Harborstone Credit Union

Dear Ms [redacted] : We received a copy of your complaint from the Revdex.com [ID # [redacted] ] dated October 7th,2016, specifically identifying charges and overdraft fees assessed against your account prior to assignmentfor collection through Merchants Credit Association Our research identified that Harborstone Credit Union [HCU] opened your account in November, 2013and closed your account on May 26th, as the account remained overdrawn in the amount of($246.92)The last deposit made to the account was on April 17th, and the first transactionoverdrawing your account was on April 24th, 2015, with additional charges presented from LifeLock,Lookout Inc., and the USPS for post office box renewalEach transaction incurred overdraft fees, totaling$ HCU provided you with monthly statements and attempted to provide notice of your negative balance onMay 11th at days overdrawn, followed by a close-out negative balance notification on May 26th whenyou did not respond to our attempts to contact youSubsequently, your account was assigned toMerchants Credit Association [MCA] for collection purposes in accordance with the Overdraft Liabilityprovision contained within HCU's Membership & Account Agreement Although the issues you have identified are concerning, it is important to understand that HCU did notassess erroneous fees on the contractual debt owed created by the overdrawn balance; any collectionfees and/or interest assessed is by MCA in accordance with the state's licensed debt collection agency law(RCW) and the federal Fair Debt Collection Practices Act [FDCPA] (USC 1692), up to the maximumlawful interest rate codified within the Revised Code We work diligently to properly vet our business partners and hold them accountable for servicing, legaland regulatory complianceOur success is focused on serving our members, however, any negotiatedsettlement involving amounts in addition to the principal balance assigned is between you and MCAWehope this letter answers your concern and we would like to take this opportunity to thank you for theopportunity to respond Sincerely,Don M [redacted] Compliance OfficerHARBORSTONE CREDIT UNION

***Please see Attached***January 6, 2017 Harborstone "Credit Union [redacted] ***Dear [redacted] We received a copy of your complaint from the RevDex.com [ID # [redacted] ) dated December 28th, 2016, specifically identifying the late payments... Harborstone Credit Union [HCU] is reporting on your credit report.Our research identified that HCU originated your loan July 14th, 2013 in the amount of $21,588.28 with a contractual payment of $406.96 and secured by a 2013 Kia Soul, including seven reported late payments between July 5th, 2015 and January 5th, 2016.HCU has responded numerous times to your requests to change your loan's payment history. On June 27th, 2016 you wrote, "/ wish to ask for good will deletion of several late payments on my auto account. I do take full responsibility for all the late payments, but I would like for you to understand why I was late and possibly take some mercy upon me and help me out by removing them."Although the personal extenuating circumstances you identified are concerning, it is important to understand that HCU is subject to various duties under the Fair Credit Reporting Act [FCRA] and its implementing regulation, Regulation V (12 C.F.R. Part 1022) including the duty to provide accurate information. Explicitly identified in §623(a) a credit union that furnishes information to a credit reporting agency about a borrower must not provide information that it knows or has reasonable cause to believe that the information is inaccurate. The FCRA does allow consumers to add a statement to their files explaining personal financial situations, which must be done through the individual credit bureaus.Our mission and success are focused on serving our members by complying with all legal and regulatory requirements. However, there is no evidence that HCU is not accurately reporting the loan payment history. We hope this letter answers your concern and we would like to take this opportunity to thank you for the opportunity to respond.

