The bureau fails to contextualize the number of complaints relative to the number of consumers who have contact with the accounts receivable management industry.
10/24/2018 16:00
A consumer complaint report released Oct. 23 by the Bureau of Consumer Financial Protection contains data related to the accounts receivable management industry that fails to provide necessary context for understanding the data.
The complaint snapshot provides a high-level overview of trends in consumer complaints and supplements the Consumer Response Annual Report with more recent information on complaints about consumer financial products and services by state, according to the bureau.
ACA International remains concerned that the bureau continues to publicize complaint trends and raw data without providing proper context and analysis.
“ACA has long held that the bureau—at a minimum—needs to develop and implement fair and transparent metrics to normalize the complaint data it makes publicly available on the database, narrow the definition of a ‘complaint’ so that it covers only alleged conduct that would be unlawful if true, and to consistently use prominent disclaimers that appropriately describe the limitations of published complaint data,” Mark Neeb, ACA International’s CEO said. “Once again, ACA International notes that the BCFP’s data fail to distinguish between actual complaints and any range of other issues, from mundane business disputes to dissatisfaction with financial services.”
The report notes debt collection was the source of 302,438 complaints, which is one example of the continued failure to contextualize the number of complaints lodged with the BCFP within the larger context of the debt collection industry. In particular, ACA’s analysis shows the total number of debt collection complaints received by the BCFP (302,438) over the last three and a half years represents an incredibly small number of consumers (0.03 percent) who had contact with the debt collection industry. [This is based on the value of one billion consumer contacts annually.]
Additional analysis from ACA shows:
- The BCFP broadly defines a “complaint” 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.” Further, the bureau also does not verify the complaints that it receives from consumers for accuracy.
- The publication of unverified consumer complaint data and the use of the raw numbers of debt collection complaints continue to imply evidence of widespread industry harm.
- Beyond the presentation of the data, there remain underlying issues with the complaint database and collection of data, including:
- The BCFP’s use of non-exclusive reporting categories that allow for overlap in the complaint submission process creating confusion among consumers and leading to inaccurate categorization of complaints.
- The problem of consumers misclassifying complaints or intending to complain about one product yet submitting a complaint for another product; particularly if there is no category available for the more appropriate product (i.e., insurance, landlord/tenant disputes, etc.).
- The bureau also has not addressed the occurrence of duplicate complaints or multiple complaints from a single consumer about a specific issue. As such, while the report suggests that the 302,438 debt collection complaints represent discrete issues impacting individual consumers that would be an inaccurate interpretation.
The bureau’s latest complaint snapshot follows a September report outlining how data are used to inform decisions as well as a Request for Information (RFI) seeking input from interested parties on the bureau’s data collection program, ACA International previously reported. ACA continues to review the RFI and will provide further feedback to members and updates in ACA Daily.
Read the complete 50-state complaint snapshot on the BCFP’s website.
Related Content from ACA International:
BCFP Issues Request for Information on Data Collection Practices