Washington, D.C.: Credit Union Advisory Council meeting

Welcome to the Consumer Financial Protection
Board Credit Union Advisory Council. I’d like to turn it over to Director Cordray
for a few comments. I would just like to welcome everyone. This
is the public session of the Credit Union Advisory Council. These are folks who have
applied and been chosen, with a lot of input from around the country. They bring us considerable
perspective about how the work of the CFPB potentially affects credit unions, how they
are finding issues and situations in their markets. Any input that they want to give
us is always welcome. We are going to have a couple of sessions
here this afternoon where we are going to talk about some specific issues. And we welcome
the public both here and anyone who may be following the meeting publicly.
I thought we might have some congressional staff here. Do we have some congressional
staff here? So I wanted to acknowledge them. Anyone? There were a couple of RSVPs. Maybe
those didn’t materialize. But, in any event, we welcome all of you to
the meeting today. Thank you, Director Cordray.
As you know, the Bureau organized the group for credit unions in 2012 for a way for us
to be able to provide feedback back on a very concrete basis to the Bureau and the Bureau
staff. It has been a great dialog session with the folks around this table and previous
folks that served on the Advisory Council. And we appreciate the Bureau’s listening ear,
as we are able to help them form policy and procedures for the industry. As you know, the Bureau regulates financial
institutions over the 10 million- 10 billion dollar mark.
But today, specifically, in the public session we are going to hear on a couple of topics
from Bureau staff. The first topic is going to be on overdrafts and the information that
is coming out on the narratives. And then, also on the consumer complaint narrative that
is on the website now. And so, we are going to be hearing from staff specifically about
those two topics, and, of course, welcome the Council members to ask questions, comments,
exactly like we have been doing all along, and feel free to interject as Bureau staff
is giving us that information. Okay. So, first off we have, let’s see here,
Gary Stein and Jesse Leary for overdrafts. Thank you both. All right. Thank you very much.
So, my name is Gary Stein. I am the Program Manager for Deposits in our Markets Group,
which is a kind of product-structured unit that sits in our Research Markets and Regulations
arm of the Bureau. And Jesse Leary who is the Section Chief in our Office of Research
is here and will, hopefully, do most of the talking this afternoon.
But I wanted to give you an update on our overdraft inquiry that we kicked in February
2012. And then, Jesse is going to give you a summary of a datapoint that we published
in July of this year, some update of the analysis on overdraft, as we continue to forge through
that. So, just to recap quickly, in February of
2012, we initiated an inquiry into overdrafts. It wasn’t a statutory requirement, like a
lot of the work that was going on at the Bureau at that time, but more a feeling that this
was probably the area of greatest interest and noise in the consumer deposits space.
And so, we kicked off a couple of major initiatives at that time. We had a Request for Information
out to all stakeholders and the general public, asking about 18 very detailed questions about
overdraft programs, how they worked, how the industry and consumers had adapted since the
Fed had made modifications to Reg E in 2010 and to Reg DD and the guidance that the other
prudential regulators had released prior to that. And then, we got back about 1100 responses,
many from individual consumers, but many from credit unions, community banks, large institutions,
vendors, trade associations, you name it, advocates. And it gave us a pretty diverse
perspective on overdraft programs, though not a scientific survey certainly of the industry
or of anybody. We also initiated at that time what we call
our Large Bank Study where we worked with several large supervised entities to really
get under the hood to understand how their programs work, not with the expectation that
every institution is like a large bank, but more because it would permit us to talk in
a very granular level about the operational aspects of these programs and how they evolved. And most of that work culminated, the first
round at least, in a White Paper that we released in June of last year. In that paper, we tried
to kind of level-set for stakeholders and describe fundamentally how these programs,
why we may see issues with high fees paid by consumers and what happens to their accounts,
and so forth, and really drew on the research that we collected through the RFI, which I
should add included a number of industry surveys conducted by trade associations and others,
as well as that Large Bank Study, the first round from that.
Since that time, we have continued to analyze and collect additional information because
in that White Paper, I think while we probably explained a lot about how these programs work,
every time I think we identified a specification or something, it triggered three or four more
questions. So, why is this; why is that? And so, we raised a number of public questions.
We didn’t feel our analysis had been completed at that time. And so, we have been hard at
work on that. One of the things that we were able to obtain,
though, as part of our Large Bank Study data request was transactional information de-identified
with no personal identifiable information, but on approximately, I think, 2 million accounts,
so that we could really observe how the combination of these program configurations and consumer
transaction patterns resulted in outcomes for consumers. And so, the datapoint we released
in July was really the first pass at the results of that.
So, I will turn it over to Jesse right now. And then, I can follow up after he is done
and give you a little bit more update on where we are on some other initiatives and where
we are headed. Great. Thanks, Gary.
Hopefully, folks will be able to see these slides as we go along here. To give a little more context, as Gary was
saying, this is based on data received from a number of large supervised banks. The datapoint
we put out in July, it is a summary of information about some key points relating to overdraft,
but it by no means reflects the breadth or the depth of the analysis that we have been
doing with this data. And I think we expect to put out additional analysis for the public
as we work through this as well. So, again, these are a set of initial findings that we
think are important to understanding overdraft, but not the full breadth.
The focus of this discussion is going to be on the relationship between opting in to overdraft
coverage on point-of-sale debit and ATM transactions and overdraft fees. The distribution across
account-holders of overdraft fee costs, typical- the characteristics of typical overdraft transactions,
and also, how long account-holders remain negative, how long the balances on accounts
remain negative after someone does overdraft. So, let me back up. So The first point about
opting into overdraft, just to make sure everyone is on the same page with what this means,
under amendments to Regulation E that the Federal Reserve Board put in place, starting
in July 2010, for a financial institution to charge a consumer an overdraft fee on an
ATM withdrawal or a point-of-sale debit card transaction, the consumer had to have first
given consent to that. So that’s called the opt-in. We have heard this as opting-in.
And the disclaimer, I’m an economist, not an attorney so, if any of what I say is not
precise legally, I apologize. But because I am an economist, not an attorney, you can’t
hold me to it. So, these are summaries of the average monthly
checking account fees per account. I apologize for the size of the font, for some of the
folks in the back. And this shows, and again, this is based on
account-level data from a number of large banks where we have detailed transaction information,
and so, are able to calculate average fees at the account level. What this shows, if you look at the first
column, an overall average for this set of fees of just under $10 per month per account,
with just a little more than half of that being overdraft and NSF fees.
If you look across to accounts that are either opted-in or not opted-in to the coverage of
debit card transactions and ATM withdrawals, you see that there is a pretty dramatic difference
in the overdraft and NSF fees that are paid, depending on whether an account is opted-in
or is not opted-in, with the overall fee level being about four times higher for accounts
that are opted-in and a much larger share of their overall fees being overdraft and
NSF fees. I should say that this isn’t simply a direct
effect of being opted-in. The difference in fees is not entirely due to  the difference
in the fees is not just the difference in fees on debit card transactions and ATM transactions.
What we see is that accounts that are opted-in tend to have more overdraft fees on all their
transactions. So, that raises the question of whether this is causal, that being opted-in
causes some sort of knock-on effect that leads to other overdraft fees or whether it’s simply
a matter of different account-holder behavior that is correlated with being opted-in or
not opted-in. And that is something that we are continuing to look at. the next slide-
and I should say, all of the folks who want to see this in detail, and either are having
trouble seeing the slides or just want to have something to take with them, all of this
is lifted directly from the datapoint that we put out in July, and that appears on the
Bureau’s website. This next slide shows how overdraft transactions
and overdraft fees are distributed across account-holders. What it shows is that, for
70 percent of the accounts that we have data on, there are no overdraft transactions over
the time period covered by the data. Or, actually, this is over a one-year period. The data covers
a full 18 months. We are looking at the last year of the data, so that we can put things
on an annualized basis. It makes it a little easier to communicate.
So, 70 percent of the accounts don’t have any overdrafts. An eighth, 12.5 percent, have
a very small number, one to three, and they pay quite a small share of the overdraft fees.
