Consumer complaint received 2025-05-13 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Installment loan
Issue: Getting the loan — 
Company: RockLoans Holdings LLC
State: CO

Complaint narrative:
In the CFPB response from Rocket I was encouraged to apply again. Before doing so on XX/XX/XXXX I sent an email to enact my consumer credit transaction rights ( provided below ). Then applied again. The response I received from Rocket was still pertaining to the loan in question from the first complaint. ( also provided below ) Still standing firm on a denial. Which is not lawful. Even though steps were taken to accommodate what I hoped to be a good faith partner in a lawful consumer credit transaction. I sent a subsequent email ( also provided below ) explaining how tithe response from Rocket was unlawful. The current loan was also denied. And has not been addressed either. The emails are posted chronologically.

Formal Enactment of Consumer Credit Transaction Rights {$25000.00} Application XX/XX/XXXX To : support CC : legal Dear Rocket Loans Compliance and Consumer Lending Department, This correspondence serves as my formal enactment of a lawful consumer credit transaction under federal law in the amount of {$25000.00}. This is not merely a request for considerationit is a lawful execution of my rights under the Consumer Credit Protection Act ( 15 U.S.C. 1601 et seq. ), the Truth in Lending Act ( TILA ), the Equal Credit Opportunity Act ( ECOA ), the Fair Credit Reporting Act ( FCRA ), and the Uniform Commercial Code ( UCC Articles 1, 3, and 9 ).

I am acting in full compliance with 15 U.S.C. 1602 ( e ) and 1602 ( i ), which clearly define this engagement as a consumer credit transaction. As the original creditor and party in interest, I have presented a bona fide offer of credit that meets the legal standards of enforceable commercial obligation under UCC 3-104, 3-105, and 3-302.

Key Points of Law and Demand for Action : 1. Holder in Due Course ( UCC 3-302, 3-305 ) : I hold lawful status as a Holder in Due Course and am asserting my right to enforce a negotiable instrument in satisfaction of this credit. Refusal to process this lawful transaction constitutes dishonor ( UCC 3-502 ) and a restraint of lawful commerce ( UCC 1-103 ( b ) ).

2. Non-Discretionary Compliance with Federal Law : No internal policy, risk model, or scoring threshold supersedes federal law. 15 U.S.C. 1691 ( a ) and 1602 require that this transaction be honored on the basis of legal capacity, lawful offer, and consumer rightsnot subjective risk assessment.

3. TILA Enforcement and Full Disclosure ( 15 U.S.C. 1631, 1632 ) : You are required to provide full, itemized disclosure of finance charges, APR, and loan terms prior to declination or funding. Failure to do so constitutes noncompliance and may void the adverse action.

4. Adverse Action Transparency ( 15 U.S.C. 1691 ( d ), 15 U.S.C. 1681m ) : Should Rocket Loans choose to deny this transaction, I demand a legally compliant adverse action notice including all models, scorecards, and third-party data sources. Failure to provide such data is a violation of both ECOA and FCRA.

Formal Demands : - Immediate approval and funding of this consumer credit transaction in the amount of {$25000.00}.

- Written confirmation that all rights under UCC, TILA, FCRA, and ECOA are being honored.

- Identification of the officer or legal representative responsible for enforcing compliance.

- A response within three ( 3 ) business days from the date of this notice.

Let me be clear : this is not a mere application. It is a lawful execution of a protected credit transaction under multiple federal statutes. Noncompliance will be escalated to the Consumer Financial Protection Bureau ( CFPB ), the Office of the Comptroller of the Currency ( OCC ), and, if necessary, the Department of Justice for deprivation of rights under 42 U.S.C. 1983.

I remain ready and willing to finalize this transaction. Please ensure this matter is handled by your compliance and legal teams immediately.

Respectfully, Loan Applicant Hi Loan Applicant, We are in receipt of your below email. Please understand that Rocket Loans has addressed your concerns noted below in our email response dated XX/XX/XXXX and our response to your CFPB complaint, dated XX/XX/XXXX. Our response remains unchanged. 

