CFPB Focuses on Complaint Trends & Concentrations Leveraging New Tools

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The CFPB recently announced new publicly available tools to better leverage the Complaints Database and to spot trends and concentrations of consumer complaints. If you are a data nerd, or even if you are not, it might be prudent to familiarize yourself and your teams with these new tools, as they are likely to be utilized by the Bureau and others in a variety of contexts. The industry should assume State AG’s offices and State consumer agencies will access the data in connection with their activities, including any supervision and enforcement. It is likely that consumer protection advocacy groups will analyze and utilize the data in their work. Finally, it is possible that consumer class action litigators may attempt to incorporate data trends or specific topic concentrations into their cases. Even if your institution may not be experiencing a complaint spike, noting the fact that others are, could help your team proactively refine operations procedures and mitigate risk.

Director Kraninger had promised the enhanced resources and tools last year.  In the recent press release, she noted that “these powerful new capabilities allow users to gain deeper insight into changes in the location, type, and volume of complaints over time, which provides valuable context into consumers’ experiences in the financial marketplace.”

Functionality Enhancements. Among the new capabilities are the (a) ability to differentiate total volume versus per capita volumes by state, (b) the ability to limit complaints volumes by time, and (c) the ability to view trends in two different manners (line graphs and stack graphs). All of this can be done per institution or across industry. There also is enhancement of the ability to focus on particular products and issues as well as their trends over time.  

Map Function – State Comparison. For example, the new map function contains seven colored tranches of volume. The lowest in the range is white and the highest is deep blue. The deep blue corresponds with complaint volumes greater than 5,958.  For 2020, specifically the time period January 1, 2020 through July 17, 2020, 8 states appear in the CFPB highest tranche: Florida, California, Texas, New York, Georgia, Pennsylvania, Illinois, and New Jersey.

  Overall Complaint Volume 2020 YTD Highest 5 States  
Florida 28,898
California 26,487
Texas 21,321
New York 13,272
Georgia 12,663

 

Highest 5 States – Per Capita (Complaints per 1000 population). The new map function also has a tab for per capita complaints (complaint per 1000 population). Similarly, this data is divided into seven colored tranches of volume, lowest white and the highest deep blue. In the Per Capita data, the deep blue corresponds with per capita complaint volumes greater than 0.77 complaints per 1000 population.  For 2020, specifically the time period January 1, 2020 through July 17, 2020, 8 locales appear in the CFPB highest per capita tranche: Arkansas, Florida, Washington, D.C., Georgia, Nevada, Delaware, Texas and Alabama.

Per Capita Complaint Volume (Complaints per 1000 population) Highest 5 States/Territories  
Arkansas 1.78
Florida 1.43
Washington, D.C. 1.25
Georgia 1.24
Nevada 1.13

Please note that the lists are fairly different and the per capita rankings may be surprising to some. Importantly, however, Florida and Georgia have the dubious honor of placing in both top 5 lists. Institutions and your teams should pay close attention to your highest volume populations, including the states on the top 5 lists, and use these data tools to see what your institution’s map and statistics may show.  

Trend Function. The “Trend” functions also have been enhanced to include (a) by company and (b) by topic type / issue. The results can be viewed in two types of trending charts, one line graph and the other stacked lines. Time frames can also be manipulated to show only the following segments: 3 months, 6 month, 1 year, 3 years or all years. For example, industry wide for the 3 months, April through June 2020, the trend shows month-over-month increases with the spike occurring in late June at 38,000+ complaints being filed. Data intervals also can be changed to limit the data increments to daily, weekly, monthly, quarterly and yearly. At times of crisis, we presume that the daily and weekly increment may be leveraged to see when peaks are rising and when the highest volumes have begun to recede. One can also manipulate the specific product and issue types to discern differing trends. For example, if the above 3 month trend data is limited to the “credit card or prepaid card” product and to the issue of “closing your account” (a sub-population of 608 complaints), the trend line shifts. June saw a reduction in complaint volumes for that product and issue, and complaint volume peaked in May 2020.       

List Feature. Finally, the new “List” feature allows the public to see the specific company name and detail involved in particular types of complaints. So for the above example, the institution, date and description of each complaint about credit card account closing is available in List. That’s where you really can see how exactly how you and your peers are doing, should you choose to look. And the data can be sorted a variety of ways including newest to oldest or the reverse, as well as by relevance, to the extent you use your own search terms instead of CFPB designated products and issues.

Takeaways. Data is power. Presumably your own institution is leveraging its own data to best execute strategy and operations. Now, the CFPB and others have enhanced tools with which they can better see both the big picture across the industry and can drill down specific time frames, issues and products at your institution and peers. Combining your own data analysis with understanding how your institution looks to the public and to regulators is an important aspect of mitigating business and reputational risks.       

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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