Consumer complaint received 2026-06-08 00:00:00
Product: Vehicle loan or lease — Loan
Issue: Repossession — Lender trying to repossess or disable the vehicle
Company: FORD MOTOR CREDIT CO.
State: ID

Complaint narrative:
b"RE: CFPB Complaint Response to Ford XXXX for incomplete information provided to complaint number Case No. XXXX Ford Motor Credit Company | Account No. XXXX XXXX XXXX XXXX XXXX VIN: XXXX Related Prior Cases: XXXXXXXX and XXXX Dear CFPB Examiner: I am submitting this feedback regarding Ford Motor Credit Company's XXXX XXXX XXXX response to CFPB Complaint No. XXXX. Ford's response is non-responsive, contains provably false statements, and continues an unbroken pattern of boilerplate deflection across three CFPB complaints spanning more than four months. I respectfully urge the CFPB not to close this matter and to coordinate with the Idaho Attorney General (Matter No. XXXX and the Idaho Department of Finance, as this conduct implicates both federal and state law. I. PRIOR COMPLAINT \nPATTERN THREE COMPLAINTS, ZERO SUBSTANTIVE RESPONSES This is the third CFPB complaint on this account. Prior cases XXXX and XXXX were each closed after Ford submitted structurally identical form letters that failed to address the specific documented concerns. The CFPB's repeated closure of these complaints without substantive investigation has allowed the conduct to continue. I respectfully request this complaint be treated as an escalated pattern matter and reviewed on its merits. II. FORD'S FALSE AND MISLEADING STATEMENTS A. Repossession Fee Contradiction Ford's XXXX XXXX XXXX response states: 'the vehicle has not been repossessed, therefore no repossession fees have been applied.' Ford's XXXX XXXX XXXX response repeats this claim. Ford's own billing statements show a charge labeled 'Repossession Fee Payment: $XXXX.' This irreconcilable contradiction between Ford's regulatory representations and its own billing documents has never been explained across four regulatory responses. B. Fees 'Correctly Assessed' Then Silently Waived Ford previously certified all fees were 'correctly assessed in accordance with the terms of the Retail Installment Sale Contract.' Ford's XXXX XXXX response then waived XXXX XXXX XXXXees without explanation. A fee that was correctly assessed cannot be waived without explanation. This waiver is a tacit admission that those fees lacked justification and the same standard must apply to all similarly assessed fees throughout the account. C. Extension Forms Authentication Ford claims to have produced 'all signed extension forms.' The two forms dated XXXX XXXX XXXX and XXXX XXXX XXXX XXXXntain only a typed name and date no DocuSign Envelope ID, no Certificate of Completion, no IP address, no timestamp. Every other extension Ford produced has a complete electronic authentication record. These two forms do not meet the requirements of the federal ESIGN Act (15 U.S.C. 7001) or the Idaho Uniform Electronic Transactions Act (Idaho Code 28-50-101). D. XXXX XXXX Described as Voluntary Ford characterizes these payment methods as voluntary consumer choices. Ford's own records and my prior submissions document that Ford disabled my online account portal during delinquency periods. Forced third-party payment channels at XXXX per transaction are not voluntary. This constitutes an Unfair practice under 12 U.S.C. 5531(c). III. CRITICAL ISSUES FORD FAILED TO ADDRESS XXXX in excess interest above the 84-month contract baseline Ford's own SOA confirms this; Ford has never explained it XXXX principal reconciliation gap principal paid + charge-off balance exceeds original loan; never explained XXXX gap between fees assessed on monthly statements XXXX and fees acknowledged in Ford's XXXX XXXX Stacked fee assessments across 10 documented delinquency periods Ford assessed late fees multiple times per delinquency period, totaling XXXX in excess beyond one fee per period Non-standard fee amount of XXXX assessed XXXX XXXX XXXX with no description or contractual basis XXXX XXXXreturn events generating cascading fee responses the XXXX XXXX return alone triggered XXXX in fees on a single replacement payment