Consumer complaint received 2025-06-01 00:00:00
Product: Prepaid card — Government benefit card
Issue: Problem with a purchase or transfer — Charged for a purchase or transfer you did not make with the card
Company: BANK OF AMERICA, NATIONAL ASSOCIATION
State: CA

Complaint narrative:
To Whom It May Concern : I am filing this complaint against Bank of Americas Prepaid Debit Card Department for systemic violations of federal consumer protection laws, unfair practices, and inconsistent handling of multiple transaction disputes tied to Californias EDD prepaid debit card. Below, I outline the facts, legal violations, and request for corrective action. 

-- - Background During the COVID-19 pandemic, Bank of America ( BofA ) issued California EDD benefits via prepaid debit cards. I never received my card, leading to unauthorized transactions. I filed disputes for these transactions, which BofA split into separate claims by date. While some disputes were approved ( with BofA admitting I never received the card ), others were denied under contradictory reasoning ( e.g., alleging I or someone authorized used the card ). In one case, BofA forced a merchant to return partial funds but denied the remainder of the claim without justification. 

-- - Violations of Federal Laws and Regulations Bank of Americas actions violate the following laws and consumer rights : 1. Regulation E ( 12 CFR 1005.11 ) - Failure to Conduct Reasonable Investigations : Regulation E mandates that financial institutions investigate disputes promptly, provide provisional credit within 10 business days ( for eligible accounts ), and base decisions on factual evidence. BofAs contradictory approvals/denials for identical claimsadmitting non-receipt of the card in some cases while denying others without evidencedemonstrate failure to comply with 1005.11 ( c ). 
- Inconsistent Error Resolution : By approving some disputes and denying others under the same factual circumstances ( non-receipt of the card ), BofA violated 1005.11 ( d ), which prohibits arbitrary resolution of error claims. 

2. Unfair, Deceptive, or Abusive Acts or Practices ( UDAAP ) under the Dodd-Frank Act ( 12 U.S.C. 5531 ) - BofAs refusal to apply consistent standards to identical disputes constitutes unfair practices. Their reliance on boilerplate denials ( e.g., you or someone authorized used the card ) without evidence of card receipt or authorization violates prohibitions against deceptive conduct. 

3. Electronic Fund Transfer Act ( EFTA ), 15 U.S.C. 1693 - BofA failed to provide written explanations with specific reasons for denials ( XXXX ), as required. Their denials cited generic justifications unsupported by evidence, particularly when they previously admitted non-receipt of the card. 

4. CFPB Consent Order ( XXXX  ) Precedent : - In XXXX, the CFPB fined BofA {$220.00} XXXX for illegally freezing accounts and mishandling EDD disputes. The banks pattern of arbitrary dispute resolution in my case mirrors the conduct cited in the CFPBs enforcement action. 

-- - Key Evidence of Violations 1. Contradictory Determinations : - Approved disputes : BofA acknowledged non-receipt of the card ( e.g., transactions on [ dates ] ).

- Denied disputes : Cited authorized use without evidence, despite prior admissions.

2. Partial Merchant Reversals : - Forcing a merchant to return funds ( e.g., transaction on [ date ] ) confirms unauthorized activity, yet BofA denied the remainder of the claim without justification.

3. Lack of Evidence : - BofA provided no documentation proving card delivery, activation, or authorization for the denied claims. 

-- - Enclosures - Copies of dispute records ( approved/denied ). 
- BofAs written admissions of non-receipt. 
- Evidence of merchant reversals. 
- Prior correspondence with BofA. 

XXXX XXXX XXXX XXXX XXXX

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