Consumer complaint received 2025-11-17 00:00:00
Product: Debt collection — Other debt
Issue: Written notification about debt — Didn't receive notice of right to dispute
Company: UNITED SERVICES AUTOMOBILE ASSOCIATION
State: OH

Complaint narrative:
Un lawful act Opening a Closed account usaa XXXX XXXX XXXX XXXX ( XXXX XXXX XXXX ) to XXXX, XXXX, XXXX : XXXX USAA reopened a closed account of 9.5 years that was closed because of fraud. With the sole intention to deposit an Insurance claim check to pay a debt.

1. The CFPA emphasizes that even if the practice is disclosed in account agreements, consumers often can not prevent or control it, which supports a finding of unfairness.

2. CFPA Prohibition on Unfair acts or practices : 12 U.S.C, 5531 ( c ) 1. An act is considered Unfair because Consumers can not prevent it or control it. This is considered unfair practice. By the CFPA.

3. CFPA Guidance : a. Circular 2023-02-Unfair Acts or Practices.

b. 12 U.S.C. 5531, 5536. See generally Statement of Policy Regarding Prohibition on Abusive Acts or Practices c. 88 Fed. Reg. 21883 ( Apr. 12, 2023 ). This conduct may also violate other applicable laws, including state law.

d. The CFPA concluded that the institutions practice of reopening consumer accounts without obtaining consumers prior authorization and providing timely notice caused substantial injury to consumers that was not reasonably avoidable or outweighed by any countervailing benefit to consumers or to competition.

e. Moreover, even if the financial institution informs the consumer at the time that the account is closed that the institution may reopen the account, pursuant to the account agreement, the consumer will still generally lack the practical ability to control whether the account will be reopened and to avoid fees and other monetary harms.

f. For these reasons, government enforcers should consider whether a financial institution has violated the prohibition against unfair acts or practices in the CFPA if they discover that a financial institution has unilaterally reopened accounts that consumers previously closed.

g. Reopening a closed deposit account may also implicate the CFPAs prohibition on deceptive or abusive acts or practices. 12 U.S.C. 5531, 5536. See generally Statement of Policy Regarding Prohibition on Abusive Acts or Practices, 88 Fed. Reg. 21883 ( Apr. 12, 2023 ).

h. Unilaterally reopening a closed deposit account to process a debit or deposit may cause substantial injury to consumers.

i. 12 U.S.C. 5531 ( c ) ( 1 ) j. In Circular 2023-02 ( the Circular ), the CFPA concluded that if a financial institution unilaterally reopens a deposit account previously closed by a bank customer to process debits or deposits, this action could constitute an unfair practice under the Consumer Financial Protection Act ( CFPA ) K. The Consumer Financial Protection Act ( CFPA ) prohibits financial institutions from unilaterally reopening deposit accounts that have been closed by consumers. This practice is considered an unfair act or practice under the CFPA if it causes substantial injury to consumers that can not reasonably be avoided and is not outweighed by countervailing benefits to consumers or competition. Financial institutions are advised to review their account reopening policies and procedures to ensure they comply with the CFPA 's guidelines.

L. An injury is also not reasonably avoidable if the injury occurs without a consumer 's knowledge or consent, if the injury can not be anticipated, or even if anticipated, the consumer can not avoid it 4. You say your authority to reopen my closed account to post payment for a debt is your Depository Agreement. However the Laws of the Land see it otherwise. Your agreement is no good based on Federal Law and CFPA policy as mentioned in the body of this email, See # 1, # 2, # 3 ( a ) - ( l ) 5. I will open another case with the CFPA today because of new information and your letter to the CFPA that you referred to, so you can wrongfully take my Insurance Claim Check. This is in clear violation of several laws and policies of the Federal Law and also the CFPA policies and guidelines.

6. I request that you immediately reissue my check and deposit it in Acct # XXXXXXXX XXXX # XXXX. If not completed by XXXX XXXX  today I will send this email to XXXX along with a few other places. 

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