Originally Posted by
mattp1987
As to the part I bolded, what constitutes accepting a credit? If Delta cancelled the flight and issued a credit without the customer asking for it, does that really count as accepting it? Unless OP contacted Delta and asked for and/or accepted a credit in lieu of a refund, they should be able to request a refund to the form of payment even after this amount of time.
It seems fairly clear, reading the April 2020 Warning Letter (which extensively quotes the 2011 original ruling) that the violation occurs when the carrier refuses a refund if it offers an alternative, e.g. credit and the customer refuses.
The right to the refund is established in the original contract and it is up to the customer to request it.