Consumer complaint received 2025-08-09 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Closing your account — Company closed your account
Company: U.S. BANCORP
State: GA

Complaint narrative:
Elan Financial Services engaged in discriminatory and unlawful conduct in violation of the Equal Credit Opportunity Act ( ECOA ), 15 U.S.C. 16911691f, and the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 16811681x. Upon initiating a credit account with Elan, I was extended a credit limit substantially lower than what is standard for similarly situated individuals with comparable or worse credit profiles. After conducting my own inquiry, I confirmed that other

cardholders, some with demonstrably lower credit scores, higher utilization, and recent delinquencies, were extended materially higher credit limits. This disparate treatment, in conjunction with other factors, raises a clear inference of unlawful racial discrimination under ECOA.

Elan 's decision-making process appears to rely on non-objective, biased criteria that result in the systematic denial of equal credit opportunity on the basis of race. Such practices were r
ecently addressed by the CFPB and the courts, including in the Citibank Armenian surname case ( XXXX ), where the institution was fined for using surname profiling in its credit determinations. In that matter, the CFPB found that targeting applicants based on surnames constituted a violation of ECOA, even absent formal denial of credit.

Furthermore, Elan Financial Services unlawfully closed my account after I submitted an identity theft claim, without conducting a reasonable investigation as required under the FCRA and the Fair and Accurate Credit Transactions Act ( FACTA ). Under 15 U.S.C. 1681s-2 ( a ) ( b ), a furnisher of information to consumer reporting agencies must, upon receiving notice of a dispute from the consumer or a credit bureau , conduct a reasonable investigation and correct or delete any information found to be inaccurate or unverifiable. Elan failed to meet these obligations. 

The Second Circuit 's decision in XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX ) affirms that furnishers are required to undertake a substantive investigation into identity theft claims. Elans failure to do so, and its subsequent account closure without proper notice or findings, constitutes a breach of these statutory duties. Additionally, the CFPBs enforcement actions against XXXX  in XXXX demonstrate that failure to honor identity theft protections, including blocking disputed accounts, can result in federal penalties. 

In summary, Elan Financial Services : Violated ECOA by offering me inferior credit terms relative to similarly situated consumers, on a basis that suggests prohibited racial discrimination.

Violated the FCRA and FACTA by closing my account without a lawful investigation into my documented identity theft claim, failing to comply with its duties as a furnisher of information under federal law.

I request that the CFPB investigate Elan Financial Services for these violations, compel the company to disclose its credit determination criteria, and enforce appropriate corrective actions and sanctions for these unlawful practices.

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