Loans on the Rocket Loans platform are offered by XXXX XXXX XXXX XXXX XXXX XXXX ), a New Jersey state-chartered, FDIC insured bank. Rocket Loans assists in processing credit applications for the Bank, provides technology to the Bank, and incorporates the Banks unbiased and nondiscriminatory credit eligibility criteria to provide a lending decision. Eligibility for a loan is determined by credit usage, credit history, and other factors. Rocket Loans performs a soft credit pull, which does not impact your credit score, to determine your credit worthiness. As a result, your application was denied on XX/XX/XXXX based on your credit history, and the reasons for such denial are outlined in the Adverse Action Notice that has been provided to you by email on XX/XX/XXXX. Please note, neither Rocket Loans nor the Bank have the obligation to send a TILA-compliant disclosure to you as we could not provide you with any loan offers based on your creditworthiness and a loan was not originated. Further, you are not a holder in due course because a loan was not originated, and a Promissory Note was not presented to you. 


Rocket Loans is in full compliance with the law as your application was denied based on nondiscriminatory factors outlined in the Adverse Action Notice and was based on a determination of your creditworthiness. You are welcome to reapply for a personal loan in the future ; however, we will not be reconsidering your application from XX/XX/XXXX. We truly hope that our multiple communications on this matter have cleared up your concerns.

Sincerely, Rocket Loans Subject : Formal Rebuttal and Demand for Reconsideration under 15 U.S.C. 1691 et seq. and U.C.C. 3-106 ( d ) To Whom It May Concern, This correspondence serves as a formal rebuttal and notice of deficiency in response to your recent message dated XX/XX/XXXX, as well as your referenced responses dated XX/XX/XXXX and XX/XX/XXXX regarding CFPB complaint 1. 

Failure to Uphold Consumer Credit Transaction Rights under 15 U.S.C. 1602 and 1691 Under 15 U.S.C. 1691 ( a ) ( Equal Credit Opportunity Act ) and 12 CFR 1002.6 ( b ) ( 5 ), lenders are prohibited from discounting or disqualifying an applicants income or financial position based solely on application structure, particularly if the applicant shares joint access to verifiable depositsas in this case. If any part of the underwriting decision failed to consider the entirety of my available credit capacityincluding consistent joint-account depositssuch exclusion would constitute disparate impact discrimination and violate the ECOA.

Further, under 15 U.S.C. 1602 ( i ) and Regulation Z, any action involving the offering, negotiation, or prequalification of a credit product initiates a consumer credit transactionwhether or not the loan is consummated. Your statement that TILA does not apply because no offer was made is incorrect as a matter of law. The moment Rocket Loans solicited, processed, and evaluated my financial data for a credit decision, a credit transaction occurred under Regulation Z and Title 15, and my Truth in Lending rights became activeeven if a formal promissory note was not delivered.

2.

Incorrect Interpretation of Holder in Due Course Status under U.C.C. 3-106 ( d ) Your assertion that I am not a holder in due course because a note was not presented mischaracterizes the applicable Uniform Commercial Code. Under UCC 3-106 ( d ), a refusal to extend credit under discriminatory or commercially unreasonable pretense converts a rejected application into a conditional instrument where obligations remain unresolved until formally disclaimed. As you acknowledge that the decision was based on creditworthiness but fail to provide substantive evidence beyond a general denial, I must treat the rejection as an unsubstantiated commercial refusal subject to formal dishonor under UCC 3-501 and 3-505.

3.

Demand for Reconsideration or Legal Justification I hereby demand that you either : Reconsider the original application in full light of my consumer credit transaction rights, my household income eligibility under 12 CFR 1002.6, and the commercial obligation to not rely on arbitrary credit scoring models that produce disparate impact ; or Furnish a legally sufficient explanationbacked by specific data inputs and scoring methodologyproving that your decision was not based on any discriminatory or materially incorrect criteria.

If no valid justification is provided, I will construe this denial as a willful violation of 15 U.S.C. 1602, 1691, and UCC Article 3, and will escalate this matter through : A supplemental complaint to the CFPB, citing discriminatory practices and failure to comply with lawful obligations ; A formal grievance with the Office of the Comptroller of the Currency ( OCC ) for XXXX XXXXXXXX XXXX role ; Filing a Notice of Dishonor under UCC 3-505 and pursuing enforcement of consumer remedies under Title 15 and state consumer protection laws.

Please be advised this letter serves as a lawful notice and demand under federal and commercial code. If I do not receive a satisfactory response within 7 business days, I reserve the right to pursue all legal remedies available. 



Respectfully, Loan Applicant Date : XX/XX/XXXX

Company response to consumer: Closed with explanation