Consumer complaint received 2025-12-27 00:00:00
Product: Credit card — Store credit card
Issue: Getting a credit card — Application denied
Company: Bread Financial Holdings, Inc.
State: NY

Complaint narrative:
This complaint concerns Comenity Banks unlawful denial of credit, improper reliance on an alternative consumer reporting agency ( XXXX / XXXX ), and failure to comply with federal credit decision, disclosure, and consumer protection laws. 
On or about XX/XX/XXXX, I received a written denial of my XXXX XXXX credit application stating the sole reason : Insufficient XXXX Risk Score. 
This denial constitutes multiple violations of federal law, including : Failure to provide a legally sufficient adverse action notice Improper use of alternative consumer reporting data without required disclosures Procedural discrimination under the Equal Credit Opportunity Act ( ECOA ) Violations of the Fair Credit Reporting Act ( FCRA ) Unfair, deceptive, and abusive acts under the Consumer Financial Protection Act ( UDAAP ) The denial caused measurable credit harm, including an inquiry, reputational injury, and loss of access to credit. 
II. FACTUAL BACKGROUND I applied for a XXXX XXXX retail credit account issued by Comenity Bank My application was denied The only reason provided was Insufficient XXXX Risk Score No meaningful explanation of factors was provided No description of how the score was calculated was disclosed No clear identification of the nature of the consumer report was provided No individualized underwriting analysis was evident The decision relied on alternative consumer data, not traditional credit metrics III. VIOLATIONS OF FEDERAL LAW 1. VIOLATION OF THE EQUAL CREDIT OPPORTUNITY ACT ( ECOA ) 15 U.S.C. 1691 ( d ) 12 CFR 1002.9 ( Regulation B Adverse Action Notices ) A creditor must provide specific, understandable reasons for denying credit.

Comenity Bank failed because : Insufficient XXXX Risk Score is not a specific reason It does not identify the actual factors leading to denial It prevents the consumer from correcting or disputing the basis of the decision It conceals the underwriting criteria used Case Law : XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) XXXXXXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) Courts consistently hold that generic, opaque reasons violate ECOA.

This constitutes procedural discrimination, which ECOA explicitly prohibits.

2. IMPROPER USE OF ALTERNATIVE CONSUMER REPORTING DATA 15 U.S.C. 1681 ( FCRA ) CFPB Guidance on Alternative Data XXXX / XXXX is a consumer reporting agency under FCRA.

Comenity Bank : Used alternative data to deny credit Failed to explain the nature of that data Failed to disclose how the score affected the decision Failed to provide meaningful dispute instructions This violates : 15 U.S.C. 1681m ( a ) disclosure requirements 15 U.S.C. 1681e ( b ) requirement to use reasonable procedures for accuracy CFPB has explicitly warned that reliance on opaque alternative data without transparency is unlawful.

3. FAIR CREDIT REPORTING ACT VIOLATIONS 15 U.S.C. 1681s-2 ( a ) & ( b ) Because the denial relied on consumer reporting data : Any inquiry or internal reporting tied to this denial must be accurate If the underwriting process itself was defective, the inquiry is unjustified The consumer must be given a meaningful opportunity to dispute the data Case Law : XXXX XXXX XXXXXXXX XXXX XXXXXXXX, XXXX XXXX XXXX ( XXXX XXXX. XXXX ) XXXX XXXX XXXX XXXX XXXX XXXXXXXX XXXX, XXXX XXXX XXXX ( XXXXXXXX XXXX  XXXX ) 4. UNFAIR, DECEPTIVE, AND ABUSIVE ACTS ( UDAAP ) 12 U.S.C. 55315536 Comenity Bank engaged in UDAAP by : Using an opaque risk score without explanation Denying credit without transparency Preventing meaningful consumer recourse Relying on undisclosed internal thresholds Causing unavoidable consumer harm This is precisely the conduct the CFPB is charged with stopping.

IV. HARM CAUSED As a direct result of these violations, I suffered : Damage to my credit profile Loss of access to credit A hard inquiry tied to an unlawful decision Financial and reputational harm Emotional distress and administrative burden These damages are foreseeable and compensable.

V. RELIEF REQUESTED I request that the CFPB require Comenity Bank to : Remove any inquiry or adverse reporting related to this denial Provide a corrected, legally compliant adverse action notice Disclose the specific factors used from XXXX Reevaluate my application using transparent, lawful underwriting Cease reliance on opaque alternative scoring without full disclosure Implement corrective compliance measures Provide restitution where authorized under 12 U.S.C. 5565 VI. CFPB DUTY TO ACT Under 12 U.S.C. 5531, 5536, and 5565, the CFPB is required to : Investigate Enforce Correct Penalize where appropriate Failure to act would undermine the Bureaus statutory mandate to prevent unfair and discriminatory credit practices.

VII. CONCLUSION Comenity Banks denial of my XXXX XXXX application was not lawful, not transparent, and not compliant with federal consumer credit law. 
This complaint is submitted for immediate regulatory review and enforcement.

Company response to consumer: Closed with explanation