And a small share, about 8 percent, incurs 10 or more overdrafts per year. And that group
pays the majority of the fees, nearly three-quarters of the overdraft fees. Something to note about this is the number
of overdrafts includes overdrafts on which a fee is not charged. And so, that is why
you will see the average fees paid for the group with one to three fees is less than
the average cost of overdraft, simply because there are some transactions that result in
an overdraft, but for reasons related to either the type of transaction or de minimis policies,
et cetera, there is no fee charged on this transaction.
The next slide shows the same analysis broken down by accounts opted-in and accounts not
opted-in. And what we see is that, for accounts that are opted-in, only about half of them
don’t have a fee over the course of a year. So, a considerably larger share of accounts
that are opted-in had at least one fee  I’m sorry had at least one overdraft transaction
over the course of the year. And a larger share of those accounts have at least 10 overdraft
transactions over the course of the year. We still see, even with the breakdown, we
still see that the majority of fees are paid by people who have a significant number of
overdrafts. The next slide, we look at the median size
of overdraft transactions. And these are transactions on which an overdraft fee was assessed. And
what we see is that, not surprisingly, the size of the transactions differs across the
type of transaction. But for some of these types, so debit cards, which are the most
common type of transaction of these different transactions, are also the smallest, with
the median transaction size of $24. So, that means, of the debit card transactions that
lead to an overdraft fee, half of them are $24 or less. And this is, for the banks that
we are analyzing here, the median overdraft fee is $34.
Finally, we looked at how long accounts stay negative. So, this shows the distribution
of the length of time that an account stays negative after experiencing overdrafts. So, what we see here is that, for just under
30 percent of the occasions where an account is overdrawn, the next day the balance is
brought positive. The median time is three days. So, half the time following an overdraft
the account is brought positive within three days. And I believe the statistic for a week
is 75 or 80 percent. So, within a week, the majority, the solid majority of accounts have
gone positive again. The spike out at 45 days, those- a large portion
of those are accounts that have gone negative with an overdraft and are not going to become
positive again. They are going to be charged off or abandoned.
So, to summarize the key points of our first publication on the account-level data, the
overdraft fees make up the majority of the fees on consumer checking accounts. Consumers
who have opted-in for overdraft coverage of their ATM and debit card transactions have
much higher overdraft frequency and pay substantially higher overdraft costs.
The majority of overdraft fees are paid by a small share of account-holders. I should
say this is consistent with previous research, I should point out.
Many of the overdraft transactions are fairly small, especially debit card transactions,
which tend to be small in general. The debit card transactions that lead to overdrafts
are, on average, quite small. And finally, when consumers do overdraft,
they typically bring their accounts positive again within a fairly short period of time.
So, those are the findings of what we have put out so far, and we would like to invite
questions or discussion or comments on this topic.
I have a comment. I have a comment. So, the comment about a lot of overdraft transactions
are small, what proportion of the total transactions in an account is small? That is, if it is
a random sample and you have 1,000 transactions in a month, and 80 percent of those transactions
are small, then it stands to reason that 80 percent of the transactions that cause the
overdraft would be small. Do you see what I’m saying?
Sure, and I believe the distribution of transaction sizes that caused the overdrafts are similar
to the distribution of transaction sizes within each category. So, they are not unusual 
That is not really information then. That is not really information then. I mean, it
is a random distribution. Well, it’s
Is it random or not random? The implication that one might draw is that, one implication
that one might draw is that it is an impulse transaction. People don’t know what their
balance is. They are getting this fee, a $34 fee for a $20 transaction, and that’s a bad
thing. We need to do something about that. On the other hand, it might just be that I
have 100 transactions during a month. “X” percent are small. So, if I am having a problem
and I overdraft, the one that triggers it, the chance of it being small is high, right?
I wouldn’t say it is non-information. I would say it’s- in trying to understand what is
going on in overdraft, its important to know whether the transactions that lead to overdrafts
are similar or different than transactions generally.
Right, but this doesn’t give that to me unless I’ve got a distribution on what the transactions
are. Yes, that’s a useful suggestion. Thank you.
Yes. Jesse, I find your summary very fair. I think
it is worth pointing out the last bullet, though, that when consumers overdraft, they
usually bring their accounts positive quickly. The other point I would make is that, had
you pulled up that fee survey and just confined it to the credit union space, you would have
found a lot of zeroes on that. Thanks, John.
Can you remind us how the overdraft study got on your radar screen or why it was a study?
Okay. So, the concept of overdraft in general being the focus was, it is kind of multi-pronged.
I think in setting up the office for deposits, I don’t think it was hard to find out where
probably there was most noise in the marketplace about, consumer anecdotes about, and complaints
even before we started collecting complaint information and the advocates. And they would
generally raise would be about overdraft programs. So, in some ways it was kind of one that was
waiting for us, if you would, before we opened our doors. But, in addition to that, the timing, whether
or not the Bureau was created, would be really appropriate I think for any regulator to take
a look at this, in the sense that there had been over the previous decade a lot of regulatory
activity that had geared towards modifying overdraft programs, that most recently, as
I said, culminated in the Fed making a couple of regulatory changes in 2010, most notably,
to require institutions to collect a consumer’s affirmative consent before they charge a fee
on debit card and ATM transactions. And there really had been no postmortem on
that change. If you look at- and It is a little easier with banks than credit unions because
of the details in the public call reports. But, if you look at bank service charges on
deposits, you would see a huge dropoff around the time that these regulation modifications
were made. Now I don’t think we would attribute all of
that dropoff to challenges in collecting consumer overdraft fees. There was also an economic
downturn and people started spending less and things like that. But, certainly, there
is enough noise to warrant attention. The prudential regulators and I’m sorry if
I’m droning on about this, but I can just say two quick things the prudential regulators
on the banking side at least had all issued guidance that was inconsistent to some degree.
And so, there was a bit of an uneven marketplace for depository providers in terms of overdraft.
So, there was an opportunity to even that out.
There was research that said consumers were still confused. Oh, and the last point I think
that also drove to this and drove to some of the regulatory changes was just the fact
that consumer transactional patterns had been changing rapidly.
So, your question about debit cards was a great one because I think a lot of people
might have prophesized that, when overdraft first started, it was for, you know, you write
your big check for your mortgage or something, and you want to make sure that goes through
as a courtesy, which I think is very well-founded. But when consumers started using debit cards,
which are a great convenience and advancement in consumer banking, the nature of all that
changed a little bit. And so, it has been a bit of a moving target.
So, can we infer that you are going to look at potential changes in policy to treat ACH,
ATM, and debit cards differently? I think that remains to be seen a little bit.
I think one of the reasons ATM and debit cards were, and I wasn’t at the Fed at the time,
but I would rationalize back that they were picked out is because the institution has
the opportunity to authorize or decline those transactions at the time the consumer executes
them and could directly prevent a consumer from going into overdraft with no NSF fee,
which is a little different from a check or an ACH transaction, the way things generally
work right now. But I would say, to your broader question,
Robin, yes. I mean, the point we engaged in this was to determine whether any policy changes
are required. And I think we went into this with no preconceived objectives to make a
specific change. There has been court cases on posting order, among other things, were
the regulatory changes. And so, I think we have a responsibility to
have a perspective on all of those things and to determine whether or not- what types
of changes are required and how to execute them.
Gary, two things. The first is in today’s environment we don’t get a lot of thank you’s
from our members because our deposit rates are low.
mhmm But one of the things we do get letters on
from our members or calls is to thank us for clearing items through overdraft. It is one
service that we have given our members that they really like and they really want. And
we very rarely, when we do our member surveys over the year, we might get one or two saying
the fee is too high or don’t charge a fee for it, but I usually get, “Thank you. It
cleared,” or we get letters. The second point, you know, it has been regulated
over the years. So now, on everybody’s statement every month they know exactly how much they
spend on overdraft a month and how much they spend on it on a yearly basis. If a member sees that and doesn’t want to
spend for overdraft, all they need to do is call and say, “I don’t want it anymore.” You
know, it is an option that they can use or can’t use. Nobody is forcing them to use this.
And most people like it and know what the fee is associated with it.
