ACA Whitepaper Analyzes Collection Complaints Submitted to CFPB

Comments from Mick Mulvaney, the acting director of the Consumer Financial Protection Bureau, have made it appear as though the agency will be using its consumer complaint database as a tool to prioritize its regulatory agenda. In those remarks, Mulvaney pointed to the number of complaints about debt collectors, saying:

“In 2016, almost a third of the complaints into this office related to debt collection. Only 0.9% related to prepaid cards and 2% to payday lending. Data like that should, and will, guide our actions.”

Those comments, and that shift in how the CFPB sets its regulatory course, make the timing perfect for a new whitepaper from ACA International, which analyzes the collection-related complaints filed by consumers with the agency.

As it has stated on numerous occasions before, ACA’s primary issue with the complaints in the CFPB’s database is a lack of context. For example, while debt collection-related complaints were the second-most popular complaint topic in 2017 (behind credit reporting and credit repair), that figure represents about 0.005% of the total number of individuals who had “contact with the debt collection industry in 2017,” according to ACA’s analysis.

ACA also pointed out that the number of “negative” complaints, such as harassment or illegal practices, were the categories of complaints in which consumers complained the least, according to the association’s review.

The whitepaper outlines some concerns about the limitations of the data and suggests that the CFPB needs to do a better job of explaining what a “complaint” represents.

“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 signicantly better job of making clear the limitations of the data it collects and reports,” ACA wrote. The agency “should adopt a more appropriate de nition of what constitutes a complaint and implement proper normalization procedures to reduce the currently misleading nature of the data.”




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