I've been doing this back and forth dance with Google for a while, where I remove a credit freeze from Experian, wait a couple days and then apply for a payment plan through Google Fi for a new pixel phone. I am then denied with a message:
"There are special circumstances on your credit profile that do not permit us to access your credit information, and we are therefore unable to review your eligibility for the Pay Monthly Device Plan."
After talking to their support and Experian, it was determined this is most likely due to having a fraud alert on my account that I placed there after getting a breach notification from T-Mobile. However, as Experian stated and claims on their website and the FDIC has published guidance stating the same, denying credit due to having a fraud alert on your credit profile is illegal. It is a violation of the ECOA because having a fraud alert is a right under the CCPA. The steps that companies are supposed to take for people with a fraud alert, is to contact the phone number included with the fraud alert and verify the individuals identity. Ironically, Google actually includes the section of the ECOA that they are violating in the denial.
After two months and retrying the same steps, I finally got a Google representative to admit that they are blanket denying credit for having a fraud alert because as they claim it is their policy and they don't have the resources to verify identities. Yes, you heard that right, a billion dollar company claims they can't afford to follow the law. I notified Google about this back in September when I sent an email to their legal department and mailed their registered agent, along with filing a complaint with the Consumer Financial Protection Bureau, which they ignored.
I am not the first person to ever complain about this, as it appears someone else reported the same on reddit but it is a pretty unique issue. Google states that I should remove the fraud alert and then try again. I appreciate the suggestion, because this will be the final nail in the coffin to prove that they are indeed violating the ECOA. However, it will be interesting (and unfortunately expensive) to see if a judge actually applies the law as written or gives a special exception to Google based on their connections.
The immediate impact is that someone who is the victim of fraud is then stigmatized and systematically denied access to financial service.
The knock-on impact is even worse, though, as it means there is a strong consumer disincentive now to report fraud at all. People would refrain from reporting identity theft so as to preserve access to their digital lives.
At scale, this would effectively leave consumers without practical recourse to fraud, meaning that having your identity stolen in 2002 might mean you don't get a mortgage in 2042.
I sure hope the hammer falls on Google here.