I mean, yes, there are issues that you have with maybe people posting different ways and
trying to grab more fees than maybe they should. But everybody is aware of what they are spending
a month because they see it in front of them. And if they don’t want it, they don’t have
to have it, but most people don’t opt to cut it off.
So, if something is working and the members really like it, why is there a need to change
it? That’s a great question. So, I would say we
certainly have enough volume of noise on the other end and that others have collected for
us that suggests that not everybody feels it is working perfectly. And certainly, there
are 14,000 depository institutions. So, it would be crazy to say that there is the same
level of understanding or everything at every single institution. Certainly many of them,
I am sure many of you all in this room offer protections and things for your members that
many other institutions may not offer. And so, it is not even across the board.
One of the things that we raised in our White Paper was, okay, we tried to explain how this
works operationally. Posting order, while it has been in court cases, quickly escalates
into some complicated discussion about different types of payment systems. I mean, a checking
account, first of all, is a very powerful tool, and it is a great consumer convenience
and provides an opportunity for mobility. It allows, generally, consumers to transact
through a lot of different methods, and these methods and payment systems all operate on
different time schedules with different rules and things like that. And so, it culminates
in the institutions that offer them to have to figure out operationally how do we update
account balances for all these different transactions and in what time basis and in what order.
And as a result, there is a lot of operational decisions that institutions have to make just
in that area alone, plus others. And so, there’s a variety of different practices.
And as we go through and we see consumers, and one of the reasons we wanted to look at
this was to see how the consumer outcomes vary by all these differences in practices.
And so, that is one thing that we want to understand.
And would a consumer that does something at Bank or Credit Union A experience the same
outcome that they would at Credit Union B, and why is that difference? And could they
anticipate that? We also raised questions in our White Paper
about the level of consumer understanding about these things. To what degree do they
anticipate that, to your point on opt-in, I would agree with you there is certainly
a requirement that says consumers have to have the ability to opt back out, although
we see few consumers that do that. And so, we actually initiated some qualitative
research earlier this year that is just getting wrapped up right now, where we set out to
have in-depth interviews with close to 100 heavy and moderate overdrafters to understand
why they do the things they do. We can see what happens. We can see that consumers sometimes
overdraft a lot. We might be able to see what operational practices might contribute to
that. But we can’t, to your point, which I think
is a great one, understand why a consumer would do that and what choices do they feel
like they have. And so, that was one of the points of our research. I just want to give you one example of that.
Yes. There was a couple that were members of our
credit union who had several thousand dollars of overdraft fees a year. And we actually
sent them letters and called them because we were concerned.
They said, “It’s our marriage counselor. We both write checks and we don’t want to bother
each other or say where is the money. And we know that we are spending `X’ amount of
dollars. But you know what? We pay it back. It saves our marriage, and we don’t have to
worry about it. Thank you very much.” And they knew exactly what they were spending,
but that is the way they financed their money. I mean, we brought it to their attention. So, there’s many different ways why people
use it. It’s their money and we let them know what they were spending. And they said, “Hey,
we know.” I would urge you, as you go through the research,
that is 100 interviews; people don’t necessarily self-disclose.
Yes, right. Because what we have found, we have a petty
lending program and overdraft privilege, and members love it and all that. And what we
find, when we find what we call the abusers, and we call them like you call them and talk
to them about what’s going on, you know, there’s lots of behaviors that are going on and, for
want of a better word, psychological profiles. So, we have had very fluent people and say,
“Three thousand dollars worth of overdrafts. What’s going on here? You know, you’re a smart
businessman. You have multiple businesses.” “Don’t bother me. This is just the way I do
it,” essentially, was what he was saying. So, I think that research is great. I am very
encouraged that you are doing that kind of research. Continue to do it, so you will understand
what that consumer is. We live it every day. So, we know these consumers very well.
One research project, 100 people, that’s not a lot. And plus, the self-disclosure problem
is a real one. Yes. No, I would agree on both counts. We
have had some other outside parties provide consumer research to us, and we have other
data to draw from. But I would agree. I mean, there is a lot of  there’s always stones
to unturn. And your point on consumer acknowledgment,
I would say we wholeheartedly agree with that. In fact, I think it is a challenge in a lot
of the issues that we, the Bureau, addressed. In these types of things, one, will they admit
what they are doing? And two, when confronted with an opportunity to change, how realistic
might they be about whether they are going to do it again? And those are difficult things
to wrap into policy considerations. Two points
Yes. if I may? The first is that the statistics,
if nothing else, show that what the Fed put into place in 2010 is working; certainly,
the overabundance of transactions by people who have chosen to opt-in. So, I think it
is fair to draw the conclusion that those who are being charged for overdraft are aware
of the fact that they are being charged and that they are happy with the program. Otherwise,
they would not have chosen to opt-in or, otherwise, may have chosen to opt-out. I think the second thing that needs to be
noted is that the world of payments is significantly changing. And to differentiate between a check
and ACH and a debit, five years ago it may have made a lot of sense. But I think in 2014,
bordering on 2015, we are coming to a system where all of those things are blurring.
Years ago, if you went into a supermarket, you paid the transaction in either cash or
you walked in and wrote a check. mmhm.
And you wrote a check for something that was a necessity for you at that moment in time.
How many people write a check in a supermarket in the fourth quarter of 2014? The mechanism
of choice is the debit card, at least from what I see.
So, by looking at a check one way and looking at a debit card transaction another way, you
are kind of discriminating against the trends of society in the ways the members are starting
to use to access their money. We just urge that you be careful that we are
using 2014-2015 banking habits as opposed to thinking that we are back 10 or 11 years
ago, because we are not. And even if a member writes a check, they
are just as likely to hand a check back to the member and treat it as an electronic check.
And we used to offer a product. We deal with a lot of members who have never had a checking
account before and who are having difficulty managing from day-to-day, week-to-week. We
used to offer a product for 25 years called courtesy call, and we would call the member
by 5:00 one day and give them until 1:00 p.m. the next day to make good on a check. But now, we can’t do that. The processing
times have changed. We don’t have the discretion to turn back an ACH or an electronic check.
We can do it instantly, but we don’t have any wait time. So, we have had to go to other
mechanisms, including the courtesy pay, instead of the courtesy call.
Gary, I have a question for you. Do you all have any data as it relates to how many of
these accounts that remain overdrawn for 45 days fall off and are actually charged off,
and then, those members or those customers no longer have access to, say, mainline financial
services? And they become the unbanked. We do have information on whether the account
is closed with that institution. We don’t have information on what happens with that
consumer afterwards. We don’t know, we don’t serve we aren’t able to follow the consumer.
The data we are working with came from the banks. It appeared to me that about 3 percent of
those transactions, just looking at your graphic, possibly would end up in that plight. And
so, that 3 percent could equate to quite a number of consumers. And so, from my experience
in the market, some of where the objections come from as far as overdraft programs in
general are concerned is that there are a group of consumers who don’t really understand
that much of what is happening. They like the idea that this month their checks are
going to be covered, but they cannot afford the overdrawn account. And when their direct
deposit or their Social Security check hits, it fills that hole, but it gives them nothing
to live on. So, it puts them in a spiral of negative activity
because next month they are going to start paying bills, and every one of their checks
or debit cards, or whatever the transaction might be, will end up costing them.
So, I think that should probably be something that would be considered in whatever rules
would come out of this study. And I have got to thank Helen for the plug
lead-in there. Because, actually, next Wednesday the Bureau is going to be hosting a forum
on checking account access and screening, and looking at this ecosystem and the cycle
that happens to consumers, how institutions determine when and when not to offer a checking
account to an applicant, the information they use. And then, how they report back on consumer
activity. And Helen has graciously agreed to serve as
a panel moderator in that event. So, I appreciate the plug and the comment there.
But I think it is an excellent question and one that I think we will spend a lot of time
talking about next week. Gary, as part of your research, did you get
down into the weeds as to who uses overdrafts; i.e., annual household income, any kind of
ethnic, racial, social, economic background? Because I know maybe the stereotype is the
folks that are being abused are poverty and below. And, in fact, you may find that it
is actually higher-income individuals who are using this as a safety-net feature or
part of how, as Mitch said, save their marriage, whatever the case may be.
