Consumer complaint received 2026-05-18 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Problem using a debit or ATM card
Company: FIRST HORIZON BANK
State: TN

Complaint narrative:
RE : Formal CFPB Complaint Against First Horizon Bank Failure to Process Valid XXXX Chargebacks Under Reason Codes 13.1 and 13.3 Account No. XXXX XXXX XXXX XXXX XXXX XXXX XXXX Transactions Totaling {$140000.00} Four Merchant Descriptors Across Three International Jurisdictions International Assessment Fees Collected on Unlawful Gambling Charges {$35.00} Overdraft Fee UIGEA / Regulation GG Compliance Failure Tennessee AG Enforcement Action I. PARTIES Complainants : XXXX XXXX and XXXX XXXX XXXX, XXXX XXXX XXXX XXXX, XXXX, TN XXXX. Respondent : First Horizon Bank, Fraud Prevention Services, Attn : XXXX XXXX. ( Claim Investigator ), XXXX, XXXX. II. SUMMARY First Horizon Bank processed {$140000.00} in XXXX XXXX XXXX XXXX XXXX XXXX transactions on Account No. XXXX from XX/XX/XXXX through XX/XX/XXXX. Complainants ' account statements document that the same illegal operator XXXX XXXX XXXX / XXXX XXXX routed charges through four separate merchant descriptors across three international jurisdictions, all appearing on the same First Horizon account. First Horizon 's UIGEA compliance program failed to identify or block any of these transactions despite their volume, frequency, multi-jurisdictional routing, and the Tennessee AG 's public enforcement actions beginning XX/XX/XXXX. First Horizon collected international assessment fees on XXXX and XXXX XXXX-routed charges, confirming its own systems identified the international nature of these transactions. First Horizon has not responded to Complainants ' formal XXXX chargeback demand dated XX/XX/XXXX. FOUR MERCHANT DESCRIPTORS DOCUMENTED FROM STATEMENTS Complainants ' First Horizon Bank account statements for Account No. XXXX confirm that XXXX XXXX XXXX XXXX XXXX XXXX routed charges under four distinct merchant descriptors across three international jurisdictions : 'XXXX XXXX XXXX XXXX ' Domestic routing through a Colorado payment processor address. This descriptor appeared most frequently throughout the transaction period and obscured the true international nature of the merchant. 'XXXX XXXX XXXX XXXX XXXX ' Direct XXXX entity charges routed through XXXX XXXX . These transactions triggered 'DEBIT CARD INTL ASSESSMENT FEE DEBIT ' charges by First Horizon , confirming First Horizon 's own systems identified them as international transactions. XXXX XXXX XXXX XXXX XXXX ' XXXX entity charges appearing with a phone number descriptor rather than an address, representing a third variation of the same XXXX-entity routing. 'XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX routing appearing on XXXX XXXX XXXX confirming the same merchant also routed transactions through XXXX XXXX in addition to Colorado, the XXXX, and via phone number descriptors. The use of four distinct merchant descriptors across three international jurisdictions Colorado, XXXX XXXX, and XXXX XXXX for the same underlying illegal operator on a single consumer account is a documented example of transaction laundering under XXXXXXXX XXXX merchant rules, which require accurate merchant identification on all transaction records. A functioning UIGEA compliance program monitoring for restricted gambling transactions should have identified this multi-descriptor, multi-jurisdiction pattern and triggered a SAR review. INTERNATIONAL ASSESSMENT FEES COMPOUNDED COMPLIANCE FAILURE First Horizon Bank assessed 'DEBIT CARD INTL ASSESSMENT FEE DEBIT ' charges throughout the transaction period on XXXX-routed and XXXX XXXX-routed XXXX XXXX XXXX charges. These fees confirm that First Horizon Bank 's own transaction processing systems correctly identified certain XXXX XXXX charges as international transactions from foreign entities while simultaneously its UIGEA compliance program failed to flag those same transactions as potentially restricted gambling charges. The total international assessment fees charged in connection with XXXX XXXX XXXX transactions are demanded as independent restitution from First Horizon Bank, separate from the Visa chargeback demand.DOCUMENTED SERVICE TERMINATION DATE XX/XX/XXXX ( Exhibits B, C, D ) : Complainants possess three screenshots from the XXXX XXXX platform at lavishluck.net confirming permanent service discontinuation for Tennessee residents effective XX/XX/XXXX per XXXX XXXX XXXX own in-platform notice stating 'XXXX XXXX, XXXX FINAL DEADLINE FOR ALL SWEEPSCOINS REDEMPTIONS FOR TENNESSEE RESIDENTS Access to our platforms and services will be permanently discontinued for Tennessee residents after this date. ' The 120-day chargeback window runs from XX/XX/XXXX to XX/XX/XXXX. Complainants ' original XXXX chargeback demand was submitted XX/XX/XXXX eleven days before services were permanently terminated. First Horizon Bank has no legitimate timeliness defense.

Company response to consumer: Closed with explanation