The Consumer Financial Protection Bureau filed a complaint against Comerica Bank on 6 December 2024, alleging that the Dallas-based institution engaged in unfair acts and practices in its administration of the Direct Express prepaid debit card programme. The programme, operated on behalf of the federal government, serves approximately 3.4 million cardholders who receive Social Security, Supplemental Security Income, and Veterans Affairs benefits — a population that is predominantly elderly or disabled and that frequently relies on the Direct Express card as its primary mechanism for accessing federal payments.

Comerica Bank is a Texas banking association and wholly owned subsidiary of Comerica Incorporated, headquartered in Dallas. The CFPB's complaint was filed in federal court and cited alleged violations of the Consumer Financial Protection Act of 2010 and the Electronic Fund Transfer Act alongside its implementing regulation, Regulation E. The Bureau characterised the alleged conduct as systematic rather than incidental, arguing that Comerica's failures collectively left millions of financially vulnerable consumers without adequate recourse when problems arose with their accounts.

FAILURES IN SERVICE, DISPUTES AND FRAUD PROTECTION

At the heart of the CFPB's case are allegations that Comerica failed to maintain the standards required of a banking partner serving some of the country's most financially marginalised households. The complaint focuses on three principal areas: customer service, the handling and resolution of disputed transactions, and the protection of cardholders from fraudulent charges. All three are obligations that arise directly under the consumer protection statutes cited by the Bureau, making the complaint broad-based rather than narrowly targeted at a single operational failure.

For cardholders who depend on the Direct Express debit card as their only means of accessing federal benefit payments, failures in any of these areas can translate quickly into serious financial hardship. An unresolved fraudulent charge or a dispute process that fails to function correctly may leave a pensioner or disabled veteran without access to funds they rely on for food, housing, and essential expenses. The CFPB has long identified this category of consumer — unbanked or underbanked individuals dependent on prepaid benefit cards — as a population warranting heightened regulatory protection.

DIRECT EXPRESS PROGRAMME AND REGULATORY CONTEXT

The Direct Express card was established by the US Department of the Treasury to deliver federal benefits electronically to recipients without conventional bank accounts. Comerica has served as the banking partner for the programme for an extended period, making its operational performance in administering the card a matter of direct relevance to the federal government's obligations to benefit recipients. The CFPB has statutory authority to supervise and bring enforcement actions against institutions that service or administer such programmes.

The Bureau's action against Comerica reflects its broader enforcement focus on institutions that manage government-linked payment infrastructure. The complaint does not specify a monetary relief figure in the publicly available materials, though enforcement actions of this type typically seek both restitution for affected consumers and civil money penalties proportionate to the scale of harm alleged. Comerica had not issued a substantive public response to the complaint at the time of filing on 6 December 2024. The case is formally titled CFPB Sues Comerica Bank for Systematically Failing Disabled and Older Americans.