Dear Ms***:We received a copy of your complaint from the Revdex.com (ID ***) dated April 28th, specifically identifying the dormant account fees assessed against your inactive savings accountFor background purposes, Prevail Credit Union merged with Harborstone Credit
Union effective January 1, As we researched your complaint, we found that you previously utilized online banking with Prevail Credit Union and we contacted to opt in to continue that service with Harborstone on June 3, We confirmed your email address and found that the account had been registered for e-Statements, which was the method used to notify you that statements were available for viewing.Under the Revised Code of Washington (RCW) financial institutions in Washington State are permitted to assess reasonable dormant/inactive account fees in compliance with the Uniform Unclaimed Property Act of 1983, Chapter RCWThe Code, however does stipulate that the business must 1) have an enforceable written contract; 2) notify the owner prior to assessing the inirial charge and 3) shall not routinely reverse dormant/inactive charges.Both Prevail Credit Union and Harborstone Credit Union had similar inactive and Abandoned Accoounts contractual agreements with their depositorsHarborstone Credit has complied with the requirements of RCW by taking the following actions: Your account initially became dormant/inactive under under the provision of paragraph one, item 17, section II of the Membership and Account Agreement Notice of dormancy/inactivity was placed on your December 31, statement Dormant account fees were assessed beginning January 31, until the account was closed out November 30, 2015Our mission and success are focused on serving our members and remaining compliant with all legal and regulatory requirementsAlthough we have faithfully performed our service our servicing requirements as establushed by our Membership & Accunt Agreement and wih a regulatory framework, we have enclosed a check in the amount of $114.14, which was your December 31, balance prior to any fees being assessed.Sincerely,Don M***

Dear Mr. [redacted]: We received a copy of your complaint from the Revdex.com {ID #[redacted]] dated December 16th, 2016, specifically identifying placement of Collateral Protection Insurance [CPI] coverage on your loan. Our research Identified that Harborstone Credit Union (HCU]...

originated your loan August 2nd, 2015 In the amount of $17,265.64 with a contractual payment of $312.30 and secured by a 2008 Dodge Avenger. The research identified inability to provide proof of insurance listing HCU as lienholder during the coverage period of August 2nd through November 5th, 2015, refusal to pay CPI insurance during the period of lapse coverage, a pattern of delinquency and failures to follow through on promise to pay commitments. Progressive [policy #[redacted]] was listed as the insurer at origination; however, the representative at Progressive stated the collateral was never added for coverage. State National sent notices requesting proof of coverage September 30th and October 28th, 2015. CPI was placed November 18th due to failure to provide proof of coverage and a Notice of Placement sent. Payments increased from $312.30 to $527.94 and a payment change notice was provided December 16th, 2015. HCU was informed December 17th, 2015, that coverage was now provided through USAA Casualty Insurance Co. {USAA), however, HCU was not listed as lienholder. A binder was eventually provided by USAA listing HCU as lienholder, payments lowered to $312.30, and a partial refund issued except for the period of lapse coverage August 2nd through November 5th, 2015. State National received a notice of coverage cancellation from USAA March 7th, 2016, and mailed notices requesting proof of insurance coverage March 30th and April 27th, 2016. CPI was placed May 20th due to failure to provide proof of coverage and a Notice of Placement sent with payments increased from $312.30 to $582.64. Messages were left for past due payments, requesting current proof of coverage, and stating a full CPI refund would be provided for the initial placement in November, 2015 with proof of coverage. The collateral was assigned for repossession at 80 days past due and a Notice of Plan to Sell Property was mailed November 4th, 2016 identifying your redemption rights, which no action was taken against. The collateral securing your loan was liquidated November 29th, 2016 with proceeds applied to your loan, and a subsequent Deficiency Notice in accordance with Uniform Commercial Code Article 9-607 identifying your contractual liability of $13,725.31 mailed December 7th, 2016.
We work diligently to properly vet our business partners and hold them accountable for servicing, legal and regulatory compliance. Our success Is focused on serving our members. We hope this letter answers your concern and we would like to take this opportunity to thank you for the opportunity to respond.
[redacted]SUPPORTING DOCUMENTS REDACTED BY Revdex.com[redacted]

September 18, 2017                                                                                ...

