ACA International Releases White Paper Analyzing CFPB’s Debt Collection Consumer Complaints

3/20/2017 8:00 AM

The CFPB’s Consumer Complaint Database fails to properly contextualize consumer complaints about debt collection and leads to an incomplete picture of the industry and its practices.


ACA International, the association of credit and collection professionals, has released an analysis of complaints submitted to the Consumer Financial Protection Bureau in a new white paper, “A Review of Debt Collection Complaints Submitted to the Consumer Financial Protection Bureau’s Complaint Database in 2016.”

In the white paper, ACA argues that although the overall raw number of complaint submissions to the CFPB database appears high for the debt collection industry, once the data has been properly contextualized, the number of consumer complaints is remarkably low. Furthermore, while the complaints have limited utility as indicators of the compliance commitment of legitimate debt collectors, they can function as tools to spur continual improvement of existing debt collection practices.

"As an industry that makes approximately one billion consumer contacts each year and actively encourages communication between consumers and legitimate third-party debt collectors, it’s imperative to understand that the CFPB’s debt collection complaint handling process relies on a flawed methodology and the resulting data lacks critical context, fundamental flaws that create an inaccurate perception of the debt collection industry,” said ACA International CEO Pat Morris.

In the white paper, ACA asserts that the CFPB fails to contextualize the number of complaints lodged with the CFPB within the larger context of the debt collection industry.  For example, ACA’s analysis shows the total number of debt collection complaints received by the CFPB represents an incredibly small number of consumers (0.004%) who had contact with the debt collection industry during 2016.  Further, the complaints account for only .05% of all Americans estimated to have a debt in collection.

ACA’s analysis also demonstrates that the CFPB’s data suggests that many of the issues consumers complain about are associated with the technical aspects of credit, outstanding debt, and the debt collection industry. In fact, based on the CFPB’s own data, an overwhelming majority of consumers are not lodging complaints about harassing or harsh debt collection practices, a finding that stands in contrast to the misleading narrative about the debt collection industry being fostered by the CFPB.

“Given that the CFPB has branded itself as a ‘data-driven’ agency that promotes transparency, this analysis underscores the critical need for the CFPB to do a significantly better job of making clear the limitations of the data it collects and reports,” writes ACA International Director of Research Josh Adams, PhD.

ACA International’s new research initiative aims to collect more original data about the credit and collection industry. The goal of this exclusive research and analysis is to quantify the ways that debt collectors help consumers and the overall economy.

ACA International (ACA), the association of credit and collection professionals, is the largest membership organization in the credit and collection industry. Founded in 1939, ACA brings together third-party collection agencies, law firms, asset buying companies, creditors and vendor affiliates, representing tens of thousands of industry professionals. ACA produces a wide variety of products, services and publications, including educational and compliance-related information; and articulates the value of the credit and collection industry to businesses, policymakers and consumers.



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