On July 16, 2015, the Consumer Financial Protection Bureau (CFPB) issued the first in a new series of monthly reports that will “highlight key trends from consumer complaints submitted to the [CFPB].” According to the CFPB press release, each monthly report will “spotlight a particular product and geographic location.” Each report will also include “complaint data on company performance, complaint volume, state and local information, and product trends.” Going forward, these reports are likely to provide valuable insight into not only trends in the consumer finance industry, but also valuable information about what the CFPB may likely be taking action on in the near future. Indeed, the press release indicates that “[c]onsumer complaints are the CFPB’s compass and play a central role in everything [it] does. They help [the CFPB] identify and prioritize problems for potential action.”Each of these monthly reports, according to the CFPB press release, will include information on complaint volume by product, state and company (including the identification of the most complained about companies) in addition to the highlighted information on specific products and geographic locations. The press release also indicates that the “[c]ompany-level complaint data in the report uses a three-month rolling average of complaints sent to companies for response. This data lags other complaint data in this report by two months to reflect the 60 days companies have to respond to complaints, confirming a commercial relationship with the consumer.” Significantly, the CFPB is currently seeking input on ways to enable the public to more easily understand company-level information and make comparisons through a formal notice and request for information (published in the Federal Register at 80 Fed. Reg. 37237) for which the comment period closes on August 31, 2015.
The first report for July 2015 focuses on debt collection complaints received by the CFPB as well as the complaints received from consumers in Milwaukee, Wisconsin. In the debt collection market, the CFPB’s July 2015 report indicated that the CFPB continues to receive complaints about collection of debts that the consumer contends are not actually owed and complaints about communication tactics, such as overly frequent contact from debt collectors and contact at inconvenient times of the day. In Milwaukee, the CFPB report indicates that the consumers in that geographic location produce a higher relative number of complaints related to debt collection and a lower number of complaints regarding mortgages and credit reporting than the CFPB received from consumers nationally.
The CFPB’s initial monthly report can be found here.
Locke Lord has a dedicated team of compliance and litigation attorneys who have significant experience handling various aspects of consumer finance. Locke Lord attorneys regularly advise financial institutions on regulatory compliance matters, new product development and represent clients in regulatory enforcement matters, class actions and various lawsuits in the U.S. and abroad. Visit Locke Lord’s Consumer Finance Regulatory Practice Group website at or contact the author with questions or for more information.
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