Perhaps it’s only fitting around the holidays that the monthly chart published by WebRecon detailing the number of lawsuits filed against companies in the accounts receivable management industry and the number of complaints filed by consumers with the Consumer Financial Protection Bureau have a fair bit of both red and green on it, although companies will likely be happy with the placement of both colors in said chart.
The number of lawsuits filed in November accusing companies of violating the Fair Credit Reporting Act, the Fair Debt Collection Practices Act, and the Telephone Consumer Protection Act were all lower than the number that were filed in October — markedly so, in fact — with each seeing a drop of at least 10% on a month-over-month basis. Through the first 11 months of 2021, the number of lawsuits alleging violations of the FDCPA and TCPA were down compared with the same period of 2020 while the number of FCRA suits is up, but only by 3.5%. With only one month left to tabulate, it appears as though litigation against companies in the ARM industry will continue its slightly downward trend. Although subsequent charts issued by WebRecon will be done after the enactment of Regulation F, so it’s possible that there will be an uptick in the number of FDCPA suits in the coming months.
While continuing to add to what will be a record year for the number of complaints filed by consumers with the CFPB, the month-over-month totals declined in November. This marks the fourth straight month that the totals have declined from the previous month and six out of the past eight months overall. Perhaps this is an indicator that the number of complaints filed in 2022 will not be as voluminous as they are going to be this year and will be returning to a more normal level.