Apple and Goldman Sachs’ $89 Million Broken Promise to Customers

EvilCorporations.com • CFPB File No. 2024-CFPB-0012 • 26 min read

The Non-Financial Ledger: What a Number Can’t Repay

Picture this. You’ve been a careful person with money your whole life. You don’t carry balances you can’t pay. You watch your credit score the way other people watch their blood pressure, because you know what it costs when it drops. You bought an iPhone from Apple, paid with your Apple Card, and believed what Apple’s own app told you: that your purchase was covered by interest-free monthly payments. Apple’s advertisements said it. Apple’s checkout process implied it. Apple’s customer service representative confirmed it when you asked.

Then the bill came. Standard interest. Not the zero-percent installment plan you’d been promised. You opened the Wallet app and filed a dispute through Apple’s own “Report an Issue” tool, exactly as the billing rights summary in your Apple Card agreement told you to do. The system asked for a little more information. You were busy. Maybe you missed the follow-up form buried inside the Messages app. Maybe you thought pressing “Done” on the first screen was enough, since nothing in the interface told you otherwise.

Apple never sent your complaint to Goldman Sachs. Goldman Sachs never investigated it. Neither company contacted you to say there was a problem. The first indication that anything had gone wrong arrived later, in a different form: a negative mark on your credit report. Goldman had reported you delinquent on the very amount you had tried to dispute, before a single human being at either company had read your complaint. Your creditworthiness, the number that determines whether you get the apartment, the loan, the reasonable interest rate on the next thing you need, took a hit because two of the most profitable companies in American history could not be bothered to forward your message.

This happened to tens of thousands of people. The CFPB’s findings are direct: these injuries were not reasonably avoidable, because neither Apple nor Goldman told consumers that failing to complete a secondary form inside the Messages app meant their dispute would be silently discarded. There was no warning. No follow-up. No acknowledgment. The system was designed by Apple, promoted as a consumer-friendly interface, and it failed the people it was supposed to serve while generating no countervailing benefit to anyone except the companies running it.

For a separate group of consumers, the harm came at the point of sale. They chose to buy an Apple device partly because they believed they could spread the cost over months with zero interest. Some of them may not have made the purchase at all at the full price, all at once, on a standard interest rate. Apple’s advertisements made the promise. Apple’s checkout process, which didn’t even explain what “Pay monthly” meant until after consumers clicked it, made the promise. And in physical Apple Stores, the promise was made again by the people Apple trained and employed to speak to customers. When those consumers discovered the truth, they were told by Apple and Goldman that the only fix was to return the device and repurchase it. Return it. Start over. As if the deception were the customer’s problem to undo.

There is also a third category of harm that is easy to overlook in the fine print. If you used any browser other than Apple’s own Safari, or if you used Safari in private mode, Apple’s checkout process simply did not show you the interest-free installment option at all. You could not choose something you could not see. Apple never disclosed that this restriction existed. Consumers shopping in Chrome or Firefox, or anyone protecting their browsing privacy with a private window, were invisibly excluded from a financing option that Apple’s marketing told everyone they could access.

Twenty-five million dollars is the fine Apple will pay. That figure, against the backdrop of Apple’s scale, is a rounding error. The people with damaged credit reports are still working to get those marks removed. The people who paid interest they were told they would never owe have already paid it. The Consent Order requires Apple to fix its systems going forward. It does not give anyone their credit score back.

Legal Receipts: What the Document Actually Says

The CFPB’s Consent Order is a federal administrative document, signed and entered October 23, 2024. The following are direct quotes from that filing. These are not summaries. They are the government’s own words.

“Beginning in June 2020, in tens of thousands of instances, Apple failed to do so. In June 2020, Apple added a new ‘forms feature’ to the Report an Issue functionality, which asked consumers to provide additional information by completing an additional form. However, when tens of thousands of consumers did not complete the additional form, Apple failed to send the disputes to Goldman, and neither Apple nor Goldman investigated these disputes.” CFPB Consent Order, File No. 2024-CFPB-0012, ¶¶ 5–6

• This confirms the dispute suppression was structural, not accidental. Apple designed a multi-step form and then quietly treated non-completion as a reason to drop the complaint entirely, without alerting the consumer.
• The scale is explicit: tens of thousands of instances. These were real people with real billing complaints, not statistical noise.
• The phrase “neither Apple nor Goldman investigated these disputes” means both companies were jointly responsible for leaving consumers with unresolved billing errors.

