Government-Regulatory-and-Criminal-Investigations.jpgOn September 27, the Consumer Financial Protection Bureau (CFPB) released its Monthly Complaint Report capturing a high-level snapshot of trends in consumer complaints.  In conjunction with releasing its September Report, the CFPB confirmed it has handled over one million consumer complaints.  The CFPB describes consumer complaints as “submissions that express dissatisfaction with, or communicate suspicion of wrongful conduct by, an identifiable entity related to a consumer’s personal experience with a financial product or service.”  Consumers are able to report such complaints to the CFPB’s publicly available Consumer Complaint Database.

In assessing consumer complaints, each monthly report uses a three-month rolling average, comparing the current average to the same period in the prior year to account for monthly and seasonal fluctuations.  When assessing company-level data, the Bureau uses a three-month rolling average of complaints sent to companies for response.  The company-level complaint data lags other complaint data in the report by two months to reflect the 60 days companies have to respond to complaints, confirming a commercial relationship with the consumer.

The CFPB’s September Monthly Complaint Report provided its usual, high-level snapshot about trends in consumer complaints, including a geographic focus on consumer complaints in Pennsylvania, and provided highlights regarding consumer complaints about money transfers across the country.

The September Report showed that the financial products experiencing the biggest percentage increase by volume during the current three-month period (June-August 2016) versus the same period last year (June-August 2015) were student loans.  The largest decrease in consumer complaints during the same period were payday loans.  The Report revealed that debt collection, credit reporting, and mortgage complaints were the top three most-complained-about consumer financial products and services, representing about 67% of complaints submitted in August 2016.  The Bureau added that Alaska, Wyoming, and Colorado experienced the greatest consumer complaint volume percentage increase during the June-August 2015 to June-August 2016 timeframe; Maine, Nebraska, and Idaho experienced the greatest complaint percentage decrease during the same period.

The Bureau’s September Report also provided a focus on customer complaints relating to money transfer services.  Since July 21, 2011, the CFPB has handled approximately 6,900 money transfer complaints, representing 0.7 percent of total complaints.  The Report provided details regarding the types of consumer complaints related to money transfer services, namely, accessing funds, resolving disputes, and frauds/scams.

The CFPB’s August Monthly Complaint Report also captured the same high-level snapshot of trends in consumer complaints, and included a geographic focus on Ohio and the Columbus metro area.  This Report also included consumer complaint statistics related to bank account and services across the country.

Just as the CFPB reported in its September Report, the August Report revealed that the financial products seeing the biggest percentage increase by volume during the three-month period of May-July 2016 versus the same period last year (May-July 2015) were student loans.  The biggest decrease in complaints during this same period were payday loans.  The Bureau reported that debt collection, credit reporting, and mortgage complaints were the top three most-complained-about consumer financial products and services.  These three areas represented two-thirds of complaints submitted in July 2016.  The Bureau also similarly reported that that Alaska, Wyoming, and Colorado experienced the greatest consumer complaint volume percentage increase during the relevant time period while Maine, Delaware, and Hawaii experienced the greatest consumer complaint volume percentage decrease.

The Report offered additional details on bank account or services, which includes products offered by banks, credit unions, and nonbank companies.  The CFPB has handled approximately 94,200 complaints related to bank account or services since July 21, 2011.  Representing 10 percent of total complaints, bank account or services product complaints are the fifth most-complained-about product, according to the CFPB.  The Report detailed numerous complaints related to bank account or services

As we reported back in 2013, the CFPB uses the Consumer Complaint Database to help adjust its risk scope examinations and prioritize enforcement actions.  Companies would be wise to use the information provided in this database, as well as to maintain information regarding their own customer complaints, to stay in front of any potential issues or emerging trends.  Companies that are more responsive to complaints may minimize legal, regulatory, and reputational risk.