To appreciate the frustration of dealing with bureaucratic stupidity and incompetence you need to first read parts 1 and 2 to really appreciate how big business and specifically large financial institutions succeed in compromising consumers day in and day out. You will recall that this saga began on December 26, 2008 when I went to a Sears Roebuck or a "Sears" store to make some purchases.
I am going to insert the letter from the Comptroller of the Currency which was sent to me on June 10, 2009. Please remember that I first wrote to this agency in February, 2009. Please note when reading this letter how they liberally quote from the letter I received from Citibank,South Dakota, NA to justify their inaction and also their lack of understanding of the issue(s) I am bringing to the table. When reading this letter from the OCC I almost started to believe that they work for Citibank South Dakota, NA.
No one ever disputed the right of a business to retain internal records regarding its dealings with customers for as long it deems practicable. My issue here is twofold. The bank lied about the source of the information used to make its decision as is proven by the recording of the phone call I made to them (See Part 1). They claimed their source was Equifax and solely Equifax. Secondarily, I maintain that there is a serious issue of non disclosure here. If you read the bank's disclosure statement on the credit card application do you see any language that would tell you that the bank is relying on old customer records as much as 30 years old?
Most people including me are walking around thinking that when you apply for a credit card that your credit file is pulled from Equifax, TransUnion or Experian. Reports could come from one of them or all three. We now see that in some instances this is not the case, i.e, that other sources of information are relied on.
The other block buster that the bank is getting away with is their rather liberal use of the term "existing account" If I asked you to define the term existing account for me, what would you say? Please post an answer to this on this blog. As you know the bank has its own definition of "existing account" as you have already read.
Citibank, South Dakota, NA/Sears defines existing account as any account I have now or have had in the past even if it was 20 or 30 years ago and even if the account is closed, the debt has been sold or the debt was discharged in bankruptcy.
If you read this letter from the OCC they state that Sears understands my dissatisfaction regarding the declined application. Again the OCC never read the file carefully as far as I can discern. I did not ask Sears for a credit card. I was going to pay cash;they asked me to apply for one. Additionally I was given the credit card application(hard copy) after being induced to apply for the credit card.
My effort here is to somehow encourage those who make our laws on the state and federal level to force those who grant credit and impact the financial welfare of consumers to treat consumers with respect and dignity; not to confuse them or obfuscate an understanding of the true facts as illustrated I hope by the present case.
When there are too many credit inquiries on your credit report it can lower your FICO score. I believe people who apply for credit accounts, installment accounts or other types of loans have the right to know specifically what information a creditor is going to rely on. The term "other information" which Citibank South Dakota, NA employs is very insufficient in my humble opinion.
I am going to lobby my Congressional representatives and try to be instrumental so that the Fair Credit Reporting Act be amended specifically so that consumers understand that when they make credit applications they know exactly what facts and information about them are being used in when credit decisions are made.
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