                Dear [redacted]:We received  a copy of your complaint from  the RevDex.com [ID #[redacted]]  dated September  11th, 2017, specifically identifying the change in APR based on your payment  history to your Harborstone Credit Union co-branded  VISA credit card.Harborstone Credit Union partners with  Elan Financial Services for  the  co-branding  of  credit cards  offered; they  are  responsible   for  issuing  the  governing   Cardholder   Agreement   and servicing.  As such, please direct your complaint to Elan Financial Services Cardmember Services, at 1-800-558-3424, or via mail at:Elan Financial ServicesConsumer Complaint Department200 South 6th Street EP.MN.L24A Minneapolis, MN 55402We  work  diligently   to  properly   vet  our  business  partners,  and  hold  them  accountable   for servicing, legal and regulatory compliance.   Our mission and success are focused on serving our members,  however,  HCU is unable to assist you further in this particular  situation.   We would like to take this opportunity to thank you for the opportunity to respond.Sincerely,Don M[redacted] Compliance OfficerHARBORSTONE CREDIT UNION

[redacted]Please see Attached[redacted]January 6, 2017 Harborstone  "Credit Union[redacted]Dear [redacted]We received a copy of your complaint from the Revdex.com [ID #[redacted]) dated December 28th, 2016, specifically identifying the late payments...

Harborstone Credit Union [HCU] is reporting on your credit  report.Our research identified that HCU originated your loan July 14th, 2013 in the amount of $21,588.28 with a contractual payment of $406.96 and secured by a 2013 Kia Soul, including seven reported late payments between July 5th, 2015 and January 5th, 2016.HCU has responded numerous times to your requests to change your loan's payment history. On June 27th, 2016 you wrote, "/ wish to ask for good will deletion of several late payments on my auto account. I do take full responsibility for all the late payments, but I would like for you to understand why I was late and possibly take some mercy upon me and help me out by removing them."Although the personal extenuating circumstances you  identified are concerning, it is important to understand that HCU is subject to various duties under the Fair Credit Reporting Act [FCRA] and its implementing regulation, Regulation V (12 C.F.R. Part 1022) including the duty to provide accurate information. Explicitly identified in §623(a) a credit union that furnishes information to a credit reporting agency about a borrower must not provide information that it knows or has reasonable cause to believe that the information  is inaccurate. The FCRA does allow consumers to add a statement to their files explaining personal financial  situations, which must be done through the individual credit  bureaus.Our mission and success are focused on serving our members by complying with all legal and regulatory requirements. However, there is no evidence that HCU is not accurately reporting the loan payment history. We hope this letter answers your concern and we would like to take this opportunity to thank you for the opportunity to respond.

Dear Ms. [redacted]:
We received a copy of your complaint from the Revdex.com [ID #[redacted]] dated October 7th,2016, specifically identifying charges and overdraft fees assessed against your account prior to assignmentfor collection through Merchants Credit Association.
Our research...

identified that Harborstone Credit Union [HCU] opened your account in November, 2013and closed your account on May 26th, 2015 as the account remained overdrawn in the amount of($246.92). The last deposit made to the account was on April 17th, 2015 and the first transactionoverdrawing your account was on April 24th, 2015, with additional charges presented from LifeLock,Lookout Inc., and the USPS for post office box renewal. Each transaction incurred overdraft fees, totaling$150.
HCU provided you with monthly statements and attempted to provide notice of your negative balance onMay 11th at 15 days overdrawn, followed by a close-out negative balance notification on May 26th whenyou did not respond to our attempts to contact you. Subsequently, your account was assigned toMerchants Credit Association [MCA] for collection purposes in accordance with the Overdraft Liabilityprovision contained within HCU's Membership & Account Agreement.
Although the issues you have identified are concerning, it is important to understand that HCU did notassess erroneous fees on the contractual debt owed created by the overdrawn balance; any collectionfees and/or interest assessed is by MCA in accordance with the state's licensed debt collection agency law(19.16 RCW) and the federal Fair Debt Collection Practices Act [FDCPA] (15 USC 1692), up to the maximumlawful interest rate codified within the Revised Code.
We work diligently to properly vet our business partners and hold them accountable for servicing, legaland regulatory compliance. Our success is focused on serving our members, however, any negotiatedsettlement involving amounts in addition to the principal balance assigned is between you and MCA. Wehope this letter answers your concern and we would like to take this opportunity to thank you for theopportunity to respond.
Sincerely,Don M[redacted]Compliance OfficerHARBORSTONE CREDIT UNION