Bullion Standard, Inc. v. Bank of America, N.A., et al.

CourtDistrict Court, S.D. California
DecidedFebruary 17, 2026
Docket3:25-cv-01299
StatusUnknown

This text of Bullion Standard, Inc. v. Bank of America, N.A., et al. (Bullion Standard, Inc. v. Bank of America, N.A., et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bullion Standard, Inc. v. Bank of America, N.A., et al., (S.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 Bullion Standard, Inc., Case No.: 25-CV-1299-W-SBC

12 Plaintiff, ORDER GRANTING IN PART AND 13 v. DENYING IN PART MOTION TO DISMISS AND DENYING MOTION 14 Bank of America, N.A., et al., TO STRIKE [DOC. 23] 15 Defendants. 16 17 Before the Court is Defendant Bank of America’s motion to dismiss Plaintiff’s 18 Amended Complaint for failure to state a claim upon which relief may be granted. 19 (Motion [Doc. 23].) In this removed case, Plaintiff Bullion Standard, Inc. (“Bullion”) 20 complains that their bank account was wrongfully frozen, their funds were stolen and 21 withdrawn, and their account was otherwise mishandled by the Bank of America (“BOA” 22 or the “Bank”), consistent with its historical pattern of defrauding customers and account 23 holders generally and Plaintiff specifically. The central disputes are (1) whether BOA 24 wrongfully treated Bullion’s account as holding fraudulent funds, (2) whether BOA 25 wrongfully conducted or failed to conduct an investigation into Bullion’s account, and (3) 26 whether BOA wrongfully froze or retained Bullion’s funds. 27 The Court finds this motion suitable for determination on the papers submitted and 28 without oral argument. Fed. R. Civ. P. 78(b); Civ. L.R. 7.1(d)(1). The Court concludes 1 that the motion (Doc. 23) is GRANTED IN PART and DENIED IN PART, as 2 explained here. 3 4 I. FACTUAL AND PROCEDURAL BACKGROUND 5 BOA removed this case on July 16, 2025. Bullion filed its first amended 6 complaint (the “Complaint”) on September 2, 2025. (Compl. [Doc. 21].) BOA moved to 7 dismiss the complaint in its entirety. (Motion [Doc. 23-1].) Plaintiff responded in 8 opposition. (Oppo. [Doc. 25].) BOA replied in support. (Reply [Doc. 26].) 9 Bullion is a California online precious metals retailer that prides itself on a 10 reputation as “the trusted choice for discerning precious metals investors.”1 (Compl. 11 ¶¶ 1, 5, 11.) Bullion opened a bank account with BOA to receive wire transfers from its 12 customers buying precious metals. (Id. ¶ 6.) Bullion’s reputation among customers is 13 vital to its business due to the fierce competition in the bullion retail market. (Id. ¶¶ 13– 14 14.) Part of Bullion’s strategy to build customer confidence and maintain its strong 15 reputation was to enact several anti-fraud policies to ensure that customers are not 16 identity thieves and that they receive their goods when purchased. Bullion’s policies to 17 this end include “IPQS Enterprise grade fraud software, telephonic order verification, 18 email verification, tracked shipping, and signature delivery confirmation.” (Id. ¶ 14.) 19 Bullion contacted BOA before opening its account to confirm whether it needed to 20 meet additional prerequisites, such as anti-money laundering certifications, in light of its 21 need for wire transfers as a core component of its precious metals trade. (Id. ¶ 22.) BOA 22 represented it was more than able to handle Bullion’s business needs and induced Bullion 23 to open the account based on BOA’s representations. (Id.) Bullion opened a direct 24 deposit account (the “Account”) with BOA on January 17, 2024, with confidence in 25

26 1 The Court assumes the truth of all factual allegations when reviewing this Rule 12(b)(6) motion and 27 construes the facts in the light most favorable to the nonmoving party, Bullion. See Cahill v. Liberty Mut. Ins. Co., 80 F.3d 336, 337–38 (9th Cir. 1996); Barrett v. Belleque, 544 F.3d 1060, 1061 (9th Cir. 28 1 BOA’s capabilities. (Compl. ¶ 22.) Bullion only later learned that its confidence was 2 misplaced because of multiple scams or violations of law BOA committed to deprive 3 classes of customers of their money. (Id. ¶¶ 16–22.) During the next year of its 4 commercial banking, there were no problems with BOA, and approximately $4,000,000 5 was received into the Account during that time. (Id. ¶ 23.) 6 7 A. BOA’s Historical Scams Against Classes Of Customers Not Alleged To Include Bullion 8

