On October 23, 2018, the Consumer Financial Protection Bureau (CFPB) issued a new report, Complaint Snapshot: 50 State Report, providing a high-level overview of the trends in consumer complaints submitted to the CFPB from January 1, 2015, through June 30, 2018. A few notable trends in the report highlight areas for focus by financial services companies and some predict the report may impact future CFPB rulemaking.
The report discloses that the three most common complaints submitted to the CFPB nationwide were related to credit reporting, debt collection and mortgages. Notably, the volume of consumer reporting complaints grew by 12% from 2016 to 2017, becoming the most common type of complaint. This reminds creditors and debt collectors to review their policies and procedures and be vigilant in requiring the furnishing of complete and accurate data to consumer reporting agencies in the coming year. Also notable is that complaints about prepaid cards trended upward in the beginning half of 2018, while student loan, payday loan and money transfer complaints all trended lower.
Nationally, the top issue reported by consumers by product were categorized as follows:
Debt Collection: Attempts to collect debt not owed
Credit or Consumer Reporting: Incorrect information on your report
Mortgage: Trouble during payment process
Credit Card: Problem with a purchase shown on your statement
Checking or Savings: Managing an account
The effect of this report may extend beyond a warning of vigilance to financial service companies as some predict this information may impact future CFPB rulemaking. Indeed, Acting Director Mick Mulvaney previously emphasized the importance of complaint data in determining how to allocate CFPB's resources. The prevalence of consumer complaints concerning "attempts to collect debt not owed" and the importance of consumer complaints in the CFPB's process may prompt the CFPB to include data integrity requirements—addressing the "right consumer, right amount" aspect of the 2016 proposed debt collection rules—in the upcoming debt collection rules, which are scheduled for release by March 2019. Debt collectors and creditors should carefully review the draft rules when they are released in 2019.