Consumer complaint received 2026-02-15 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Problem with a purchase shown on your statement — Credit card company isn't resolving a dispute about a purchase on your statement
Company: CITIBANK, N.A.
State: AR

Complaint narrative:
Here is a clean, self-contained narrative you can paste into the CFPB portal or a letter ( you can adjust formatting and any dates/amounts as needed ) : CFPB Complaint Pattern of Inconsistent Investigative Determinations, Inadequate Written Explanation, and Failure to Apply Uniform Billing Error Standards Account Ending : XXXX In total, I have disputed 147 transactions from this merchant family. Of those, 133 were credited and 14 were denied. During XXXX, I received {$18000.00} in security credits labeled SECURITY CREDIT ITEM UNDER INVESTIGATION tied to this merchant group, reflecting the substantial scale of disputed activity and corresponding account adjustments. Despite this volume and pattern of credits, Citibank has alternated among Security Credit Issued, Customer Responsible ( No Credit Issued ), and Credit Reversed determinations on transactions sharing materially similar characteristics, without identifying transaction-specific evidentiary distinctions. This pattern raises concerns regarding the consistency of Citibanks application of Truth in Lending Act and Regulation Z billing error standards under 15 U.S.C. 1666 and 12 C.F.R. 1026.13. 

Illustrative Transaction Comparisons Example 1 : XXXX XXXX XXXX NY {$290.00} Disputed XX/XX/XXXX Security Credit Issued ( XX/XX/XXXX ) XXXX XXXX XXXX NY {$290.00} Disputed XX/XX/XXXX Customer Responsible ( No Credit Issued ) Example 2 : XXXX XXXX Coins {$44.00} Disputed XX/XX/XXXX Security Credit Issued Comparable merchant-family transactions Denied using identical boilerplate language. 

Applicable Law Under 15 U.S.C. 1666 ( a ), upon receipt of a billing error notice, a creditor must investigate and either correct the error or provide a written explanation clarifying why the charge is believed to be correct. Regulation Z requires : 12 C.F.R. 1026.13 ( b ) ( investigation of billing errors ) ; 12 C.F.R. 1026.13 ( e ) ( correction where error is found ) ; 12 C.F.R. 1026.13 ( f ) ( reasonable investigation and written explanation of results ) ; and 12 C.F.R. 1026.13 ( g ) ( restriction on collection of disputed amounts during investigation ). A written explanation must reflect the investigation actually conducted and identify the basis upon which the creditor concluded the transaction was authorized. 

Signature-Packet Process Inconsistency In at least one instance, Citibank issued an Action Required packet requiring a signed consumer affirmation in response to merchant documentation asserting authorization. This demonstrates that merchant-provided materials were not treated as self-proving. However, in other materially similar disputes involving the same merchant family, Citibank issued final denials without comparable escalation or articulated differentiation. This variability raises concerns regarding uniform application of investigative standards under 1026.13 ( f ). 

Opacity of Investigative Basis Citibanks adverse determinations rely on boilerplate language stating : Your dispute is resolved and no credit has been issued. The letters do not identify whether AVS results were reviewed, whether CVV verification was confirmed, whether IP/device consistency was analyzed, or what evidentiary distinction justified differing outcomes among materially similar transactions. Without articulated differentiation, the written explanation requirement of 1026.13 ( f ) is not meaningfully satisfied. 

Requested Relief Provide transaction-specific written explanations identifying investigative findings relied upon. 

Disclose authentication and evidentiary data reviewed for denied transactions. 

Confirm whether uniform escalation procedures were applied across materially similar disputes. 

Reevaluate denied transactions where no articulated evidentiary distinction exists.

Confirm compliance with 15 U.S.C. 1666 and 12 C.F.R. 1026.13.

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 monetary relief