Consumer complaint received 2025-12-01 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Installment loan
Issue: Charged fees or interest you didn't expect — 
Company: Denefits LLC
State: PA

Complaint narrative:
NOTICE OF REBUTTAL, ESCALATION, AND FORMAL DEMAND FOR REFUND From : XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX  To : Consumer Financial Protection Bureau XXXX CFPB ) Formal Complaint Filing CC : Denefits, XXXX XXXX XXXX XXXX XXXX XXXX XXXX ( Originator/Fiduciary ) Subject : FORMAL REBUTTAL TO RESPONSES AND ESCALATED COMPLAINT ALLEGING ABUSIVE ACTS OR PRACTICES ( UDAAP ) AND VIOLATION OF XXXX LAW ( Contract : XXXX XXXX To Whom It May Concern, This letter serves as a formal and final response to the defenses provided by both Denefits, XXXX XXXX XXXX XXXX XXXX regarding my financing agreement XXXX XXXX. I refute their claims and formally escalate this complaint based on statutory violations of consumer protection laws. 

I. The Predatory Nature of the Financing Agreement ( UDAAP Violation ) The central issue is the origination of the debt under terms that constitute an Abusive Act or Practice as prohibited by Section 1031 ( d ) ( 2 ) of the XXXX XXXX XXXX Reform and Consumer Protection Act ( 12 U.S.C. 5531 ), which is enforced by the CFPB. 

The terms of the contract ( XXXX ) forced a {$2500.00} legal fee into a high-cost debt structure, imposing a total premium exceeding {$970.00} ( a XXXX XXXX add-on ). This cost includes : Finance Charge ( Interest at XXXX XXXX Compound ) : {$710.00} Late Fees ( XXXX x {$25.00} ) : {$220.00} Enrollment Fee : {$30.00} Abusive Practice Allegation : An abusive act is defined as XXXX that " takes unreasonable advantage of a consumers lack of understanding of the material risks, costs, or conditions of the product or service '' ( 12 U.S.C. 5531 ( d ) ( 2 ) ( A ) ).

The high-cost nature of this financing, which adds nearly 40 % to the cost of a necessary legal defense fee, took unreasonable advantage of my vulnerable position during a time of immediate legal need.

II. Violation of Pennsylvania Consumer Protection Law The financing scheme violates the XXXX Unfair Trade Practices and Consumer Protection Law ( XXXX XXXX XXXX XXXX XXXX et seq., which prohibits " unfair or deceptive acts or practices. '' The steering of a client into a high-interest product with punitive fees by a fiduciary partner constitutes an unfair practice. The exorbitant finance charges and the complexity of the XXXX contractwhich includes multiple fees not covered by the primary interest ratesupport the claim that this transaction was structurally unfair and designed to profit from the necessity of legal defense. 

XXXX. Rebuttal to Denefits ' Defense of " Fraudulent Activity '' Denefits internal statement focuses entirely on my subsequent, desperate attempts to pay off the debt following my job loss ( communicated on XX/XX/XXXXXXXX  ), characterizing these actions as " fraudulent activity. '' Irrelevance to Origination : Post-contractual payment issues, even if disputed, do not retroactively validate the abusive terms of the contract at the time of origination. The core complaint is about the predatory cost structure, not the method of payment. 

Mitigating Circumstance : My multiple payment attempts using third-party cards were a result of financial duress due to job loss and an effort to extinguish a rapidly escalating high-interest debt. My intent was payment, not fraud. Denefits won the majority of the subsequent chargebacks, minimizing their claimed losses. 

Denefits Claim of " Even Outcome '' : Denefits admits to winning XXXX disputes while losing only XXXX primary payoff amount ( XXXX ). This admission undermines the claim of systemic loss or harm from my actions, demonstrating that they are using a secondary payment dispute to deflect from the primary violation of lending practice. 

IV. Rebuttal to XXXX XXXX Offices ' Defense ( Fiduciary Duty ) XXXX XXXX XXXX claim of being an " independent, third-party '' is rejected. As my legal counsel, the firm had a Fiduciary Duty and a Duty of Fair Dealing. By providing the Denefits contract as the primary or sole fee solution, the firm failed to protect my financial interests and actively steered me into a demonstrably abusive financial instrument. The firm is liable for the resulting harm under principles of agency and ethical standards governing the attorney-client relationship. 

V. Formal Demand for Refund and Escalation I hereby formally demand, for the final time, the full refund of all finance charges and fees as compensation for the alleged abusive and unfair lending practices : Total Demanded Refund : {$970.00} I expect the CFPB to open a formal investigation into the UDAAP violations detailed above. I also notify all parties that failure to issue this refund within XXXX ( XXXX ) business days will result in the immediate filing of formal complaints with the XXXX Office of the Attorney General and the XXXX Bar Associations Disciplinary Board against XXXX XXXX XXXX. 

Sincerely, XXXX XXXX ( Debtor/Complainant )

Company response to consumer: Closed with explanation