“These injuries were not reasonably avoidable because neither Respondent nor Goldman took steps necessary to make consumers aware that, if consumers did not complete the additional form, the Billing Error Notices at issue would not be investigated.” CFPB Consent Order, File No. 2024-CFPB-0012, ¶ 22

• “Not reasonably avoidable” is a legal standard under the CFPA’s unfairness test. Meeting this threshold means the CFPB concluded that a reasonable consumer had no practical way to protect themselves from what Apple and Goldman allowed to happen.
• Apple designed the interface. Apple chose not to include a warning. That was a design decision, not an oversight the consumer could have detected or circumvented.

“Respondent’s failure to send Billing Error Notices to Goldman for resolution did not create any countervailing benefits to consumers or to competition.” CFPB Consent Order, File No. 2024-CFPB-0012, ¶ 23

• Under CFPA unfairness analysis, a practice must cause substantial injury, be unavoidable, and produce no offsetting benefit to pass the threshold for a violation. The CFPB confirmed all three conditions were satisfied here.
• The plain meaning: dropping consumer complaints produced zero legitimate business benefit. It only harmed the people who filed them.

“Until at least July 2020, when consumers used a browser other than Respondent’s ‘Safari’ or used ‘Safari’ in private mode during the checkout process for purchasing Apple devices from Respondent’s website, Respondent did not display an option to enroll in ACMI.” CFPB Consent Order, File No. 2024-CFPB-0012, ¶ 40

• This is documented browser discrimination. Apple’s own non-Safari users, which includes the majority of global internet users, were invisibly excluded from a financing option Apple promoted to everyone.
• Private mode users, a category that explicitly includes people protecting their privacy, were also blocked. Apple’s privacy-protective Safari mode was used against the consumers who chose it.

“Until at least August 2020, after consumers had already purchased Apple devices without enrolling in ACMI, Apple and Goldman required consumers to return the devices and repurchase before they could be enrolled in ACMI.” CFPB Consent Order, File No. 2024-CFPB-0012, ¶ 34

• This is the remedy Apple and Goldman offered to victims of their own misleading enrollment process: physically return the product and start the transaction over from scratch. The burden of correcting the companies’ deception was placed entirely on the consumer.
• For many consumers, especially those who had already set up a new device, this was not a realistic option. It was a procedural barrier designed to limit redress.

“Respondent acknowledges that its Taxpayer Identification Number… may be used for collecting and reporting on any delinquent amount arising out of this Order, in accordance with 31 U.S.C. § 7701.” CFPB Consent Order, File No. 2024-CFPB-0012, ¶ 59

• The CFPB is treating Apple the same way a debt collector treats a delinquent borrower: retaining Apple’s taxpayer ID for collection purposes in the event of non-payment. The company built a system to hold consumers’ financial information hostage, and now the government holds theirs.

Societal Impact Mapping: Who Pays When Corporations Cut Corners

Public Health of the Financial System

Consumer trust in financial technology is a public resource. When a company as dominant as Apple systematically misleads people about how its financial products work, the damage spreads well beyond individual account holders.

• Tens of thousands of consumers who submitted billing disputes through Apple’s official dispute channel received no investigation, no resolution, and no notification that their complaint had been dropped. Their trust in the dispute process, a federally mandated protection, was weaponized against them by the company that designed it.
• Consumers who had negative credit marks applied to their files for disputed amounts, before any review occurred, may have faced higher interest rates, denied loan applications, or rejected rental applications during the period those marks remained on their reports. These cascading consequences are impossible to fully quantify but are documented as real injuries in the CFPB order.
• The fraudulent auto-enrollment promise for ACMI affected consumers’ purchase decisions at the point of sale. Thousands complained to Apple that they had expected zero-percent financing and instead received standard credit card interest, meaning their cost of borrowing was higher than they consented to when they agreed to make the purchase.
• Apple’s customer service representatives actively reinforced the false auto-enrollment claim to consumers who called in to ask. This means the misinformation was embedded not just in advertising copy but in trained human interaction, making it harder for any individual consumer to independently identify the deception before it cost them money.
• The requirement that consumers return their device and repurchase to correct the financing error was functionally a denial of remedy for most people. Device setup, data migration, and the logistical barrier of a physical return created a recovery process designed to fail anyone who didn’t have the time, ability, or proximity to carry it out.

Economic Inequality

The specific design of Apple and Goldman’s misconduct targeted the financial tools that working people rely on to manage large purchases. The people most harmed were those who needed the zero-interest installment option because they could not absorb a full iPhone payment at once.