IV. APPLICABLE VIOLATIONS 15 U.S.C. 1638 (TILA) Undisclosed finance charges from extensions and fee capitalization: XXXX in excess interest never disclosed at time of modification 12 U.S.C. 5531 (UDAAP) Deceptive: vague fee labels with no contractual basis; Unfair: portal lockout forcing costly alternatives; Abusive: fee stacking across delinquency periods 15 U.S.C. 1681s-2 (FCRA) Certifying accuracy of a disputed balance containing XXXX in justwaived fees, a contradicted repossession charge, and XXXX in unexplained interest Idaho Code 48-603 (Idaho CPA) Unfair and deceptive trade practices Idaho Code 28-45-106 (Idaho RISC Act) RISC modifications require written signed consumer agreement V. COMPLETE CORRECTED BALANCE CALCULATION Ford claims XXXX When all documented, provable overcharges from Ford's own records are applied: Credit Item Amount Ford's claimed balance (after XXXX waiver, XXXX XXXX XXXX) XXXX VI. STACKED FEE ASSESSMENT DETAIL 10 PERIODS Ford's contract permits one late charge per payment. The following table documents 10 delinquency periods in which Ford assessed late fees multiple times for a single delinquency, producing XXXX in excess fee assessments: Less: TILA Excess interest above original 84-month contract baseline (XXXX shows $XXXX collected; contract baseline = XXXX XXXX Less: Repossession fee appears on billing statements; denied in four consecutive Ford regulatory responses XXXXXXXX Less: Double-charged extension fee (XXXX XXXX bank return fee assessed on both original and replacement payment) XXXX Less: Forced third-party payment fees (portal access disabled; XXXX XXXX forced est. conservative minimum) XXXX Less: Unexplained principal gap principal paid + remaining balance exceeds original loan by XXXX XXXX unaccounted after fees XXXX Less: Stacked fee assessments fees assessed multiple times per delinquency period across 10 documented periods (detail below) XXXX Less: Non-standard unexplained fee amount XXXX XXXX; not a standard late charge amount, no description provided) XXXX ADJUSTED BALANCE FORD OWES CONSUMER RESTITUTION XXXX Period # Fees Total Assessed 1st (Contract) Excess Notes XXXX XXXX XXXX XXXX XXXX XXXX XXXX payment delinquent; 2 monthly late charges assessed XXXX XXXX XXXX XXXX XXXX XXXX XXXX payment delinquent; 2 monthly assessments XXXX XXXX XXXX XXXX XXXX XXXX 1 payment delinquent; 2 assessments XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX payment delinquent; 2 assessments XXXX XXXX XXXX XXXX XXXX XXXX XXXX 69-day delinquency; 3 monthly late charges stacked XXXX XXXX XXXX XXXX XXXX XXXX XXXX delinquency; 3 monthly late charges stacked XXXX XXXX XXXX XXXX XXXX XXXX 99-day delinquency; 3 late charges + XXXXXXXX collection fee (waived) XXXX XXXX XXXX XXXX XXXX XXXX 80-day delinquency; 3 monthly late charges stacked VII. ATTORNEY RETENTION NOTICE AND AGENCY COORDINATION REQUEST I have pursued resolution through the CFPB complaint process in good faith for over four months across three complaints. Ford has not provided a single substantive response. I am now prepared to retain legal counsel to pursue all available remedies under TILA (15 U.S.C. 1640), UDAAP (12 U.S.C. 5565), FCRA (15 U.S.C. 1681n), and the Idaho Consumer Protection Act. Under TILA's fee-shifting provision and Idaho Code 48-608(5), attorney fees are recoverable from Ford as the violating party. I respectfully request that the CFPB: (1) not close this complaint as resolved; (2) treat this as an escalated pattern matter; (3) coordinate with the Idaho Attorney General's Consumer Protection Division (Matter No. XXXX) and the Idaho Department of Finance; and (4) require Ford to produce a complete transaction-level accounting with fee justification for every charge in the account history. Respectfully submitted\n\n\n\nUpdated complaint addressing Fords response with omissions and also admissions. \n\n\nFORENSIC LOAN AUDIT REPORT\nFord Motor Credit Company LLC\nREVISED AND UPDATED XXXX XXXX XXXX XXXX XXXXPrepared by: XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX \nAccount No.: XXXX | VIN: XXXX | XXXX Ford XXXXContract Date: XXXX XXXX XXXX | Original Term: 84 months | Amount Financed: