Consumer complaint received 2025-12-26 00:00:00
Product: Vehicle loan or lease — Loan
Issue: Managing the loan or lease — Problem with additional products or services purchased with the loan
Company: NAVY FEDERAL CREDIT UNION
State: MD

Complaint narrative:
I am submitting this complaint regarding Navy Federal Credit Union ( NFCU ) to request formal review of what I believe constitutes unfair and deceptive practices related to hardship relief representations made to me during a period of unemployment.

Before detailing the facts, I want to addressupfront and clearlyanticipated defenses that may be raised by the creditor.

I understand creditors often respond by asserting that hardship relief discussions are informational only, subject to change, or not guaranteed. However, in my case, specific representations were made, a timeline was provided, and reliance was induced. At no point was I informed that the options discussed were speculative, conditional upon undisclosed criteria, or likely to be unavailable. Any post hoc attempt to characterize these representations as nonbinding contradicts the substance and structure of the communication itself.

Factual Background On XX/XX/year>, I spoke with a Navy Federal collections representative named XXXX regarding my credit card account. During this conversation, I disclosed that I was unemployed and experiencing financial hardship and requested assistance.

During that call, I was advised : That I could delay payment due to unemployment-related hardship That my account would be reviewed for a permanent interest rate reduction and lower monthly payment That if I could wait until XX/XX/year>, at which time permanent optionsincluding a reduced interest rate or permanent refinancewould populate within the collections system for the vehicle loan I relied on these representations in good faith and followed the guidance provided. After XX/XX/year>, I contacted Navy Federal to proceed, only to be informed that the options discussed were unavailable or could not be honored.

There was no material change in my financial circumstances, no new adverse information, and no prior disclosure that these options were provisional or unlikely.

Legal and Regulatory Concerns This conduct raises concerns under multiple federal consumer protection frameworks, including : Dodd-Frank Act ( 12 U.S.C. 5531, 5536 ) Prohibiting unfair, deceptive, or abusive acts or practices ( UDAAP ). Making specific representations about future relief, inducing reliance, and later denying those representations without disclosure constitutes deception and consumer harm.

Truth in Lending Act ( TILA ) and Regulation Z ( 12 C.F.R. Part 1026 ) Requiring clear, accurate, and non-misleading disclosures regarding credit terms and servicing. The absence of transparency around eligibility criteria and the reversal of communicated options impaired my ability to make informed decisions.

CFPB Servicing Standards and Supervisory Expectations Which require financial institutions to provide consistent, accurate information to consumers seeking hardship accommodations, particularly when unemployment is disclosed.

Any assertion that I should have known the representations were nonbinding is unreasonable and unsupported. The burden of clarity lies with the servicer, not the consumerespecially in collections communications where reliance is foreseeable.

Requested Resolution I respectfully request that the CFPB require Navy Federal Credit Union to : Produce documentation or call records reflecting the representations made on XX/XX/year> Explain the criteria used to deny the permanent interest rate reduction and lowered payment plan discussed Honor the promised review for permanent hardship relief, including a reduced interest rate Correct internal practices that result in consumers being given misleading timelines or expectations during hardship discussions This complaint is submitted to ensure transparency, accountability, and compliance with federal consumer protection law. I am not seeking preferential treatmentonly that representations made to a consumer during documented hardship be honored or, at minimum, clearly and accurately disclosed.

Company public response: Company believes it acted appropriately as authorized by contract or law
Company response to consumer: Closed with explanation