And you may not have the answer to that, which is fine. But, if you haven’t asked that question,
I would. Secondly, in this, was there a study on the
median merchant fee for a returned item? Because that is important because that is what the
consumer is not having to face when we cover their overdraft or a financial institution
covers that overdraft transaction. So, that is an economic benefit, also a convenience
issue, but it is also an economic benefit because they are not having now to face the
merchant. You know, I struggled when my credit union
implemented courtesy pay, which is enhanced overdraft protection, until I had a member
come to me and say, “Because you offered this, and I was two days short of payday, and I
was able to get formula for my baby. So, paying the fee was not a problem for me.” Okay? That
opened my eyes. But, by the same token, it opened my eyes
to those who abuse it, okay, to where, like Kevin and others have said, we pull those
members aside to find out what’s wrong. And we will put them in financial counseling,
free of charge to the member. We will pay for that to help them get their account straightened
out, but they have to do that voluntarily. I can’t make them do that.
Because I have had members say, “I know what I’m paying. You don’t have a problem with
me. Okay?” So, those are things that won’t necessarily
come out of the study, but there are abuses, but it is not the evil instrument that I think
maybe it has been puffed up to be, so to speak. Thank you, Jim.
I would like to talk about, and I know many credit unions do this as well, but we have
had a practice in our credit union for many years that we do courtesy calls for deposits.
So, our branches know these numbers very well. And so, every morning there is a list distributed
of members that have overdrafted, and we give them a courtesy call. Nowadays we send them
a text as well. And they have until five o’clock that day to make a deposit, and we will not
charge them that overdraft fee. Now you know that that costs the credit union
money to keep that negative balance, but we believe that we are providing a service. And
members have a choice, and I think we have said it around this room. We all probably
do financial counseling. We have done that as well. We have helped members that want
to get out of that ODP situation and give them a small dollar loan to pay back over
time, so that they can opt-out. There’s been very few, but we do offer that service.
So, we are trying to be as proactive as possible and still giving members a choice to handle
their ODP. I just want to make one point which hasn’t
been brought up yet. It is, for most people, courtesy pay is a tertiary way of paying a
charge. Because we would overdraft first free from a savings account, and then, we offer
a line of credit, which we overdraft for free as well.
So, you have two options with our credit union to overdraft without paying anything. It is
only when those two don’t have anything available does courtesy pay hit in, and then, a fee
is charged. And we let people know. I mean, on everything
we send out it will say, “Remember, you can also use your savings account and a line of
credit to cover overdrafts for no fee.” So, there are alternatives to using courtesy
pay and having to pay a fee to pay for your overdrafts.
But I would like to just ask, what is going to happen if you prohibit us or make it more
difficult for us to offer this program? You know, how are our members going to get cash
that they desperately need? Have you thought about what those alternatives are going to
be and where they are going to go? My credit union is a CDFI. Many of our, you
know, two days before payday overdrafts are “I’m at the gas station, I’m at QT and I need
gas.” We literally sometimes have people calling us to make sure that they can get money out
of their debit card. So, their ability is to do that. And some of that is because, as you may or
may not know, at a gas station, and especially QT, if you go in there, they may put a $50
hold on there to make sure that that clears. So, if they are running very lean and mean
in their checking account, that $50 hold plus the 24 bucks that they need for their gas
is going to cause them to overdraft. So, thoughts, also, of where would our members
go; how are they going to be serviced? And some of the alternatives that are out there
aren’t very pretty. So, food for thought. Tagging off of that, is there any data that
says where this money, where these debit transactions are taking place, what percentage is for food,
what percentage is for gas, things that are necessities to life?
So, first of all, I like all the questions, and I like that you don’t let us answer them. So, this is a great session. I’m sorry there
was a pause right there. So, I will just answer that last one first.
The data that we have, because we don’t have any personally-identifiable information, unfortunately,
things like those merchant codes, we can’t see that. We have seen analysis that others
have conducted. And as you might expect, it is generally quite
different if it is happening with a debit card than with a check or an ACH type of payment.
As Jesse indicated with the research, those transactions, whether they are causing an
overdraft or not, tend to be very different. They are used for different purposes, even
in some cases where those lines are starting to blur a little bit, but they are still quite
different. So, I would just say that, with regard to
how overdraft is used, the benefits of overdraft, and the consumers’ alternatives, those are
all things that we need to be cognizant of; we need to be thinking about as we are doing
the research and thinking about what good policy would be I this area.
And so, things like transactions that are able to go through that either allow someone
to make a purchase that is a very, very high value to them in a moment or allows them to
avoid having an NSF situation, certainly the things that we are thinking about trying to
do our best to understand and incorporate into the thinking.
Do we have any other questions? Jason?
Yes, these are all great comments that people have made. It is all about unintended consequences. Another unintended consequence from changing
the overdraft programs as they sit today is our bottom lines. As credit unions, the only
way we can grow in our equity position is through earnings. We already naturally have
a small or thinner margin. Taking away a fee product is going to add a larger disparate
impact on credit unions as opposed to a larger financial institution that has a lot broader
way of making revenue. So, that is just another one of those unintended
consequences that we have to look at from not just credit unions. I think mutual savings
banks are probably set up the same way. So, we need to think about all of those.
I just had one sort of research question again. I apologize for that. But it gets to some of the comments we have
been making here. One of the things I think that, from a policy perspective, is a natural
tendency is to look at a discrete product at a discrete point in time. The products
we have all been talking about are cash management products that are for usually a month period
or what the pay period is. And so, perhaps at some future time you can
look at that relationship of what is going on over a period of time, rather than at a
discrete product or a discrete point, because, then, you may get some understanding about
what is happening that will inform your policy decisions, if that makes any sense.
Maybe. Maybe sometime in the future. The cash management go ahead.
Do you mean looking at what is going on over the course of the pay cycles or the course
of the monthly expense cycle  Yes.
and trying to see when overdrafts are occurring? Yes. Yes, that is something we are interested in.
We have tried to identify pay cycles. There are some people where you can look at their
transaction data and see the pay cycle with other
The issue is you refer to the difference between overdrafts with checks and overdrafts with
debit, and you see a difference. That difference may just be a function of the way the individual
is monitoring their cash management strategy. And they pull it right up to the edge, and
it is at the edge where overdrafts start kicking in, but they have taken care of the big, you
know, in some cases things. So, you wouldn’t know what is going on unless you looked at
a period, rather than just a discrete point or a discrete product, because they are using
lots of products. If you talk to a consumer, they are using
lots of products to keep their house together when they are in the situation. And so, I
think it might mislead you in terms of a policy decision by not looking at a bigger picture.
That’s all. You probably don’t have the resources to do that, but just if you ever do.
Okay. And just from my experience with my members,
what my members need to help manage their cash better are better jobs with higher pay.
If I could just have a little bit of a contrarian view, we never did courtesy pay. We lent probably
$40 million in income before Dodd-Frank required it. And it did not harm our financial position.
You learn not to rely on that type of income. And I applaud you for recognizing the change
in the transaction set. And some of it is societal. The use of debit cards is obviously
a much higher usage. But I ask a lot of my members, especially
young members, if they had a buggy full of product at the grocery store or Home Depot,
would they rather that the clerk turn down the transaction or that they pay $25, $29,
and let the transaction go through. And I get a variety, but I will say more and more
young people actually would prefer that we turn down the transaction.
And I think that is because  and I always underestimate the number of transactions.
I always say, well, how many would use it more than 10 times, a debit transaction more
than 10 times a week? And they laugh in my face because they are using it, I think your
report showed 17. So, some are using it 20; some are using it 30, which also means they
are not tracking their balances very well. I mean, we used to actually enter it into
our check registers, and they laugh at that. So, I applaud the fact that you are looking
at the change in the dynamics, but they seem to have a handle on the fact that they are
prepared to have us turn it down, in which case they would opt-out. They would say, “I
don’t want you to do that.” And then, there are some that do.