XXXX XXXX 5.69%\nFord Member No.: XXXX\n \nCFPB Case Nos.XXXX XXXX XXXX XXXX XXXX XXXX [NEW]\nIdaho Attorney General: Matter No. XXXX [NEW]\nIdaho Department of Finance: Formal Complaint Filed XXXX XXXX [NEW]\n \nOriginal Report Date: XXXX XXXX XXXX XXXX Revision Date: XXXX XXXX XXXX XXXX XXXXDISPUTED FOR REGULATORY AND LEGAL REVIEW\n \nKEY REVISION SUMMARY:\n Interest baseline corrected to exact figure: XXXX (previously estimated XXXX\n Excess interest corrected to exact figure: XXXX (previously estimated ~XXXX\n Extension count corrected: 7 extensions, 14 months added (previously 6 / 13 months)\n Extension documentation updated: Ford produced forms; 2 of 7 lack verifiable signatures; 5 of 7 lack TILA disclosure\n Bank return characterization corrected: R01/R02 coded returns are bank-side NSF/account closed not unilateral Ford reversals\n New Section 4A added: Stacked Fee Analysis 10 delinquency periods, XXXX excess\n New Section 4B added: Principal Reconciliation Gap $XXXX unexplained\n New Section 4C added: Ford XXXX Confirmation of All Audit Figures\n Balance calculation updated: Ford owes consumer $XXXX in restitution\n \n\x0c\nSECTION 1: PURPOSE AND SCOPE\nThis forensic audit report documents material servicing irregularities in Ford Motor Credit Account No. XXXX, based exclusively on Ford Motor Credit's own statements, transaction records, and the Statement of Account (XXXX) produced in response to CFPB Complaint No. XXXX in XXXX XXXX No external assumptions have been introduced. All conclusions are drawn from documentary evidence produced by Ford Motor Credit.\n \nThis revised report supersedes the XXXX XXXX XXXX original audit. Revisions incorporate Ford's XXXX XXXX XXXX, seven extension agreements produced by Ford, and the forensic analysis completed after receipt of those documents. All material corrections are identified in the revision summary on the cover page.\n \nThis report is submitted in support of three active CFPB complaints (XXXX XXXX XXXX XXXX, Idaho Attorney General Matter No. XXXX, and a formal complaint with the Idaho Department of Finance. It is also submitted as a predicate document supporting retention of legal counsel to pursue all available remedies under the Truth in Lending Act (15 U.S.C. 1638, 1640), the Consumer Financial Protection Act (12 U.S.C. 5531, 5565), the Fair Credit Reporting Act (15 U.S.C. 1681s-2), and the Idaho Consumer Protection Act (Idaho Code 48-603, 48-608).\n \nFord XXXX XXXX XXXX XXXX response produced a Statement of Account and seven extension forms. The XXXX confirms this audit's core payment figures in their entirety. The extension forms reveal that two of the seven cannot be authenticated under applicable electronic signature law. Ford's response also waived $XXXX in fees without explanation after previously certifying all fees were correctly assessed a tacit admission that those fees lacked contractual justification.\n \nSECTION 2: BASELINE LOAN PARAMETERS AND ACCOUNT PERFORMANCE\nThe following table compares the original contract terms against expected amortization and actual performance as confirmed by Ford's own Statement of Account produced in XXXX XXXX All 'Actual' figures are now drawn directly from Ford's SOA rather than estimates.\n \nParameter\nContract Terms\nExpected (Normal)\nActual (Ford XXXX Confirmed)\nAmount Financed\nXXXXnInterest Rate (APR)\n5.69%\n5.69%\n5.69%\nMonthly Payment\XXXX XXXXcontracted)\nOriginal Term\n84 months\n84 months (ending XXXX)\n98 months (ending XXXX\nExpected Total Interest\n\nXXXX (exact: XXXX confirmed per Ford XXXX\nExcess Interest\n\n\nXXXX above contract baseline\nTotal Payments Received\nXXXX (confirmed per Ford XXXX)\nTotal Principal Paid\n\nXXXX (per Ford XXXX)\nPrincipal Reconciliation Gap\n\n$XXXX (should balance)\nXXXX unexplained overage\nRemaining Balance at Term End\nXXXX XXXX XXXX XXXX XXXX XXXX waiver\n \nCRITICAL FINDING: After 9198 months of payments totaling XXXX XXXX more than the contracted total Ford Motor Credit claims a remaining balance of XXXX (after its own $XXXX fee waiver). The principal reconciliation gap of $XXXX documented in Section 4B cannot be explained under standard amortization and is consistent with undisclosed fee capitalization.