Consumer complaint received 2025-04-26 00:00:00
Product: Payday loan, title loan, personal loan, or advance loan — Personal line of credit
Issue: Problem when making payments — 
Company: ENOVA INTERNATIONAL, INC.
State: FL

Complaint narrative:
Follow-Up Response to CFPB and Rebuttal to XXXX Response Submitted by : XXXX XXXX XXXX XXXX XX/XX/XXXX Complaint ID : [ insert CFPB Complaint ID here ] To Whom It May Concern, I am writing to submit my formal rebuttal to the response provided by NetCredit regarding my complaint. 

First, XXXX response fails to address the central issue of my complaint : the loan they issued violates Florida state usury laws and is therefore illegal and unenforceable under Florida law. 

Violation of Florida Law : True Lender Doctrine Applies Florida law strictly limits the interest rate on consumer loans to XXXX % for loans under {$500000.00} ( XXXX XXXX. XXXX, Florida XXXX XXXX ). NetCredit attempts to hide behind XXXXXXXX XXXX federal charter, claiming they are permitted to export interest rates from XXXX 

However, XXXX, like many states, applies the XXXX XXXX XXXX : if the nonbank ( NetCredit/Enova ) is the true lender meaning they bear the economic risk, control key terms, and receive the profit then Florida law applies. 

In this case, it is clear that : XXXX XXXX XXXX marketing, origination, servicing, and collection of the loan. 
NetCredit controlled the risk and profit. 
NetCredit dictated all major loan terms. 

The economic reality is that NetCredit, not XXXX Bank, was the true lender. Therefore, XXXX usury cap applies, not XXXX law, and this loan is illegal under Florida law. 

Florida courts have held that courts will look past form to substance when determining lender status. ( XXXX v. State, 616 So.2d 1228 ( XXXX XXXX XXXX XXXX ) ). 



NetCredit Has a Documented History of Regulatory Violations and Lawsuits This is not the first time NetCredit and its parent company, Enova International, have been caught engaging in illegal, deceptive, and predatory lending practices : 2021 Enova International ( NetCredits parent company ) was fined {$3.00} million by the Consumer Financial Protection Bureau ( CFPB ) for illegal debt collection practices, including withdrawing money from consumers accounts without authorization. ( Source : CFPB Enforcement Action, XXXX ) XXXX A major class action lawsuit ( XXXX XXXX XXXX ) alleged NetCredit violated state usury laws by partnering with Republic Bank to issue loans at unlawful rates while claiming exemption through federal law. 
XXXX The Illinois Department of Financial and Professional Regulation ( XXXX ) cited NetCredit for issuing consumer loans above the XXXX  % rate cap imposed under state law after the passage of the Predatory Loan Prevention Act. 
Multiple ongoing CFPB complaints allege the same pattern : Misrepresenting the true lender. 
Charging rates in violation of state law. 
Deceptively structuring loans to appear legal while evading state protections. 

It is clear that NetCredit has a long and repeated pattern of : Attempting to evade state lending laws. 
Misrepresenting loan structures. 
Engaging in deceptive and unfair practices to exploit consumers. 

Their behavior in my case fits this exact documented pattern. 



Predatory Practices and Bad Faith Conduct in My Case NetCredits response also confirms the following : I made a {$400.00} good faith payment toward resolving the account. 
Despite this, they accelerated the balance without properly crediting my account or honoring the payment arrangement. 
They ignored my attempts to resolve the matter, while simultaneously moving the account into default. 
They continued to charge unlawful fees even after acknowledging partial payments. 

This constitutes violations of : The Fair Debt Collection Practices Act ( FDCPA ), The Florida Deceptive and Unfair Trade Practices Act ( XXXX ), And Floridas strict consumer protection statutes. 



Relief Requested I am reiterating and expanding my demands : Immediate deletion of all references to this illegal account from all consumer reporting agencies ( Experian, Equifax, and TransUnion ).

Recall of any collection activity and full closure of the account.

Cease and desist from any further attempts to collect on this illegal loan.

Refund the {$400.00} payment I made.

Written acknowledgment that my balance is {$0.00} and no further payments are owed.

If these demands are not met, I will escalate this matter by : Filing a formal complaint with the XXXX Attorney Generals Office. 
Filing an additional complaint with the Federal Trade Commission ( FTC ). 
Engaging an attorney to pursue civil litigation for damages under Florida and federal law. 



Conclusion NetCredits response is wholly inadequate and ignores the substance of my complaint. Their actions in this case mirror a well-documented, repeated pattern of violating consumer protection laws. 

I respectfully request that the Consumer Financial Protection Bureau take serious enforcement action against NetCredit and XXXX XXXX consistent with their repeated violations of consumer lending laws across multiple jurisdictions. 

Sincerely, XXXX XXXX

Company response to consumer: Closed with explanation