Incomm gave similar response that you got, but they wouldn't refund any fees. I wrote back twice that I wasn't satisfied, but they wouldn't budge. There was no option to escalate. BBB did nothing but transfer correspondence. I didn't bother going to FDIC. I also had bought a second card before 1st was cancelled. I couldn't register it and they still refused to refund any fee. I had to wait at least a month for check to come in mail. I had an experience with a different card, green dot related, where I didn't pay a fee, which I couldn't register. They sent a refund in 10 days, including the normal fee which I hadn't paid!