Apparently I'm good at pushing legit business boundaries too far as I keep getting blacklisted for permitted behavior as previously Chase blacklisted me for using their $500 offers too many times a few years ago and Fort Knox CU refuses to let me add an authorized user to my gas credit card.
Just got a letter (apparently an ECOA notice since it includes the required small print) from USAA stating that they are going to close my credit card account due to "unacceptable behavior or activity" and stated they will take next steps of:
Discontinue my bank access to usaa.com and banking services available through that site.
Deny applications for other USAA products and services.
This is annoying as I'd like to know what I did wrong so I can avoid repeating it in the future with another institution.
I called them up to ask, what exactly was the issue and they had nothing to offer other than "unacceptable behavior or activity" and a supervisor was even less helpful and wanted to get off the phone quickly. I asked how do I know the unacceptable behavior is not the church I attend or due to a bug in your computer systems? They had no useful response. They also had no response to whether this would impact my DW or children. They did say that my home, auto, renters, and umbrella insurance policies are not affected, although I expect my premiums will go up without the banking relationship in the future.
It is unclear to me from the letter whether they are closing my banking accounts. It appears to only say online access is to be removed. Letter is dated beginning of October, and I still have online access as of today and my checking/savings (joint with DW) are still open.
I also received two letters by overnight FedEx, dated a couple days later, and left on my doorstep with no signature taken that I found recently. These letters, one to me, one to my wife, stated:
In keeping with USAA' s core values and our commitment to our membership as a whole we are discontinuing your business relationship with the USAA Investment Management Company (IMCO).
Both the brokerage closing letter and the credit card letter are very vague as to what my sins are in their eyes, but I share this here in the hope that others way try be able to avoid a similar fate or may have other advice or suggestions.
My USAA membership was opened around 2010 shortly after I joined CreditBoards and my credit card was opened around 2016.
I've come up with a list of possible actions I've taken that could possibly be the source of their institutional displeasure, which I've tried to rank using my estimation from highest probability to lowest probability:
About 3 months ago I discovered that for my joint checking account I could ACH transfer in $5,000 per login per business day with no hold, so I could do $5K and my DW could do $5K on the same day and I did this about 4 times over the last 3 months to avoid having to do it over two days from just one login.
My checking account was my ACH hub, I transferred large amounts of money through USAA between USAA and other banking institutions, using ACH in and ACH out. Other than the transfers, I did not maintain a significant balance in this account. For example, I paid my rent each month by ACH and I used their ACH to create activity at other financial institutions that require ACH for a free account. My daily ACH limit in and out were each $8,000, but for no hold on transfer in, limit was $5,000 with excess amounts having a several day hold, however, it would also allow $5,025 per day with no hold, which I often exercised.
About 4 years ago, I used their CCT service they rebranded under the USAA name to bump inquiries from Equifax by pulling my credit report daily using automated web scripting. I know an officer in the military that feels wronged by me for enforcing a contractual relationship in a way they felt was unfair. Could this person have contacted USAA proactively to get them to blacklist me for this auto bump activity?
I only used my credit card for balance transfer offers, twice at 0% and never paid them any interest other than the transfer fee. I applied for CLI and got one up to $30K limit about 9 months ago. They even sent a new 0% balance transfer offer on this account about 45 days ago, which I did not utilize.
About two years ago, I had an ACH overdraft due to funds held uncleared at the bank it was drawn upon, but it did not pull overdraft from my credit card, so I covered the overdraft within about 5 days.
USAA complained that I had a low balance in my brokerage account about a year ago, so I raised the balance to $500 to meet their requirements for non-closure, I never had any trades in the account and maintained it to get additional discounts on my insurance. (This brokerage account is the subject of the overnight FedEx closure letters.)
I got an extended fraud alert added to my credit reports about 45 days ago. (Since their adverse action letter made no mention of a credit reporting agency, I imagine this could not be the case. I think I will make sure and get all three reports to see if they soft pulled my credit report and failed to divulge.)
My savings account was never really used and was maintained with a small balance.
Perhaps it is some combination of the above? Or if none of those seems likely, then could there be some kind of computer glitch I am the unfortunate victim of? Should I be concerned that USAA will be looking to non-renew my insurance policies now despite the CSR saying no impact to insurance?
Does it make sense to file complaints with:
For example, I could complain that the 1002.9 regulations require:
(2) Statement of specific reasons. The statement of reasons for adverse action required by paragraph (a)(2)(i) of this section must be specific and indicate the principal reason(s) for the adverse action. Statements that the adverse action was based on the creditor's internal standards or policies or that the applicant, joint applicant, or similar party failed to achieve a qualifying score on the creditor's credit scoring system are insufficient.
And the "Official interpretation of Paragraph 9(b)(2)" from the same link says:
2. Source of specific reasons. The specific reasons disclosed under §§ 1002.9(a)(2) and (b)(2) must relate to and accurately describe the factors actually considered or scored by a creditor.
3. Description of reasons. A creditor need not describe how or why a factor adversely affected an applicant. For example, the notice may say “length of residence” rather than “too short a period of residence.”
6. Judgmental system. If a creditor uses a judgmental system, the reasons for the denial or other adverse action must relate to those factors in the applicant's record actually reviewed by the person making the decision.
I'm not sure USAA has complied as 2) I do not feel like I got an accurate description of the factors actually considered by USAA when they say "unacceptable behavior or activity", but is that covered by 3) their not needing to describe how or why the factor affected me? Would their reasons be considered 6) a judgmental system, in which case, how do I know the adverse action related to factors in my record actually reviewed by the person making the decision?
What would be the basis for any complaints to CFPB or OCC? Any other thoughts or ideas?