Within the past few months, we have seen an uptick in the number of complaints that consumer finance companies are receiving through the CFPB’s Portal. Recall that the CFPB established the Portal as a complaint reporting system to assist consumers in having their complaints heard by creditors.
From the consumer’s point of view, it’s a five-step process:
From the creditor’s point of view, there are eight basic responses that it may make to the complaint:
The CFPB does not require that the company/creditor communicate directly with the consumer with respect to a complaint coming through the Portal. However, if the complainant also reached out directly to the creditor with a “direct dispute” letter then such should be treated as a dispute; and following an investigation of the complaint, the creditor should respond as it would to a direct dispute.