So, I don’t know if you are headed towards an additional disclosure requirement or a
programmatic requirement, but I do think that the dynamics of the market are changing. We
are here to improve our members’ lives. And so, I certainly, as one member of the Council,
would not oppose continued education and disclosure as the product set and the usage evolves.
So, I appreciate the study. Bob, did you have a comment?
One last question, an easy one. What percent of members or I’m sorry, not members respondents
to the survey opted-in and opted-out overall? Oh, you mean the interviews that we conducted?
You know, I don’t have that figure off the top of my head.
To Kevin’s point earlier, you know, sometimes consumers don’t always you have to kind of
tease some of this information out of them. We couldn’t look at their account information
or anything like that. That might be intrusive. We tried to understand by asking them how
they have overdrawn and things like that. You categorized them into opted-in or opted-out?
For the study, as best we could. But, again, we couldn’t verify their account information.
We could talk about the histories and stuff like that. What we did find in the White Paper and I
think I remember having this conversation with this Council a year ago is that we saw
that these opt-in rates vary considerably by institution.
And I think there was a member on this Council I told this story, if it was this that had
a 95-percent opt-in rate, but that only charged a $5 overdraft fee, which I thought was 
did that make sense? Perhaps. But we see these rates anywhere from the single digits to the
80 to 90 percent range, and it varies quite a bit.
But I think as Marcus and other people here have made the comments on the transactions,
you know, you have people, like you say, that use their debit card a lot. And when they
use it, they generally use it a lot. It is every little thing. They don’t carry any cash.
They don’t write anything. So, every $2 purchase, every $10 purchase, you know, would be one.
Whereas, if you carried cash, you might have one ATM transaction in a week, you know, and
then, you pay everything out of that, theoretically. And the former gives you a lot of theoretical
opportunities to overdraft. The latter would only give you one because the banks only see
one and the credit unions only see one. So, those behavioral patterns definitely come
into play, as well as the consumer choices. Just to clarify, the results I was showing
today come from analysis of account data, where we do know the opt-in status. And I
think, for the study banks, it is in the high teens of the account-holders are opted-in.
For the consumer interview research that Gary was referring to, yes, he was saying we don’t
know offhand what share of consumers there would say they are opted-in. I think one thing
that has been found in some survey work that has been done by others is that, if you ask
people, they often don’t know whether they are opted-in or not. So, just to summarize some of the discussion
by the way, this is typical excellent discussion from this Council within an hour, you have
surfaced some of the major issues that we are grappling with, including how do these
products actually work; how are they evolving in tandem with payment products, evolving
over time? What are the alternatives to these products? What are the benefits of these products,
and how are they actually used by consumers as opposed to just the cost numbers and the
like? We have not settled on any particular policy
judgment yet. So, this discussion is quite timely. We try to make these discussions timely.
As you can see from Gary’s and Jesse’s presentation, there is quite a bit of analysis being done,
and we are trying to wrestle through that. And there were a lot of good suggestions today
about other vantage points we might take on some of that. Going back to your original question, Rose,
as to why we again look at this in the first place, I think Gary laid that out pretty well.
I mean, this is, when you look at deposit accounts, which are one of the markets we
look at, this is the biggest driver of fee income on deposit accounts. So, it is something
worth looking at and understanding and knowing about.
There is also the fact, as Gary noted, that a guidance on this issue to this day, at this
moment, is inconsistent among the regulators, which is never a very happy place to land.
And so, it certainly seemed that re-looking at that, now that we have one Bureau that
can cut across banks and credit unions and thrifts, and even non-banks, though that is
less relevant to a product like this, we are looking at a variety of cash management products,
including overdraft, small dollar loans, prepaid cards, and trying to think about this somewhat
holistically. But the other thing I would say is the experience
that some of you have laid out in terms of your institutions today is in many ways maybe
considerably different from some of the larger institutions.
One thing we have seen as we have examined larger institutions is you see and it is not
simply in this market; it is a variety of markets where one of the dynamics that can
emerge is that there are third-party vendors and others who come to the institutions with
various plans and sales promotions. “I can get you more revenue if you do” X or
Y, which is always of some interest. In your for-profit business, you’ve got to pay attention
to those things. What we are trying to emphasize is, when that
happens, you need to think carefully about what you are doing to consumers and are you
treating them fairly, and there may be costs that you don’t see upfront that are going
to come down the road. The other indicators here for us have been
a fair amount of litigation, particularly over the transaction reordering, which one
of the revenue-enhancing techniques that vendors took to certain institutions. And in some
of those areas, more consumer confusion than you are indicating you are having at some
of your institutions. So, these are all fair points, things for
us to be thinking about, thinking about pretty carefully, all of which will lead us to decide
what to do here, if anything. I think I have already said and I will say
it again – you know, this courtesy product, this is not something the Consumer Bureau
will be looking to ban. There may be some aspects of it that are problematic, some ways
in which it has been executed that are problematic. We will look at those things. But overdraft has been a product that is useful
in many ways for a lot of consumers. But, again, for us to understand how this work,
and even the opt-in requirement that the Fed imposed in 2010, we have been interested to
see how that may play out differently at different institutions. And it can play out very differently
in terms of how you market around whether your consumers opt-in or opt-out. So, that
is another piece of this that we are interested in.
But it is a good subject for us. It is a fair subject. It does fairly quickly lead to a
lot of questions and analytical considerations. As you can see, our folks are very carefully
working it through in what I regard as a very intelligent way, but we are not at the end
of that process yet. Thank you, Director Cordray. Gary and Jesse, we certainly respect the work
that you are doing, very much so. I thought it was a great dialog. We could probably go
on for a long time on this subject. It’s pretty passionate, as you can see. But
I’m sure many of us would invite and welcome you to study our programs in credit unions
and how we get to the ODP program, because you may find that there are very vast differences
between us and the other guys. So, again, thank you so much for the work.
We look forward to more information coming out. And if you could get into some credit
unions and see how we do it, I think we would very much appreciate that. Let me add, too, that some of you were reacting
sort of off the top of your head to a presentation you just saw today. For all of you who are
interested or your staffs or others or your colleagues, have them go back, take a look
at the White Paper, think about it. You know, give us more developed thoughts, as you have
them. Some of you may have already done that, I’m aware.
And anybody out there paying attention to the meeting or thinking about it and interested
in this subject, we are keen to hear from people about different vantage points, different
perspectives, different thoughts. We want to feel that we have covered the waterfront
and thought things through in dealing with these types of issues.
Yes, we welcome any invitations. We would be glad to come down and visit you. All right.
Yes, yes. Excellent. We won’t let you go.
Well, thank you all. We appreciate it. So, to dovetail off of this discussion, we
are going to now have Scott Pluta, who is going to talk to us about the initiative on
the consumer complaint side and the proposal that is coming forth. And I’m sure that there
is going to be a lot of discussion on this front as well.
Thank you, Scott. Okay. Okay, perfect.
Is the deck ready to go? Can people see the deck, and do they have materials in front
of them? Okay, everyone can see it. Good. So, good afternoon, everyone. Nice to see
some of you again. I know we had orientation yesterday and we chatted.
I was on my walking up here, and a member of my staff asked me why I was dressed like
a government bureaucrat. And so, I nailed it, apparently. So, thank you to my staff. So, I am here this afternoon to talk a little
bit about a proposed policy that my office and the Bureau is putting forward. And it
relates to a piece of the function that my office does.
Some of the folks, again, in the room heard a little bit about this yesterday. So, some
of it will be rehashed, and is going to get into it in much better detailed.
And then, also, at the front-end, for those who weren’t in the orientation yesterday,
I thought it was really important to make sure that I provide some grounding my what
my office does and what that looks like before launching into an expansion of part of the
operation. So, the first piece, just to ground everyone
in what my office does. I run the Office of Consumer Response. We do three things. We
answer questions, we handle complaints, and we share data. On the answering questions side, it is broken
into two pieces. We have a call center and we have an online presence. So, the call center,
we actually have two call centers. We have got one in Iowa and one in New Mexico. They
are open from 8:00 a.m. to 8:00 p.m. every day Monday through Friday, except holidays.
