Prepaid card -- Problem with a purchase or transfer -- Complaint #18331866

Complaint Overview

Complaint ID: 18331866

Company: Comerica

Product: Prepaid card

Sub-Product: Government benefit card

Issue: Problem with a purchase or transfer

Sub-Issue: Card company isn't resolving a dispute about a purchase or transfer

State: Texas

ZIP Code: 77385

Date Received: 2025-12-28T12:00:00-05:00

Date Sent to Company: 2025-12-28T12:00:00-05:00

Company Response: Closed with explanation

Timely Response: Yes

Consumer Disputed: N/A

Submitted Via: Web

Consumer Narrative

b'Subject: Error Resolution Request XXXX XXXX (Comerica Bank, Treasury Program)\n\nSummary of Issue:On XXXX XXXX XXXX XXXX at approximately XXXX XXXX XXXX I spoke with XXXX (employee ID 52495730), a supervisor at XXXX XXXX. I made a formal error resolution request under the Electronic Fund Transfer Act (15 U.S.C. 1693) and Regulation E (12 CFR Part 1005).\n\nI explained that debits had been posted to my XXXX XXXX account without corresponding credits, which is an accounting error. I requested ledger reconstruction and balancetransferonly correction to restore the missing credits.\n\nDetails of the Call:\n\nI verified my identity (name, SSN, DOB, card number ending in XXXX).\n\nI stated clearly this was not a refund request, not a dispute, and not a request for new funds.\n\nI explained that every debit requires a credit, and every credit requires a debit, consistent with GAAP principles.\n\nDuring the call, I pulled out an old billing statement and read specific entries to XXXX. For exampleXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX\n\nI explained that these transactions were valid purchases, but the error is that the credits were shown as XXXX. This proves the bookkeeping error: debits were posted without credits.\n\XXXX refused to document my request, refused to escalate, and stated there was no accounting team and no errors.\n\nHe insisted the card was just a prepaid debit card. I clarified that it is a Treasuryissued prepaid benefit card, subject to Regulation E and EFTA.\n\nHe offered only to send a billing statement, which does not resolve the error.\n\nI requested written confirmation (email) of my call, but he refused, despite other XXXX XXXX representatives having provided such verification in the past.\n\nHe confirmed the call was recorded.\n\nLegal Basis Electronic Fund Transfer Act (15 U.S.C. 1693) requires investigation and correction of errors.\n\nRegulation E (12 CFR Part 1005) applies to prepaid benefit cards, mandates error resolution procedures.\n\nCustomer Identification Program (31 CFR 1020.220) Comerica verified my identity before issuing the card, making me the account holder.\n\nGAAP Principles every debit must have a corresponding credit; failure to apply credits is a bookkeeping error.\nI request that this complaint be documented and investigated as an error resolution case. Specifically:\n\nLedger reconstruction to apply missing credits against debits.\n\nConfirmation that my request is recorded as balance-transfer-only ledger correction.\n\nEnforcement of my rights under EFTA and Regulation E, which I was denied.\n\nRequested Action: I request that this complaint be documented and investigated as an error resolution case. Specifically: Ledger reconstruction to apply missing credits against debits. Confirmation that my request is recorded as balancetransferonly ledger correction. Enforcement of my rights under EFTA and Regulation E, which I was denied. I told him that I would be making a complaint and that I also had a hearing on XXXX XXXX XXXX. I explained that this is about competency and that I am required to show I can handle my own private affairs, including all banking and accounting. I did not make the laws; I am required to follow them. This is an accounting issue, and I must ensure all these matters are taken care of by law and that I remain compliant.'

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