\n \nSECTION 3: CHRONOLOGICAL STATEMENT ANALYSIS\nThe following table represents all available statements, deduplicated and ordered chronologically. The XXXX gap represents periods where Ford's account access lockout policies prevented statement retrieval. All figures have been cross-referenced against Ford's XXXX XXXX SOA.\n \nNOTE ON BANK RETURNS [REVISED]:\nThe original audit characterized five payment reversal events as potentially unilateral Ford actions. Ford's XXXX XXXX SOA codes these events as R01 (Insufficient Funds bank returned payment) and XXXX (Account Closed bank returned payment). These were bank-side returns, not Ford-initiated reversals. The legal significance is retained the cascading fee response to each return event was disproportionate and the resulting fee stacking remains a documented violation but the characterization is corrected here.\n \nStatement Date\nPayoff Amount\nFinal Pmt Date\nPrincipal Bal.\nTransactions / Key Data\nAudit FlagsXXXXNo transactions; Prev Due XXXXLate fees accruing; 2 months delinquent\XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXso assessed same cycle stackedXXXXTwo late fee assessments (XXXX XXXX\n Payoff INCREASED $XXXX after payment received\nXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXn Final pmt date pushed 2 months; $XXXX fee same XXXXLate fee only; Prev Due $XXXX\n Final pmt date pushed; no payment receivedXXXX XXXX XXXX Prev Due $XXXX\n Payoff INCREASED despite no charges beyond late fee\XXXXLate fee XXXX XXXX XXXX XXXX Misc $XXXX\n Final pmt date pushed again; $XXXX undisclosed fees\XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Payoff INCREASED from prior XXXXnFee Assessment $XXXX (no description; WAIVED XXXX XXXX); Late XXXX XXXX XXXXith ZERO description; final pmt pushed to XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX Late fee waived\n FIRST written TILA disclosure of extension consequences\nXXXXnNo transactions; Prev Due $XXXX\n4 months accrued unpaid prior to charge-off\n \n\x0c\nSECTION 4: FEE ANALYSIS UNDISCLOSED, STACKED, AND UNCONTRACTED FEES\n \nSection 4A: Stacked Fee Assessment Analysis [NEW]\nFord's retail installment contract permits one late charge per payment. Ford's own Statement of Account documents a systematic pattern of assessing late charges multiple times per delinquency period across 10 separate periods throughout the account life. The following table identifies each period, the number of fees assessed, the contractually permissible amount (one fee), and the excess.\n \nDelinquency Period\n# Fees\nTotal Assessed\n1st Fee (Contractual)\nExcess\nNotes\nXXXX XXXX fees, 1 delinquent payment\XXXX XXXX fees, 1 delinquent payment\nXXXX XXXX fees, 1 delinquent payment\nXXXX XXXX XXXX XXXX 1 delinquent payment\nDec XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXnLEGAL BASIS: Stacking fees beyond the contractual one-per-payment limit constitutes an Unfair practice under UDAAP (12 U.S.C. 5531(c)) imposing substantial financial injury through a fee structure that consumers could not reasonably anticipate or avoid. This pattern also constitutes a violation of the Idaho Consumer Protection Act (Idaho Code 48-603). The XXXX XXXX CFPB Supervisory Highlights specifically cited auto servicers for fee stacking as UDAAP violations.\n \nSection 4B: Principal Reconciliation Gap $XXXX [NEW]\nOn a standard simple interest installment contract, principal paid plus remaining balance must equal the original loan amount. Ford's own XXXX produces the following irreconcilable result:\n \nItem\nAmount\nOriginal loan amount\nXXXXnPrincipal paid per Ford XXXX\n$XXXX\nRemaining balance at charge-off\n+ $XXXX\nTotal (should equal original loan)\n$XXXX\nUNEXPLAINED GAP\n$XXXX\nExplained by fees in payment columns\n$XXXX\nREMAINING UNEXPLAINED (likely fee capitalization)\n$XXXX\n \nThe $XXXX that remains unexplained after accounting for fees applied within payments is consistent with undisclosed fee capitalization fees being added to the outstanding principal balance, upon which interest then accrues. This constitutes an undisclosed finance charge under TILA (15 U.S.C. 1638) that was never disclosed to the consumer at the time it was generated.