And you can call; anyone in the U.S. can call and they can ask questions. “What is APR?”
“Can a bank do this?” “How do overdraft fees work?” “I see that you did an enforcement
action today. How does that impact me?” So, you can go and you can pick up the phone
and you can call or you can go online. We have a product that we partner with Consumer
Education Engagement called “Ask CFPB”. And the same exact content that is available through
the phone is available online. The second thing that we do is we handle complaints.
So, we talked about this yesterday a little bit. You know, everyone in this room has credit
cards, student loans, mortgages, credit lines, or credit reports. Sometimes things go wrong;
things go off the rails. And you call the company. The vast majority
of the folks who have issues with their financial products and services, they will call the
company. Under the survey work that we have done, we
know that 85 percent of the people that come to us have already gone to the company. I
was on a webinar about a year ago that American Banker put on. There was a gentleman from
Deloitte there. He had conducted a study, and what he found was that, on average, every
time a consumer comes to the Bureau, they had already gone to the company on that specific
issue, on average, three times. So, in the first instance, things happen.
The people generally go to the company and try to resolve them. The vast majority of
the time that issue gets resolved at the company level. There are, however, times when the consumer
goes to the company; they feel like something is wrong. And the company decides, for whatever
reason, that it is not going to get fixed. At that point, historically, the consumer
is kind of stuck. There are a few avenues they can take. They can write their Congressmen.
They can go onto social media. Potentially, they can hire a lawyer, to the extent they
have a private right of action. But, really, at the end of day, the vast majority of cases,
the consumer basically has to just deal with that issue themselves. Well, Dodd-Frank, one of the statutory charges
the Bureau has is to collect and monitor and respond to consumer complaints. So now, the
consumer has an additional avenue that they can go to if they truly believe that there
is something wrong with the interaction that they had with the company, and the Bureau,
as the regulator of these financial institutions, can get a response for them.
So, the third thing we do is, you know, the answering-the-questions piece and the handling-the-complaints
piece, which leads into the analyze and share data. So, each of those things generates an
awful lot of data for us. Each and every contact we have with the American
consumer, the Director often talks about this mosaic effect; that is, each and every one
of these is a pixel in that mosaic. And the more pixels we have, the more clearer picture
we have of what is going on in real-time in the consumer financial marketplace in the
United States. So, just lots of data. The picture that we
have forming is getting better and better. The sharing-data piece is, as that picture
gets better, we have the ability to share our insights, share that picture with partners
we have both inside and outside the building. So, I will get into some of the specifics
a little later. But, outside the building, for the first time
ever at the state or federal level, the Bureau shares individual-level complaint data. And
I will show you a visualization of that later. We also share data with our government partners.
So, right now, we have a tool called the Government Portal. On that, government agencies and AGs
can sign up, and we will share with them the complaint data that we have for them in their
jurisdiction. So, to the extent that we get a complaint
and it may implicate some type of state law issue, they have the ability to go in and
get a more fulsome picture of what is going on in their jurisdiction. We have partners inside the building that
we share data with. So, Rules, Markets, and Research. We have partners in SEFL, Supervision
Enforcement/Fair Lending; Consumer Education Engagement. We share with all those parties.
Frankly, our principal consumer data inside the building is Supervision Enforcement and
Fair Lending. So, Supervision has finite resources. They can’t be in all banks at all times. They
have to make choices about who they go and examine. Part of their process to prioritize
who they go talk to overlies on our complaint data. So, it is very important there.
Obviously, to the extent some enforcement actions, potentially their genesis is in complaint
data that we receive, that bears itself out. And then, of course, Fair Lending on both
fronts. So, moving on to the next slide, as you can
see from our mission statement, the three things that we do is embedded upfront. And
then, obviously, the reason that we do those things, which is to level the playing field
and empower consumers to take more control over their financial lives.
So, a very important question: what is a complaint? I try as much as possible to get outside D.C.
and meet with credit unions and meet with banks and talk to them about how they handle
feedback, how they handle complaints. One of the first questions I always ask is,
“Well, how do you define a complaint?” Some have very narrow definitions; some have very
broad definitions. Our definition is based on the OCC’s definition. So, to the extent
folks are familiar with that, but it is a fairly-broad definition, and folks can read
it. But, in essence, it is an expression of dissatisfaction with a product or service
over which we have jurisdiction over a financial institution over which we have jurisdiction. The complaint process, just very quickly,
it is somewhat unique. So, when I first arrived at the Bureau about three and a half years
ago and we did some research to figure out, well, what would our complaint-handling process
look like, we looked at the prudential regulators, we looked at NCUA, we looked at OCC, the FTC,
the Fed, FDIC. We looked at the private sector. We went and
met with eBay and a bunch of companies like that to see, okay, well, how does the private
sector do this? And then, we made some decisions about process
and staffing, et cetera. So, our process is in some ways a hybrid. We always knew that
we would have very high complaint volumes. I know these are numbers are slightly dated. But, in 2011, the NCUA, the Fed, FDIC, and
the OCC, respectively, had 3, 6, 9, and I think 70 thousand complaints. This year we
are trending towards 275 to 300 thousand complaints. Last year it was in the hundreds of thousands
of complaints or 100,000 complaints, 150 I think. The year before that it was about 70.
We anticipate, based on the modeling that we have done, that we will probably end somewhere
between half a million and a million complaints coming in the door every year. I expect to
get there probably in the next three to five years.
One of the indicators that we look at to do that modeling, our partners in CE have done
a study on brand recognition. What they found was that the CFPB’s unaided brand recognition
is zero percent. It is not that it is literally zero; it just rounds down to zero, and that
is without any kind of aiding. So, we know that a lot of folks out there
don’t know the services that we can provide. As the CFPB’s name gets out there more and
more, it is not that we are trying to drive volume; it is that kind of one of our mantras
is that citizens in this country shouldn’t have access to services simply because they
don’t know about them. And so, we want people to be in a position
where, if they want to use our services it is not that they have to or we are trying
to get them to but they have that as an option in their toolkit, as they are navigating their
financial life. So, thinking about the complaint process that
we have, again, it is a hybrid between a high-volume, low-touch model, which is what the FTC has
they simply collect data; they are very upfront about it, and they make it available through
FTC Sentinel and a kind of low-volume, higher-touch model, which the prudential regulators have
adopted. So, the front-end is fairly automated, and
then, the back-end is the kind of high-touch piece. So, it begins with complaint intake.
So, consumers can submit complaints to us on a range of products, which we will get
to in a second. They can do so through the mail. They can do so through the web, which
is about 50 percent of our intake. They can do fax, which I am surprised that people still
use fax machines. They can get it through referral. So, other
regulators get complaints for us, and they refer it over to us. It is about, I think,
25 percent of our volume. And then, lastly, through phone. About 10
percent of our complaints come through the phone channel. I mentioned this yesterday.
As we were thinking about making the phone channel available it is a very expensive channel.
Folks in this room that run call centers know that every minute on the phone is our dollars. But, when we look at the FCC’s broadband penetration
study on who has access to broadband, we saw that a lot of our wheelhouse constituency
is minorities, poor, elderly, uneducated, rural. So, they don’t have access to broadband
as much as kind of others do. So, having an open phone channel, very important to us.
So, we intake the complaint. We have an intake staff. They look at it. They say, is this
a duplicate? If it is, we merge it into another record. Is this something we have jurisdiction
over? For example, if this is flood insurance, that is something the FDIC covers. We send
it to them. And then, lastly, does this have all the elements
required that we need to process this as a complaint? For example, does it have a bank?
Does it have the person’s name, contact info, things like that?
