Consumer complaint received 2025-11-26 00:00:00
Product: Checking or savings account — Checking account
Issue: Managing an account — Problem using a debit or ATM card
Company: NAVY FEDERAL CREDIT UNION
State: MD

Complaint narrative:
On XX/XX/XXXX, Navy Federal Credit Union ( NFCU ) placed a one-year restriction on my checking account that prohibits me from having or ordering a debit card until XX/XX/XXXX. This restriction prevents me from accessing my own funds in a normal and reasonable manner. I was not given any advance notice, documentation, or explanation before this action was taken. 

When I contacted Navy Federal through their secure message system, I specifically requested : The reason for the debit card restriction The findings or investigation used to justify it The internal policy or regulation Navy Federal is relying on A written adverse action explanation Instructions on how to appeal or remove the restriction Navy Federal refused to provide any of this information and responded only with a vague statement that my account does not meet Navy Federals underlying acceptance of risk for use of a debit card. They did not provide any specific details, any evidence, or any legally required notices. 

This situation raises multiple regulatory concerns : 1. Regulation E ( 12 CFR 1005 Electronic Fund Transfers ) Regulation E requires that consumers have clear access to their own funds via electronic means unless the financial institution has a documented, lawful reason to limit access. A debit card is an EFT access device regulated under this section. 

Navy Federal : Did not provide written notice before restricting my access Did not provide documentation or investigation results Did not give any valid Regulation E reason for denying access Imposed an extreme one-year restriction without due process This appears to be an unreasonable restriction on an EFT access device in violation of Regulation E. 

2. ECOA Adverse Action Requirements ( 12 CFR 1002.9 ) Restricting access to an account or denying a service normally provided on that account is considered an adverse action. 

Under ECOA, Navy Federal is required to : Provide a specific written reason for the action Provide a notice of rights Identify the decision maker Provide an explanation of the factors used Navy Federal did not provide any of these required disclosures. 
The phrase underlying acceptance of risk is not a legally sufficient ECOA adverse action reason. 

XXXX. UDAP/UDAAP ( 15 U.S.C. 45 Unfair or Deceptive Acts and Practices ) Blocking a consumer from accessing their own funds, for one full year, without : A valid reason Proper notice Investigation Documentation and then refusing to provide the required information when requested, may constitute an unfair practice, because : It causes substantial harm The consumer can not reasonably avoid the harm There is no stated countervailing benefit 4. NCUA Compliance ( Federal Credit Union Act and Fair Access Principles ) As a federally insured credit union, Navy Federal must : Provide fair access to member accounts Document any risk-based restriction Notify the member of the basis for the decision Navy Federal did not follow these requirements. 

5. Failure to Provide a Clear Appeal Process Navy Federal informed me that I could appeal, but did not provide : What information is required What documentation is needed Who reviews the appeal How long the review takes What standards are used This prevents me from exercising my rights as a consumer. Navy Federal imposed a severe and unjustified restriction on my checking account, refused to provide the legally required explanation and documentation, and prevented me from accessing my own funds via debit card. This appears to violate Regulation E, ECOA adverse action rules, NCUA access standards, and UDAP/UDAAP protections. 

I am requesting CFPB assistance in requiring Navy Federal to : 1. Provide the legally required written explanation and documentation.

2. Restore my debit card access and allow me to order a replacement card.

3. Ensure compliance with all applicable federal regulations in this matter.

Company public response: Company believes it acted appropriately as authorized by contract or law
Company response to consumer: Closed with non-monetary relief