\n \nSection 4C: Ford XXXX Confirmation of Audit Figures [NEW]\nFord's XXXX XXXX Statement of Account confirms every material figure in this forensic audit. The following comparison demonstrates that this audit's findings are not disputed calculations they are derived directly from Ford's own records:\n \nCategory\nThis Audit\nFord XXXX Confirmation\nTotal Payments Made\nXXXX XXXXApplied to Principal\nXXXX XXXXnApplied to Interest\nXXXX XXXXnFees Applied in Payments\nXXXX \nContract Expected Interest (84 mo.)\n$XXXXCalculated from XXXX XXXX \nExcess Interest\nXXXX\nSOA confirms: XXXX XXXX XXXX XXXX \n \nSection 4D: Undisclosed and Non-Transparent Fee Registry\nThe following fees were assessed across Ford Motor Credit's own statements with no description of the service rendered, no triggering event disclosed, and/or no verifiable contractual authority. Each entry has been extracted from Ford's statement and XXXX records. This table has been updated to reflect Ford's XXXX XXXX waivers and the extension form authentication findings.\n \nStatement Date\nFee Label\nAmount\nDisclosure\nAudit Finding\nXXXXnCollection Fee\n$XXXX\nNone\nWAIVED XXXX XXXX Ford tacitly admitted no contractual basis\nXXXXCollection Fee\n$XXXX\nNone\nWAIVED XXXX XXXX same admission applies\nXXXXnFee Assessment\n$XXXX\nNone\nWAIVED XXXX XXXX labeled 'Fee Assessment,' zero identification; same admission applies\nXXXXnMiscellaneous\n$XXXX\nNone\nSame billing cycle as Extension Fee; no description, no triggering event; NOT waived\nXXXXnMiscellaneous\n$XXXX\nNone\nSecond consecutive $XXXX Misc charge; no description; NOT waived\n1XXXXFee Assessment\n$XXXX\nNone\nNon-standard amount not a standard late charge; no description; no contractual basis identified\nXXXXnExtension Fee\n$XXXX\nNone\nExtension 2 typed-name form only; authentication disputed under ESIGN/UETA\nXXXXExtension Fee\n$XXXX\nPartial\nExtension 3 DocuSign authenticated but no TILA disclosure of finance charge impact\XXXXnExtension Fee\n$XXXX\nPartial\nExtension 4 DocuSign authenticated but no TILA disclosure\nXXXXnExtension Fee\n$XXXX\nPartial\nExtension 5 DocuSign authenticated but no TILA disclosure\nXXXX\nExtension Fee\n$XXXX\nPartial\nExtension 6 DocuSign authenticated but no TILA disclosure\nXXXXExtension Fee\n$XXXX\nFULL\nExtension 7 DocuSign authenticated; FIRST extension with TILA cost disclosure\n \nNOTE ON FORD'S $XXXX WAIVER: Ford's XXXX XXXX XXXX response waived three fees totaling $XXXX without explanation, after previously certifying all fees were 'correctly assessed.' An unexplained waiver of fees previously certified as correct is a tacit admission that those fees lacked contractual justification. The same standard Ford implicitly applied to those three fees must be applied to all similarly assessed charges in this table.\n \n\x0c\nSECTION 5: PAYOFF ANOMALY ANALYSIS BALANCE INCREASES AFTER PAYMENTS\nUnder standard amortization at 5.69% APR, each payment reduces the payoff balance. The anomalies below document months where Ford Motor Credit's own stated payoff amount increased despite no disclosed charge sufficient to explain the increase. These increases are consistent with the undisclosed fee capitalization pattern identified in Section 4B.\n \nStatement Date\nStated Payoff\nPayment Received\nMoM Change\nAnalysis\nXXXXNone\n\nBaseline delinquent, fees accruing\XXXX\nNormal payment applied\XXXX ANOMALY payoff INCREASED after prior payment; 2 late fees same cycle\nXXXXnBelow-expected reduction; $XXXX Collection Fee same period\nXXXX\n\nLate fee only month; term extended\nXXXXn ANOMALY payoff INCREASED with only a late feeXXXX in Extension + Misc fees added\nXXXX ANOMALY payoff INCREASED month-over-month\nXXXX Fee Assessment; no description\XXXX XXXXn ANOMALY payoff INCREASED despite extension processed\nXXXXnFinal pre-charge-off statement; 4 months accrued unpaid\n \nFour months in which the stated payoff increased following payments represent unexplained balance growth totaling $XXXX. Ford has not explained any of these anomalies across four regulatory responses.