If all those conditions are met, we then send it, automated as much as possible frankly,
half our cases get auto-routed; we are trying to become much more efficient in that space
over to the company. So, we have got about 3500 companies signed
up right now on our secure web channel. So, you know, the perfect scenario is someone
submits a complaint over the web. Our auto-routing picks it up, and within seconds, it gets sent
to the institution. The institution, in the third box, has the
company response piece. There are statutory obligations with respect to response. They
have to do so in a timely manner. 1034(b) of the Dodd-Frank Act has some requirements
for those responses. What have you done thus far? What do you plan on doing? And what communications
have you had thus far with the consumer? So, they do that. They have got 15 days to
provide a substantive response. They have 60 to close. So, it is all very regimented. Most of the products, they close relatively
quickly. So, for example, a credit card is usually closed within two or three days. Some
of the products such as mortgage, which is an international money transfer, can be much
more drawn-out, either because of documentation or cycle times. And that can get to the 15-day
mark. They ask for an extension. They get up to 60 days.
When they close a complaint, they put it into one of four buckets to get some structured
data out of it, so we can share it through the public database, which we will get to
in a second. Was it closed with monetary relief? Was it closed with non-monetary relief? Was
it closed with explanation or was it just closed?
The Bureau doesn’t pass any judgment whatsoever on any of those four buckets. So, we are not
advocating on behalf of the consumer for credit unions or banks or non-banks to provide customer
service gestures. We are simply collecting structured data at that point on how the case
was closed, if the complaint was closed. From that point, once it gets closed by the
company, it goes to the consumer. So, we allow the consumer to provide some feedback to us
on how the complaint-handling experience was. Are you satisfied, essentially, with the response
you have gotten from the company? At that point, for all intents and purposes,
the consumer-facing piece of our complaint-handling process is done. You can see that a lot of
it is automated. Obviously, there are a lot of exceptions and there is some human-touch
work that has to go into there. But, in order to scale to a half a million to a million
complaints, that first piece has to be, frankly, highly-automated, minimizing exceptions. Then, we moving into the last two pieces of
the complaint process, they are less linear than they suggest on the slide. The review
and investigations piece, so some element of my staff all day every day they are tearing
through complaints, looking for legal violations. Obviously, when they find things, whether
they are technical legal violations like TILA RESPA or things that drift into the UDAP territory,
those are, then, bundled and packaged and handed over to Supervision Enforcement for
lending, like I talked before. And then, they analyze and report. So, those
two things are commingled. And obviously, the public database piece, which I will get
to in a second. So, these are the complaints that we accept
right now. You can see we did so in a rolled-out fashion. We started with credit card. It was
the simplest product to start with. You know, 90 percent of the waterfront is covered by
institutions. The transactions are fairly easy to sort out. And so, we started with
that. We moved into the balance of the non-bank
products. So, we moved to mortgages, bank accounts, et cetera. And then, at some point,
we transitioned to the non-bank things that we cover. So, you can see credit reporting,
money transfers, debt collection, pay to lending. In July, we launched prepaid cards and a few
other things. The fact is that, as financial innovation continues into the future, we will
continue to roll out new products. So, you can see there virtual currency came
out in October 2014. Think virtual currency; you are thinking things like Bitcoin. I think
we have probably gotten a very, very, very, very low volume of Bitcoin complaints this
far. But, as we move into this world you know,
today eBay announced that they were spinning off PayPal. You’ve got the Apple payment issue.
As you move into that kind of innovative space, I assume we are going to continue to see new
products pop up. And obviously, then, we will have to start doing complaint intake for those
products. You can see at the bottom we have handled
north of 400,000 complaints this far. So, to give you an idea of what we are seeing,
how it falls against product, and also the channels I mentioned some of these numbers
earlier the web is the biggest channel, and then, referral; phone is 10 percent. You can
see the breakdown. Mortgage for a long time was our No. 1 issue. As non-big products have
come into the scene, those have started to take bigger pieces of the pie. You can see
debt collection is obviously a very big pieces, and credit card and credit reporting, big
pieces. I would anticipate, kind of moving into the
future, that mortgage will probably shrink as a share of the pie and you will see probably
debt collection and credit reporting get to be bigger pieces. So, how do consumers interact with us? Here’s
our home page, which I talked about yesterday. I think it is one, if not the best, web pages
in the federal government. Our phone number is in the upper righthand corner. You can
call that, and you can get to the contact center, which I mentioned.
Some of the headlines there, if you click on “Get Assistance,” you can go to the “Ask
CFPB” product and go into the knowledge base. And then, on the right there, you see “Submit
a Complaint.” So, very easy to get in touch with us.
So, here is a visualization of the public database, which we will talk about in a second.
It is, as I said yesterday, kind of beautiful in its simplicity and transparency. In essence,
it is an Excel spreadsheet. So, running down, each row represents an individual complaint,
an individual consumer that has come to us. And then, you can see the various data fields
running to the right. I think there is somewhere between 13 and 15 now. So, product, sub-product,
issue, sub-issue, the day we received it, the day we sent it to the bank. You know,
that is an efficiency metric that we measure our self on. And over time, you will have
seen that come down. The name of the institution is there, whether
or not they net their 15- or 60-day statutory obligation with respect to a response; the
zip code, to the extent that people want to crunch data based on geography.
And then, I think “Dispute” is another column, which is whether or not at the end of the
day the consumer provided feedback indicating to us that they want to in some way dispute
the resolution of the company or the response. So, what we will talk about in a second is
and you can imagine visually  there would be an additional column. So, at the end of
these columns, there would be one more column. And that would be or I guess a couple of columns
a narrative provided by the consumer and, then, a narrative provided by the company
in response. So, I am going to intervene here to say two
things. We are now going to get to the issue of consumer complaint narratives. But I want
to just stress one thing, and Scott, it is awkward for him to say it.
You can imagine that, when we opened our doors back in July of 2011, very understaffed and
very preliminary in terms of anything we were doing, this whole consumer complaint function
that was mandated by Congress for us to handle was a pretty daunting task. And we had no
idea what the volumes would be, and the difficulty in actually handling this, and handling it
well, loomed large. Scott’s team, the Consumer Response Group,
about 150-odd now, has been one of the highest-performing teams at the Bureau. You can see how thoughtful
and well-put-together this process has been, drawing on the best we could find in the public
and private sectors, and going beyond it in many ways.
It has become central to the Bureau because we do and we make no bones about it it is
very public that we look at complaints. And when there were just a few and they were only
in a few areas, it wasn’t very helpful. But now that we get many across the board, it
influences our choices about what to do in our enforcement actions, our supervisory work,
our regulatory work. And so, it behooves and we stress this all
the time industry out there to pay attention themselves to our complaints. That is part
of the beauty of having a public complaint database. They can see what we see, and they
can act accordingly. They don’t have to wait on us and they can fix problems. So, it has
become very central to the Bureau. The other thing I wanted to just ground here
for the members of the Council is all of what we are describing with respect to the credit
unions on this panel is hypothetical with respect to you because none of you are within
our jurisdiction of having $10 billion in assets or more.
So, the complaints that we might receive with respect to any of you, we would pass on, I
guess, to NCUA. So, everything we are talking about here is hypothetical and not actual
with respect to you all. Nonetheless, we will be interested in your feedback and thoughts
about it as we move on to the complaint narratives, which is a policy decision in front of us
at the moment, whether you have insight or thoughts about it. But I just wanted to make
that clear. To the extent you were sitting there worrying about how this affects you,
in fact, it doesn’t. So, thank you.
But you can still pay attention. Yes. You can still pay attention to the complaints
you see, so that you can make sure you’re not having those problems yourselves, which
is a great educative function of this whole project.
That is hard to follow. And the Director raises a good point, and
I should have said that from the outset. Again, very clear, this is pointed towards institutions
with assets of $10 billion or greater or the non-banks.
So, this is actually what is in the consumer complaint database. You will see not every
product is in there right now. The virtual currency, and the prepaid, and other, those
aren’t in yet. What we like to do is launch the product, wait 90 to 120 days, make sure
that the data that we are getting in the door is appropriate for publication as a product.
And then, once we decide, yes, everything is functioning as we thought, then we publish
that. So, at some point before the end of the year,
we will be releasing the complaints that we have on our most releases.