• Consumers who specifically chose ACMI to avoid interest charges were precisely those for whom standard credit card interest rates would represent a significant additional cost. A consumer who can pay $1,000 upfront without issue does not care about an interest-free installment plan. The people who relied on ACMI were people for whom the interest cost was material to their budget.
• Credit score damage falls hardest on people with thin credit files or those who are already managing their score carefully. A negative mark from Goldman Sachs, applied before a dispute was even reviewed, could take months to correct and cause concrete economic harm in the interim, including higher rates on other credit products, failed rental applications, and employment background checks that consider credit history.
• The browser restriction that hid ACMI from non-Safari users had an unequal impact across economic lines. Lower-cost Android devices, Windows laptops, and non-Apple hardware are disproportionately used by lower-income consumers. Apple’s ACMI option was effectively more accessible to people who already owned an Apple ecosystem than to people shopping on the hardware they could afford.
• The $25 million penalty Apple paid represents less than 0.02% of the company’s 2023 net income of approximately $97 billion. For the consumers who absorbed unexpected interest charges over months, the financial burden was not a rounding error. It was rent money, grocery money, or credit card debt that compounded.
• Goldman Sachs’ parallel $45 million restitution order is meant to compensate harmed consumers, but the CFPB’s own Consent Order against Apple does not guarantee direct restitution to every affected person. The $25 million Apple pays goes into the CFPB’s Civil Penalty Fund, not into the pockets of the people whose credit scores were damaged.

The Cost-of-a-Life Metric: Translating the Fine

Numbers mean different things at different scales. Here is what Apple’s $25 million federal fine looks like when you translate it out of the abstract.

What Now? The Watchlist and the Path Forward

Apple has consented to a federal order that governs its behavior for five years. Knowing who is watching and what they are watching for is the first step in holding them to it.

Who Is Responsible at Apple

The Consent Order identifies the following roles within Apple as bearing direct accountability for compliance. The CFPB requires these specific officers to review all compliance reports and approve submissions under penalty of perjury:

• The General Counsel and Secretary of Apple Inc.
• The Senior Vice President for Services
• The Vice President of Internet Services responsible for managing Apple Card
• The Audit and Finance Committee of Apple’s Board of Directors
• Apple’s full Board of Directors, which bears ultimate responsibility for compliance under the order

Regulatory Watchlist

• Consumer Financial Protection Bureau (CFPB): The primary enforcer of this Consent Order. Apple must submit a compliance progress report to the CFPB’s Enforcement Director within one year of October 23, 2024. Any new violation of the order can result in additional civil penalties at the maximum rate allowed under federal law.
• Consumer Reporting Agencies (CRAs): The three major credit bureaus (Equifax, Experian, TransUnion) received negative reports from Goldman Sachs on behalf of consumers whose disputes were never investigated. If you were an Apple Card user who disputed a transaction through Messages between June 2020 and July 2021 and your credit was marked delinquent, you may have grounds to dispute that entry directly with each bureau.
• Federal Trade Commission (FTC): Retains authority over deceptive advertising practices independently of the CFPB. Apple’s misleading ACMI advertisements remain relevant to FTC enforcement scope.
• State Attorneys General: The Consent Order explicitly does not bar any other governmental agency from taking action against Apple based on the same conduct. State-level consumer protection offices in California, New York, and other major states can and do pursue independent actions.

What You Can Do Right Now

• If you used Apple Card’s “Report an Issue” function in Messages between June 25, 2020 and July 31, 2021 and your dispute was not resolved, file a complaint directly with the CFPB at consumerfinance.gov/complaint. The CFPB is actively monitoring Apple under this order and your complaint creates a documented record.
• Pull your credit reports for free at annualcreditreport.com and search for any negative marks from Goldman Sachs Bank USA on Apple Card accounts from the 2020–2021 period. Dispute any entry that corresponds to an amount you contested during that window.
• Join or follow digital rights and consumer finance advocacy groups that track CFPB enforcement, including the National Consumer Law Center (NCLC) and the Center for Responsible Lending (CRL). These organizations file amicus briefs, publish enforcement trackers, and provide legal resources for people harmed by financial product misconduct.
• If you believe you personally were charged interest you were told you would not owe on an Apple device purchase made between December 2019 and August 2020, consult a consumer protection attorney. Class action litigation based on the same facts described in the CFPB order is a legally protected avenue. The Consent Order does not bar private lawsuits.
• Talk about this in your community. Apple’s brand identity is built on trust. The people in your network who use Apple Card should know that the company running their financial product was found by a federal agency to have engaged in unfair, deceptive, and abusive acts. Share this article. Share the source document. The CFPB made it public for exactly this reason.