\n \nSECTION 6: TERM EXTENSION TIMELINE UPDATED WITH FORD-PRODUCED DOCUMENTS\nFord's XXXX XXXX regulatory response produced seven extension agreements. This section has been substantially revised to reflect the actual dates, authentication status, and TILA disclosure status of each extension form as produced by Ford. The original audit's statement that Ford 'produced zero signed extension agreements' is superseded by this updated analysis.\n \nEvent\nDate\nNext Pmt Date\nMonths Added\nPayments Deferred\nDocumentation Status\nContract Signed\XXXXOriginal 84-month term\nN/A original contract\nExpected Maturity\nXXXX\nBaseline end date under original contract\n\nExtension XXXX (next pmt)\n+2 months\nXXXX and XXXX deferred\n TYPED NAME ONLY NO DOCUSIGN No IP address, no timestamp, no Certificate of Completion\nExtension XXXX (next pmt)\n+3 months\XXXX XXXX XXXX deferred\n TYPED NAME ONLY NO DOCUSIGN Not authenticated under ESIGN Act or Idaho UETA XXXXXXXX\nExtension XXXX next pmt\n+2 months\nXXXX XXXXnd XXXX deferred\n DocuSign authenticated Envelope: XXXX... | Signed XXXX XXXX XXXXnExtension XXXX XXXXext pmt\n+2 months\XXXX XXXX XXXX deferred\n DocuSign authenticated Envelope: XXXX... | Signed XXXX XXXX XXXXxtension XXXX XXXXext pmt\n+2 months\nXXXX XXXX XXXX deferred\n DocuSign authenticated EnvelopXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXXext pmt\n+1 month\nXXXX deferred\n DocuSign authenticated EnvelopeXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX next pmt\n+2 months\nXXXX XXXX XXXX XXXXferred\n DocuSign authenticated Envelope: XXXXXXXX | Signed XXXX XXXX XXXX XXXX XXXX WITH FULL TILA DISCLOSURE\nCharge-Off\n11/25/XXXX\n\n\nAccount charged off $XXXX\n\nTOTAL EXTENSION\n\n\n14 MONTHS (XXXX months)\nLoan ran 14 months beyond original contract\n5 of 7 extensions lack required TILA disclosure 2 of 7 lack verifiable signatures\n \nCRITICAL FINDING TILA WILLFULNESS: Extension 7 (XXXX XXXX) contains the full TILA-required disclosure language regarding the cost consequences of extension. Extensions 1 through 6 do not. Ford possessed the correct disclosure template and chose not to use it for six consecutive extensions spanning XXXX through XXXX. This is not a compliance oversight it is evidence of knowing conduct. Under 12 U.S.C. 5565(c)(2), knowing UDAAP violations are subject to civil money penalties of up to $XXXX per day.\n \nCRITICAL FINDING ESIGN/UETA DEFICIENCY: Extensions 1 (October 2018) and 2 (July 2019) bear only a typed consumer name and date. They contain no DocuSign Envelope ID, no Certificate of Completion, no IP address, no timestamp, and no electronic authentication record. Under the federal ESIGN Act (15 U.S.C. 7001) and the Idaho Uniform Electronic Transactions Act (Idaho Code 28-50-101), an electronic signature requires an electronic process executed with intent to sign. A pre-populated typed name is not an electronic signature. Every other extension form Ford produced contains a complete DocuSign authentication record making the absence on these two forms a documented inconsistency.\n \n\x0c\nSECTION 7: ACCOUNT ACCESS LOCKOUT AND PAYMENT OBSTRUCTION\nFord Motor Credit repeatedly disabled online account access during periods of delinquency precisely when borrower oversight, payment management, and account monitoring are most critical. The consequences were direct and measurable:\n \n Online statement download: unavailable during lockout periods\n Transaction history access: unavailable during lockout periods\n Standard online payment: unavailable during lockout periods\n Payment allocation review: unavailable during lockout periods\n Dispute or communication portal: unavailable during lockout periods\n \nPayments were redirected to XXXX XXXX or XXXX, with third-party fees of XXXX per transaction assessed to the borrower. Over the life of the account, this represents a conservatively estimated $400$800 in additional undisclosed cost burden.