9 Bullion alleged broadly that BOA has a notorious and somewhat recent history of 10 fraudulent practices and conduct against the interests of its customers in general. (Compl. 11 ¶¶ 16-21.) In support, Bullion alleged BOA committed four historical scams against the 12 Bank’s customers in defined classes—the credit card scam, the garnishment scam, the 13 fraud reporting scam, and the theft scam. (Id.) There is no allegation that Bullion was 14 impacted directly by any of these scams. Rather, Bullion alleges them as relevant to 15 BOA’s treatment of its customers and alleges that the orders entered in response to those 16 scams are evidence of BOA’s knowledge of its own wrongdoing. 17 First, the credit card scam alleged that BOA deceptively marketed their credit card 18 add-on products and “illegally charged approximately 1.9 million consumer accounts for 19 credit monitoring and credit reporting services that they were not receiving,” by 20 misrepresentation and engaged in unfair billing. (Id. ¶ 18.) BOA was ordered, among 21 other penalties, to pay approximately $268 million to approximately 1.4 million 22 customers, approximately $459 million to roughly 1.9 million customer accounts who 23 enrolled in credit monitoring, and a penalty of $20 million in penalty to the Consumer 24 Fraud Protection Bureau’s (“CFPB”). (Id.) The second alleged historical scam was the 25 garnishment scam. (Id. ¶ 19.) Bullion alleged that the CFPB described BOA’s 26 misconduct to include, among other things, false representation regarding rights to have 27 funds exempted from garnishment, and in response to an adverse finding, BOA paid a 28 $10 million penalty to the CFPB. (Id.) The third alleged historical scam was the fraud 1 reporting scam. (Id. ¶ 20.) The CFPB described the primary wrongdoing as using a 2 fraud filter, as opposed to reasonable investigation, that automatically imposed an 3 account freeze to the debit cards of unemployment insurance benefit accounts. (Id.) The 4 final alleged historical scam is the theft scam. (Id. ¶ 21.) Plaintiff alleged that, in 2023, 5 the CFPB concluded that BOA was liable for wrongfully retaining the money of its 6 poorest customers, causing customers to be charged wrongful fees and to suff harm on 7 their credit profiles. (Id.) 8 9 B. Wrongdoing Alleged to Harm Bullion Specifically 10 Here, Bullion’s claims arise from BOA’s conduct in early 2025, over the course of 11 multiple transactions between Bullion and three of its customers. (Compl. ¶ 25.) 12 13 1. Customers 1 and 2 14 Between January 8, 2025, and February 13, 2025, Customer 1 purchased 15 approximately $380,000 of precious metals from Bullion over a series of transactions, 16 sending multiple wire transfers of money to the Account. (Compl. ¶ 25.) After each 17 transaction, Bullion transferred the funds to its wholesaler to fulfill Customer 1’s orders. 18 (Id.) Bullion monitored the transactions and confirmed the product was delivered to 19 Customer 1 for each order. (Id.) Customer 1 verified receipt of the product on February 20 17, 2025, and Bullion believed the transaction was complete. (Id.) In fact, without 21 Bullion’s knowledge, Customer 1 gave their product to an unknown third party, 22 according to Bullion’s complaint, “Potential Thief 1.” (Id. ¶¶ 25–26.) According to 23 Bullion, Potential Thief 1 obtained the product under false pretenses, and Customer 1 was 24 a victim of the third party’s fraud. (Id. ¶ 26.) Customer 1 then allegedly went to BOA 25 (there is no allegation that Customer 1 was also a BOA account holder) and reported the 26 product stolen. (Id.

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Bullion Standard, Inc. v. Bank of America, N.A., et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/bullion-standard-inc-v-bank-of-america-na-et-al-casd-2026.