ACA Whitepaper Calls Out CFPB’s Servicemember Complaint Data

ACA International has published a report that questions the claims made by the Consumer Financial Protection Bureau related to the interactions between servicemembers and debt collectors.

The CFPB’s broad classification of what constitutes a servicemember and the broad definition of what constitutes a “complaint” are skewing the data, and over-sensationalizing the actual scope of the problem, claims the ACA.

The CFPB’s Office of Servicemember Affairs issued its annual report for 2015 in March. In the report, the CFPB noted that servicemember complaints were twice as likely to be debt collections than any other category of complaint. And the mainstream media picked up on that nugget in a very big way.

ACA’s whitepaper attempts to provide additional context to the report, to illustrate that the collections industry is not targeting servicemembers.

First, the CFPB’s definition of what constitutes a servicemember includes not just active duty members of the military, but members of the Nation Guard, Reserves, veterans, military retirees, and their family members. The CFPB does not break out the number of complaints for each group of individuals that are included in the definition of servicemember. There are approximately 2 million active duty and reserve military personnel, but there are more than 22 million veterans, for example, who are included in the CFPB’s definition of servicemember.

The whitepaper also calls into question the broad nature of what constitutes a complaint. The whitepaper quotes testimony from CFPB Director Richard Cordray, who said that some complaints filed under the category of debt collections are being misclassified, as those filing the complaints should have filed them under a different category. The whitepaper also notes that the CFPB’s definition of complaint “is so broad that mere dissatisfaction, as opposed to actual misconduct, is categorized as a complaint.”