Consumer complaint received 2026-03-02 00:00:00
Product: Vehicle loan or lease — Loan
Issue: Managing the loan or lease — Billing problem
Company: ALLY FINANCIAL INC.
State: NJ

Complaint narrative:
CFPB COMPLAINT XXXX XXXX XXXX XXXX Product : Retail Installment Sales Contract Vehicle : XXXX XXXX XXXX Date of Execution : XX/XX/year> This complaint concerns material disclosure defects at consummation, post-execution alteration of credit disclosures, and coordinated enforcement of a contract whose operative terms remain unclear. On XX/XX/year>, XXXX XXXX XXXX XXXX presented and executed a Retail Installment Sales Contract in connection with the above-referenced vehicle. That contract was subsequently assigned to Ally Financial. Ally Financial has acknowledged in writing that the contract originated by XXXX XXXX contained omitted or incorrectly stated material disclosures and that corrected disclosures were generated on XX/XX/year> sixteen ( 16 ) days after execution. This admission establishes that the contract as originated was not accurate and complete at consummation. Under the Truth in Lending Act ( TILA ) and Regulation Z, material disclosures must be accurate and complete at consummation. Post-consummation generation of corrected disclosures reflects a disclosure defect at origination, not a clerical adjustment. I was never provided with a corrected contract dated XX/XX/year>. I did not sign or authorize any amended agreement on that date. I did not execute or ratify any post-consummation modification. Despite this, the transaction continues to be enforced as fully valid without re-execution or documented mutual assent. Regulatory Concerns This matter raises the following compliance concerns : Origination of a contract containing omitted or incorrectly stated material disclosures. Post-consummation generation of corrected disclosures without consumer re-execution. Absence of documented assent to any amended instrument. Assignment of a contract requiring correction without clear identification of the operative agreement. Continued enforcement and credit reporting under contractual ambiguity. I have formally requested : Identification of the operative contract XXXX XXXX asserts governs this account. A complete copy of any corrected or amended agreement dated XX/XX/year>. Documentation bearing my signature reflecting assent to any amended terms. A full breakdown of bundled products and third-party payees. Funding documentation demonstrating disbursement consistent with the executed agreement. To date, XXXX XXXX has not produced a contract bearing my signature dated XX/XX/year> and has not clearly identified which agreement governs. Coordinated Enforcement and Assignee Risk The originating dealer and the assignee lender are presently aligned in enforcing a credit obligation despite acknowledged post-execution corrections and the absence of any signed amended instrument. Under TILA, assignees may be subject to liability for disclosure violations apparent on the face of assigned documents. Where a contract required post-consummation correction of material disclosures, questions arise as to whether the defect was apparent at assignment and whether continued enforcement is appropriate without re-execution. Neither XXXX XXXX nor Ally has clearly stated whether : The XX/XX/year> contract governs despite acknowledged disclosure defects ; or A XX/XX/year> corrected version governs despite the absence of consumer assent. If the XX/XX/XXXX contract was compliant, correction would not have been required. If correction was required, enforcement without documented mutual assent creates material compliance exposure for both originator and assignee. Appropriate Compliance Resolution Where a retail installment contract required post-consummation correction of material disclosures and no amended instrument was executed, the most efficient compliance remedy is not continued enforcement under ambiguity. The appropriate resolution may include : Formal re-execution with full and documented consumer consent ; or Repurchase of the contract by the originating dealer and unwind of the assignment ; or Written confirmation that no obligation will be enforced based on terms not provided to or agreed to at consummation. Repurchase or unwind would resolve assignment ambiguity, eliminate potential assignee liability exposure, and allow corrective action at the origination level without prolonged regulatory scrutiny. Resolution Requested 1. Written identification of the operative contract governing this account. 2. Delivery of any corrected disclosures XXXX XXXX and/or Ally rely upon. 3. Documentation bearing my signature for any amended instrument dated XX/XX/year>. 4. Written confirmation that no obligation will be enforced based on terms never provided to or agreed to at consummation. 5. If no signed corrected instrument exists, repurchase and unwind of the assigned contract as the appropriate compliance resolution. 6. Correction of any adverse credit reporting tied to disputed or non-consensual contractual terms. 7. Confirmation that XXXX XXXX has reviewed its origination and post-consummation correction procedures to ensure compliance with TILA and Regulation Z. This complaint concerns disclosure compliance at consummation, proper contract formation, assignment responsibility, and enforcement integrity. I respectfully request formal regulatory review of XXXX XXXX XXXX XXXX origination and assignment practices in connection with this transaction. Additional information provided by consumer : XXXX Consumer wants complaint sent to Ally Financial. Once complaint has been updated please send to company for response.

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