Consumer complaint received 2026-03-18 00:00:00
Product: Checking or savings account — Checking account
Issue: Problem caused by your funds being low — Overdrafts and overdraft fees
Company: OFG BANCORP
State: PR

Complaint narrative:
I am submitting this follow-up complaint regarding the handling of my prior dispute against Oriental Bank concerning two electronic fund transfers totaling {$230.00} that I reported as unauthorized. In my original complaint, I explained that one transaction in the amount of {$34.00} occurred through an online merchant using what appears to be a misleading and extremely rapid one-click checkout mechanism that processed a charge without any meaningful confirmation step or opportunity to review the transaction details before completion. As a result, the charge was processed even though the transaction was not made with the intention of purchasing the product or service. Immediately after noticing the charge, I contacted the merchant by email requesting cancellation and explaining the accidental nature of the transaction. I subsequently provided the bank with copies of those email communications as evidence of my prompt attempt to resolve the matter with the merchant. Those communications were sent directly to XXXX XXXX ( on XX/XX/year> ) as part of the dispute process. Despite providing the only documentation available to me demonstrating that the transaction was unintended and that I acted promptly to address the issue with the merchant, the bank never acknowledged receipt of this evidence and nevertheless treated the transaction as valid. The second transaction, in the amount of {$200.00}, remains entirely unknown to me and was never authorized. I reported both transactions to the bank immediately and initiated a dispute under the error-resolution procedures established by Regulation E ( 12 C.F.R. 1005.11 ), which implements the consumer protections provided by the Electronic Fund Transfer Act ( 15 U.S.C. 1693 et seq. ). Appears that the bank treated both disputed transactions as a single consolidated amount rather than evaluating each transaction independently. Both transactions were resolved under the same determination and causal explanation, which raises concerns that the bank did not conduct a separate or individualized investigation for each amount. The bank initially credited the total combined amount and later reversed it in the same consolidated manner, without providing any documentation or evidence supporting how each transaction was evaluated. This approach suggests that the bank may not have performed a thorough investigation, particularly since I formally requested the documentation and evidence relied upon in the investigation and, to date, nothing has been provided to me. In its previous response to the complaint submitted to the CFPB, Oriental Bank asserted that the account qualified as a new account under Regulation E and therefore the bank was permitted additional time to investigate the dispute pursuant to 12 C.F.R. 1005.11 ( c ) ( 3 ). While the bank relied on this explanation regarding regulatory timelines, its subsequent conduct has raised additional concerns regarding its compliance with the procedural safeguards required during the investigation process. During the course of the dispute, the bank issued a provisional credit for the disputed transactions ; however, the bank later reversed that credit and allowed the account balance to become negative while the disputed charges remained posted. The reversal of the provisional credit occurred WITHOUT providing a CLEAR written EXPLANATION of the investigative FINDINGS or IDENTIFYING the factual basis or EVIDENCE relied upon to DETERMINE that the transactions were valid. This sequence of actions appears inconsistent with the banks prior representations regarding the status of the investigation and raises serious concerns regarding whether the investigation required under Regulation E was conducted in a reasonable, thorough, and transparent manner as required under the error-resolution provisions of 12 C.F.R. 1005.11. Additionally, after the provisional credit was reversed, I requested that the bank provide copies of the documentation and evidence relied upon in reaching its determination regarding the disputed electronic fund transfers. To date, the bank has not provided any documentation demonstrating that the transactions were authorized or otherwise valid, including authentication records, merchant verification, card-not-present, authorization data, or any investigative materials supporting its conclusion. The absence of such documentation is particularly concerning given that I had already provided the bank with evidence demonstrating that one of the transactions was unintended and that I had immediately attempted to cancel it with the merchant. Under the error-resolution provisions of Regulation E, when a financial institution determines that no error occurred, the institution must provide the consumer with an explanation of its findings and must provide copies of the documents relied upon in making that determination upon the consumers request ( 12 C.F.R. 1005.11 ( d ) ). Without access to the materials relied upon in the banks investigation, I have no way to understand how the bank concluded that the transactions were valid or whether the dispute was evaluated in accordance with the requirements of federal consumer protection law. Finally, the reversal of the provisional credit caused the account to become overdrawn while the legitimacy of the disputed transactions remained unresolved and while I was actively requesting clarification and documentation from the bank. As a result, I have experienced additional financial harm directly related to the banks handling of this dispute. I intentionally did not re-fund the account during the investigation process because I wanted to preserve the integrity of the dispute and avoid creating confusion about the source of funds or the status of the transactions while the banks review was pending. In fact, during one of my calls with the bank I clearly informed a representative that I would not deposit additional funds into the account until the investigation was completed. Now overdraft! These circumstances raise significant concerns regarding whether the bank conducted the reasonable investigation required under Regulation E ( 12 C.F.R. 1005.11 ) and whether the bank adequately considered the evidence provided by the consumer during the dispute process. Furthermore, the handling of this dispute raises concerns regarding potentially unfair practices in the administration of consumer account protections under federal law, particularly when a consumer has made a timely report of disputed transactions and has attempted in good faith to provide supporting evidence. Such practices may also implicate the prohibition against unfair, deceptive, or abusive acts or practices under the Dodd-Frank Wall Street Reform and Consumer Protection Act ( 12 U.S.C. 5531 ).

Company response to consumer: Closed with explanation