Consumer complaint received 2025-11-27 00:00:00
Product: Credit card — General-purpose credit card or charge card
Issue: Problem when making payments — Problem during payment process
Company: BANK OF AMERICA, NATIONAL ASSOCIATION
State: AL

Complaint narrative:
Bank of America Improper Minimum Payment Increase, Inadequate Disclosure, Improper Delinquency Reporting, and Resulting Consumer Harm Subject : Sudden increase in minimum payments without clear disclosure, improper 30-day delinquency reporting, and credit limit decrease. 
Summary of the Issue Bank of America increased my minimum payment by more than 300 % between XXXX and XX/XX/year> without clear or conspicuous disclosure in my statements. This change caused an artificial delinquency despite the fact that I was paying more than the previously required minimum. Bank of America then reported me 30 days late, which damaged my credit and contributed to further adverse actions from other lenders. The bank also reduced my credit limit without issuing a proper ECOA adverse action notice. 

The sudden change in minimum payment requirements violates Regulation Z ( 12 CFR 1026 ) and the CARD Acts 45-day advance notice provisions for changes in repayment terms. The resulting delinquency and limit decrease constitute FCRA and ECOA compliance failures, as well as an unfair practice under UDAAP.

Detailed Timeline and Evidence XXXX. XX/XX/year> Minimum payment was ~ {$50.00} and I was paying above the minimum From my XXXX XXXX XXXX XXXX statement : Total Minimum Payment Due : {$50.00} XXXX During this period, I consistently paid {$100.00} per month, which was more than double the required minimum. 

I had no delinquencies and was in good standing. 

XXXX. XX/XX/year>XXXX  Minimum payment suddenly increased from {$50.00} {$150.00} My XXXX XXXX XXXX XXXX statement shows : Total Minimum Payment Due : {$150.00} XXXX This is a 300 % + increase, and the statement contains no explanation for the drastic change. 
There is no label, no warning, no line item, and no calculation explanation indicating the new formula. 

I again made a payment of {$100.00}, which previously exceeded the minimum. 

XXXX. XXXX & XX/XX/year>XXXX  Minimum payment increases again My payment history ( from my XXXX  report ) shows : XXXX minimum : {$180.00} XXXX minimum : {$190.00} These increases were not disclosed in the statements either. 

XXXX. XX/XX/year> Bank of America reports me 30 days late Despite consistently paying {$100.00} ( which met the previous required minimum ) : Bank of America reported : Past Due : {$230.00} Rating : 30 ( 30-day delinquency ) ( Shown on my XXXX  report ) This delinquency arose solely because my minimum payment changed unexpectedly, not because I failed to pay. 

5. The change originated from an XX/XX/year>XXXX  legal notice but it does NOT meet the CARD Act standard for disclosure Bank of America sent me a dense legal notice in XX/XX/year>. While it mentions changes to the minimum payment formula, it : Does not specify my new minimum payment Does not provide a clear example of how the change would affect me personally Does not warn that my minimum payment could triple Does not appear on my XXXX statement Does not meet the clear and conspicuous standard required by the CARD Act Furthermore, the revised minimum took effect on the XXXX XXXX XXXX  billing cycle, but no 45-day advance notice was displayed on the XXXX statement. 

XXXX. XX/XX/year>XXXX  Bank of America lowers my credit limit following the disputed delinquency My XXXX XXXX XXXX XXXX statement shows : Total Credit Line reduced to : {$5300.00} ( from {$7000.00} ) XXXX Bank of America did not send me an ECOA adverse action notice regarding the credit limit decrease. This is required by federal law when an account is adversely affected based on credit behavior or perceived risk. 

Compliance Issues A. Violation of the CARD Act Failure to Provide 45-Day Notice for Changes in Required Minimum Payments 12 CFR 1026.9 ( c ) ( 2 ) requires creditors to provide 45-day advance written notice before : Increasing the minimum payment Changing the formula for minimum payment Changing terms affecting repayment obligations The statements do not show clear, conspicuous notices. 
The XXXX legal notice does not meet the clarity requirement and was not accompanied by specific impact disclosures. 

B. Violation of FCRA Inaccurate Reporting Bank of America reported me 30 days late even though : I was still paying above the previous minimum The delinquency was caused by an undisclosed formula change I had no history of late payments prior to the XXXX jump This makes the late payment inaccurate and misleading under FCRA 1681s-2. 

C. Violation of ECOA Failure to Issue Adverse Action Notice When Bank of America reduced my credit limit following the disputed delinquency, no adverse action notice was provided.

Credit limit decreases based on credit behavior require written notification under : ECOA ( 15 U.S.C. 1691 ) Regulation B ( 12 CFR 1002.9 ) I did not receive such notice.

D. UDAAP Unfair Harmful Practice The sudden increase in required payment : Was not clearly disclosed Caused an artificial delinquency Resulted in a credit limit decrease Damaged my credit score Triggered cascading adverse decisions from other creditors This constitutes unfair harm and a deceptive practice under CFPB authority.

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