\n \nFord's XXXX XXXX XXXX response continues to characterize WXXXX XXXX and XXXX as 'voluntary' consumer choices. This representation is false. When Ford disables the standard payment portal during delinquency periods, third-party payment channels are not voluntary they are the only available option. This conduct constitutes an Unfair practice under 12 U.S.C. 5531(c): it causes substantial financial injury that the consumer cannot reasonably avoid.\n \nThe CFPB's XXXX XXXX Supervisory Highlights specifically identified auto servicers for payment obstruction practices as UDAAP violations issued while this account's complaints were active in the CFPB system.\n \nSECTION 8: UDAAP ALIGNMENT ANALYSIS UPDATED\nUnder the Consumer Financial Protection Act (12 U.S.C. 5531), an act or practice is Unfair if it causes substantial injury that consumers cannot reasonably avoid; Deceptive if it misleads or omits material information; Abusive if it interferes with a consumer's ability to understand or manage their account. The following matrix maps documented conduct to each category. This table has been updated to reflect findings from Ford's XXXX XXXX XXXX and extension forms.\n \nCategory\nConduct Documented\nUDAAP Basis\nRisk\nUNFAIR\nPayment portal lockouts forcing third-party payments (XXXX)\nSubstantial injury not reasonably avoidable; cost burden imposed unilaterally\nHIGH\nUNFAIR\nStacked fee assessments multiple fees per delinquency period across 10 documented periods ($XXXX excess)\nDisproportionate principal starvation; materially increased total cost of credit\nHIGH\nUNFAIR\nExtensions 1 and 2 lack verifiable consumer signatures; processed without authenticated authorization\nBorrower could not reasonably avoid resulting term extension and fee accumulation\nHIGH\nDECEPTIVE\n$XXXX fees labeled 'Miscellaneous,' 'Collection Fee,' or 'Fee Assessment' with no description or contractual basis\nMaterial information omitted; consumer cannot verify, challenge, or budget for fees\nHIGH\nDECEPTIVE\nTILA cost disclosure appeared first in Extension 7 (XXXX XXXX absent from Extensions 16 spanning XXXX\nPrior extensions imposed without required cost/consequence disclosures; Ford possessed correct template throughout\nHIGH\nDECEPTIVE\nFord's XXXX XXXX regulatory response stated no repossession fees were assessed; billing statements show $XXXX Repossession Fee\nInternal contradiction between regulatory statement and billing records; one is false\nHIGH\nDECEPTIVE\nPayoff amount increased in 4 documented months after payments received\nMisleads borrower about actual balance trajectory; obscures true cost of credit\nMEDIUM\nABUSIVE\nAccount access lockout during delinquency periods preventing payment, monitoring, and dispute\nDirectly interfered with borrower's ability to manage, monitor, and pay account\nHIGH\nABUSIVE\nComplete transaction-level records withheld across multiple regulatory requests; no ledger produced until XXXX XXXX response\nCreates informational asymmetry; prevents consumer from independently verifying account\nHIGH\n \nThe CFPB has taken enforcement action against auto servicers for substantially similar conduct, including actions against XXXX XXXX (XXXX XXXX), XXXX XXXX, and XXXX. The XXXX XXXX CFPB Supervisory Highlights specifically flagged auto servicers for misallocated payment application and fee stacking issued while this account's complaints were pending. The pattern here is not isolated error. It is a recognizable and documented servicing failure profile.\n \n\x0c\nSECTION 9: EVIDENTIARY GAPS AND RECORD CONTROL UPDATED\nFord's XXXX XXXX response partially addressed prior evidentiary demands. The following records the current status of each previously demanded item:\n \nItem Demanded\nStatus\nCurrent Position\nComplete transaction-level ledger from origination to charge-off\nPARTIALLY PRODUCED\nFord produced a Statement of Account in XXXX XXXX this confirms payment figures but does not provide fee justification, allocation methodology, or explanation of the $XXXX principal gap\nSigned authorization for every deferral and extension\nPARTIALLY PRODUCED\nFord produced 7 forms. Extensions 1 and 2 XXXX) lack verifiable electronic signatures under ESIGN Act and Idaho UETA. Extensions 37 are DocuSign authenticated.\nWritten TILA disclo"

Company response to consumer: Closed with explanation