Consumer complaint received 2025-12-23 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Getting a credit card — Application denied
Company: Bread Financial Holdings, Inc.
State: TX

Complaint narrative:
b'Subject: Adverseaction notice noncompliance  Comenity Capital Bank (ECOA & FCRA violations)\nSummary: XXXX XXXX Comenity denied my XXXX XXXX XXXX  application citing only inability to verify your previous credit experience. The notice failed to state specific principal reasons under ECOA/Reg B and failed to provide lawful FCRA score disclosures (claimed score XXXX XXXX XXXX  despite stating the decision was based on a consumer report. I mailed a demand for corrected disclosures via certified mail (tracking XXXX delivered XXXXFacts & timeline: (list dates: application date if knownXXXX XXXX XXXX XXXX XXXX XXXX XXXX  delivery confirmation). Attach: denial letter, certifiedmail receipt, demand letter.\nLegal basis: ECOA (15 U.S.C. 1691 & Reg B 1002.9)  failure to provide specific principal reasons; FCRA (15 U.S.C. 1681m & Reg V)  defective score disclosure and factor disclosure\n\n[What happened]\nOn December 19, 2024 Comenity Capital Bank sent an adverseaction letter denying my XXXX  Visa Signature application. The letter stated only: Inability to verify your previous credit experience. It also included a purported credit score disclosure that said the score was not able to be calculated and listed a score range of XXXX XXXX XXXX XXXXhile simultaneously stating the decision was based on information in my consumer report.\n\nWhy this is a problem\n\nUnder the Equal Credit Opportunity Act and Regulation B a creditor must provide a written adverseaction notice that either (a) states the specific principal reason(s) for denial or (b) informs the applicant of the right to request those reasons; the notice must identify principal creditworthiness factors, not vague internal process failures. Comenitys single phrase is vague, nonspecific, and appears to describe an internal verification failure rather than a consumer creditworthiness factor.\n\nUnder the Fair Credit Reporting Act and Regulation V, when an adverse action is based in whole or in part on a consumer report the creditor must disclose the numerical credit score used (if any), the score range, the date of the score, the key factors affecting the score, the CRA name and contact information, and notice of the right to obtain a free report within 60 days. Comenitys XXXX XXXX XXXX XXXX  and was not able to be calculated statement are nonsensical and inconsistent with its statement that the decision was based on a consumer report. The listed most significant factors repeat the same vague phrase and do not identify score factors.\n\nSteps I took  \nI mailed a demand letter by certified mail requesting corrected disclosures and a compliant adverseaction notice. Certified mail tracking number XXXX XXXX XXXX XXXX XXXX XXXX4 shows delivery to Comenity Capital Bank in XXXX, OH on XXXX XXXX XXXX  I have attached the original denial letter, my demand letter, and USPS delivery confirmation.\n\nRequested action from CFPB  \nI request that the CFPB investigate whether Comenity Capital Bank violated ECOA/Regulation B and FCRA/Regulation V by issuing a deficient adverseaction notice and defective credit score disclosure, and require Comenity to provide the corrective disclosures and other relief listed below.'

Company response to consumer: Closed with explanation