relied upon I am submitting this complaint regarding the closure of an Apple Card account issued by Goldman Sachs Bank USA, XXXX XXXX XXXX XXXX. 

The Apple Card account at issue was closed effective XX/XX/year>. At the time of closure, the account was in good standing. The remaining balance has since been paid in full, and the current balance is {$0.00}, as confirmed by Apple Card Support. 

The account closure notice stated that the account was closed because there was a failure to comply with the terms of the Customer Agreement. No further explanation was provided identifying which specific provision of the Customer Agreement was allegedly violated, what conduct formed the basis of this determination, or what account data was relied upon.

I contend that the closure of this Apple Card account constitutes an adverse action under the Equal Credit Opportunity Act ( ECOA ). Under 15 U.S.C. 1691 ( d ) ( 2 ) and its implementing regulation, 12 C.F.R. 1002.9 ( b ) ( 2 ) ( Regulation B ), a creditor that takes an adverse action is required to provide a statement of reasons that is specific and that indicates the principal reason ( s ) for the adverse action. A generic statement that the customer failed to comply with the terms of the Customer Agreement, without identifying any specific term, conduct, or factual basis, does not satisfy this statutory and regulatory requirement.

In addition, pursuant to the Fair Credit Reporting Act ( FCRA ), including 15 U.S.C. 1681m ( a ) and 15 U.S.C. 1681s-2, I am entitled to know whether any consumer report was obtained or used in connection with this adverse action and to receive confirmation that any information furnished to consumer reporting agencies is complete and accurate.

Since the account closure, I have contacted Apple Card Support multiple times via XXXX and telephone, requesting clarification and compliance with these legal requirements. Apple Card Support responded, among other times, on XX/XX/XXXX, XXXX days after the account closureand again on XX/XX/year>, each time reiterating only generic contractual language stating that the issuer reserves the right to close an account at any time, with or without notice. None of these responses identified a specific contractual provision, factual basis, adverse action analysis, credit reporting details, or the account history relied upon. 

I am not disputing Goldman Sachs Bank USAs contractual right to close an account. Rather, I am requesting confirmation that Goldman Sachs Bank USA has complied with its statutory obligations under ECOA and FCRA. 

Specifically, I request that Goldman Sachs Bank USA provide : 1. Confirmation that the closure of the Apple Card account on XX/XX/year> was treated as an adverse action under ECOA, or a clear explanation of why it was not.

2. A specific statement of reasons, as required by 15 U.S.C. 1691 ( d ) ( 2 ) and 12 C.F.R. 1002.9 ( b ) ( 2 ), identifying the principal reason ( s ) for the account closure, including the specific provision ( s ) of the Customer Agreement allegedly violated. 
3. Identification of the specific account history, activity, or data relied upon in determining that the Customer Agreement was violated, including, at a minimum, the category or type of account activity ( for example, types of transactions, use patterns, or other account data ), even if individual transaction-level details are not provided.

4. Confirmation of whether any consumer report or information from any consumer reporting agency was obtained, reviewed, or relied upon in connection with the decision to close the account. 
5. Full disclosure of all information furnished to any consumer reporting agency, whether positive or negative, including account status, remarks, codes, comments, payment history, or classifications, and confirmation that the account is accurately reported as closed by the creditor, with no derogatory notations.

6. Confirmation of whether any adverse action notice or additional disclosure was required or provided under ECOA and/or FCRA, and if not, the legal basis for that determination.

I am requesting the CFPBs assistance in ensuring that Goldman Sachs Bank USA provides the disclosures and specificity required by law. I am seeking clarification and compliance only and am not requesting reinstatement of the account, monetary compensation, or enforcement action. 



Evidence ( plain text, verbatim, redacted ) : XXXX XXXX sent by me to Apple Card Support ( XX/XX/year> ) : Subject : Formal request for specific reasons for Apple Card XXXX ( ECOA ) Hello, I am writing regarding my Apple Card account ( Goldman Sachs Bank USA ) , which was closed effective XX/XX/year>. I received a notice stating that the closure was due to failure to comply with the terms of the Customer Agreement. 

Pursuant to my rights under the Equal Credit Opportunity Act ( ECOA ) and the Fair Credit Reporting Act ( FCRA ), I am requesting a specific written explanation of this decision. In particular, I am relying on the following provisions of the FCRA : 15 U.S.C. 1681m ( a ) ( Requirements on users of consumer reports adverse action disclosures ) 15 U.S.C. 1681s-2 ( a ) and ( b ) ( Responsibilities of furnishers of information ) Accordingly, please provide : 1. The specific provision ( s ) of the Apple Card Customer Agreement that you allege were violated. 
2. The factual basis and account activity relied upon in reaching this determination ( including relevant dates and types of activity ).

3. Confirmation of how this account closure is being reported to consumer reporting agencies, including confirmation that the account is reported as closed by the creditor ( not by the customer ), and identification of any adverse codes, remarks, or classifications furnished. 

Please provide your response in writing by email or secure message. If available, please include a reference or case number for this request. 
2. Account closure notice from Apple Card Support dated XX/XX/year> ( redacted ) : Your account has been closed Apple Card Customer : [ redacted ], [ email address on file ] Your Apple Card account has been closed as of XX/XX/year> and can no longer be used for purchases because : There was a failure to comply with the terms of the Customer Agreement. 

Currently, your account balance is [ redacted ] Recent activity, including purchases and interest charges, may not yet be reflected. If you have a balance, minimum payment must be made each month until the account is paid off. 

Apple Card is issued by Goldman Sachs Bank USA, XXXX XXXX XXXX XXXX. 

Notice : The Federal Equal Credit Opportunity Act prohibits creditors from discriminating against credit applicants on the basis of race, XXXX, religion, national origin, XXXX, marital status, age ( provided the applicant has the capacity to enter into a binding contract ) ; because all or part of the applicants income derives from any public assistance program ; or because the applicant has in good faith exercised any right under the Consumer Credit Protection Act. The Federal agency that administers compliance with this law concerning this creditor is the Bureau of Consumer Financial Protection, XXXX XXXX XXXX XXXX XXXX XXXX XXXX 
XXXX. Follow-up email from Apple Card Support dated XX/XX/year> ( redacted ) : Following up on your Apple Card feedback Apple Card Customer : [ redacted ], [ email address on file ] We received feedback regarding your Apple Card account and are looking into it. 
Per the terms and conditions outlined in the Customer Agreement, we reserve the right to close your Apple Card account at any time, with or without notice. Please continue to make payments until the balance is XXXX. 
If you have any further questions, please reach out to an Apple Card Specialist. 

Apple Card is issued by Goldman Sachs Bank USA, XXXX XXXX XXXX XXXX. 
4. Follow-up email from Apple Card Support dated XX/XX/year> ( redacted ) : We received feedback regarding your Apple Card account and are looking into it. 
Per the terms and conditions outlined in the Customer Agreement, we reserve the right to close your Apple Card account at any time, with or without notice. Please continue to make payments until the balance is XXXX. 

Additional context : XXXXalance paid in full; current balance : {$0.00} Apple Card Support case reference ending in XXXX

Company response to consumer: Closed with explanation