So now, at this point, to pivot to the proposed policy that the Bureau announced in mid-July,
I think we will walk through a little bit. And then, I will turn it over. I think we
will get some feedback, and I will also make myself available. And obviously, the Director
will answer questions now on the policy. So, as you can see on this slide in front
of you, very technical and I can’t really read it because of the light so the Bureau
published a notice in mid-July about expanding the database that I showed you. There is the
title, the docket number, and the comment period, which closed about a week ago Monday. The proposed policy would supplement the Bureau’s
existing policy statements establishing and expanding the consumer complaint database.
So, consumers who submit a complaint will be given the opportunity to give consent to
the Bureau to publish his or her complaint narrative. So, again, very, very, very important
to us. You know, two of the big issues that we wrestled
with inside the Bureau before we even proposed the policy were reputational risk, harm to
the institution, and the consumer privacy piece. The consumer privacy piece, we feel
very strongly that this first bullet goes directly to that issue, which is asking the
consumer if they want to opt-in. Obviously, a lot of people in here know about
the power of default. So, the default is typically what folks go with. So, if you have an opt-in
or an opt-out, that can be a very powerful thing as far as behavioral psychology goes. We chose to go against the power of default,
so that consumers have to actively think about it and decide, yes, this is something I want
to opt into. So, I think a very powerful, a very important piece to say upfront.
The second piece is the opt-in consent will state, among other things, and in plain language,
that whether or not consent is given will have no impact on how we handle the complaint.
Very important. If it is given, they can withdraw consent at anytime. We have a mechanism for
that. And then, also, and very importantly, the
second piece, the privacy issue, the CFPB will take reasonable steps to remove personal
information from the complaint to minimize, but obviously not eliminate, the risk of re-identification.
So, I am not sure you know, obviously, there is a lot of literature and research around
this idea of re-identification, the ability to look into a dataset, and even though it
may not have the person’s name, but through direct and indirect identifiers, figure out
who that person actually is. So, we will take the narrative, both the ones
that the consumer provides and the one the company provides, and we will scrub it. In
the policy we have a standard, and I think we talked about it a little bit, but there
is a standard that is in the policy. And it said these are the types of things that we
will scrub out. There are several standards out there, both
in the government and the private, that we could have adopted. The one that we have adopted
comes most closely to the HIPAA standard that they use when scrubbing medical records. It
is a very, very high standard. We scrub a lot of stuff out.
So that, but adopted for, obviously, a financial context. So, that is the standard. So, a very
strict standard. And then, the methodology by which we scrub.
So, you take that standard and you apply it to the narratives, and through computers and
humans, you are able to, then, scrub out all these direct and indirect identifiers, making
it extremely difficult, though not impossible, although very, very, very rare, to be able
to re-identify consumers in that database. So, complaints will continue to be published
after the company responds or after it has had the complaint for 15 calendar days, whichever
comes first. So, the same trigger that is in place right now.
We get a complaint. It goes in the public database the sooner of two things. Either
we get a substantive response from the company so, for example, it is a credit card complaint
and they close it in two days it goes up in two days. If we send it to a company and they take 15
days, we have kind of decided that is long enough for them to decide whether or not that
is their consumer. If 15 days lapses and we don’t hear back from them, it also goes up
in the public database. If after 15 days they come back and they say, “No, no, no, that’s
not our consumer,” then, obviously, it comes down. But we decided internally 15 days is
long enough. We are adopting that same timeframe for the publication of the narrative, which
we will get to in a second. But, when the narrative goes up, contemporaneously,
the company’s response would go up. So, one wouldn’t go before the other.
So, we only disclose consumer complaint narratives, again, for which consent has been obtained
and there has been a robust personal information scrubbing standard methodology applied.
Companies would have the option to provide narrative text that would appear next to the
consumer’s narrative in the consumer complaint database. Again, the same standards for removing
personal information would apply to company responses. And then, I think this is last. Lastly, so
we put the policy out. We got a lot of comments. The documents I have in front of me are related
to that; I’m going through right now. There were three things, in particular, that
we were looking for feedback on and would love to hear this group’s feedback on.
One is consumer consent. Where in the process should that take place? What are some things
we should be sure to alert the consumer to with respect to giving consent?
Two, the company response, what should that look like? What are the elements of that that
you would suggest? Are any thoughts you have on the company response piece? And then, again, the personal information
scrubbing standard methodology. Again, the standard is, what are the things, what are
the categories of things we scrub out? The methodology is, how do we go about doing that?
What is the process that we go against to actually scrub the data out of those narratives?
So, with that How many responses did we get?
So, we got just kind of two buckets of responses. PIRG did a campaign and was able to get about
30,000 effectively form letters submitted in favor of the policy.
We have got about 100 and I think 20 or 30 comments. I would say about half of them are
from some type of entity; the other half are from individuals. Of the half from entities,
the way it is broken out, as far as I can tell right now, kind of companies and trade
associations related to those companies have generally come out against the policy; some
are fairly moderate. A lot of them have very good suggestions. On the other side, those kind of in favor
and with suggestions, one of the trade associations for the newspapers, so Dow Jones and Newscorp
and those folks, their trade association submitted something in favor. Several consumer groups,
including the umbrella organization AFR, submitted I saw that. They thought we should disclose
everything, regardless of whether consumers consent, right?
Yes, they are firm believers in FOIA. And so, consumer groups, open government,
kind of transparent government groups, and, frankly, privacy groups have come out in favor.
Obviously, the privacy groups, I think about four or five of the kind of biggest nationally-recognized
privacy groups in this area came out in favor, but, obviously, with heavy suggestions. They
want to see this done, but, obviously, they are very thoughtful about the privacy aspect
of it. So, that is the kind of trend that I have
seen thus far in going through the comments. Next steps, obviously, we will go through
them, summarize them, provide responses. And at some point, to the extent the Director
decides to move forward with the policy, any adjustments would be made to that and it would
be published. We don’t have a timeframe right now on when that all is going to take place.
It depends the size of the work, you know, all the comments we got in, and also, frankly,
internal decisionmaking and that process. So, with that, I want to open it up, maybe
turn the microphone back. Scott, I had an opportunity to speak with
you on the phone on a conference call on this. My credit union, my Board accepts comments
directly from our membership. And just to share that experience, what often
happens is the member comes out of the box with a full head of steam on something. And
it is pretty edgy. Often, though and maybe this is where the 15 days comes in it turns
out that perhaps the member was missing some money from an ATM transaction, maybe it is
some ACH transactions; it turns out their son got a hold of their ATM card and they
had shared their pin number. It is embarrassing for all concerned.
And so, what I would tell you from our experience and we have been doing this for four years
now, so there are many, many of these examples, and I think most credit unions are like this
we are not going to go out on a comment section and say anything disparaging about that member
or their family. It is just not in our DNA or our culture. But, recognizing that we could, you are allowing
us to do that and you are protecting the privacy, but it is just not the type of thing that
we are likely to do. So, then, it makes you question, what is the
value of that exchange? And it is very common. It is very common. And so, I think you used
the language something to the effect of, can it be fixed? These aren’t necessarily things
that are broken. They are exchanges of information that probably are better handled between the
financial institution and their member. And granted, there are others that are not,
that are legitimate. But I just caution you that there is a fair amount of that out there.
And we wouldn’t put that type of information in our comments section.
I have a quick comment. I’ve got to run. First of all, very good work. I’m impressed.
So, keep up the good work. One of the things I would caution you on,
and maybe you already recognize this, is that database of narrative will be very valuable.
As this goes publicly, there will be firms that download it and use it. So, I am sure
you are aware of that. But, as that value increases, the incentive for people to populate
the database is going to increase as well. We regard that as a good thing, yes.
Scott, just two questions. Yes.
It looks like the end of this whole process where you are scrubbing narratives and doing
it all, it is very manual. Maybe it takes a lot of time. Are you concerned that a lot
of consumers are going to opt-in and you are going to have to add a lot of staff just to
do that portion? And also, the second question is, you mentioned
that you are going to break it out by credit card complaints, mortgages, and other. Is
it going to be further broken out by institution. So, if I am shopping for a new credit card,
I can look at Capital One complaints, Bank of America complaints, and those types of
things, kind of like an Angie’s List type of consumer review?
So, thanks for those questions. On the first one, the cost, we are actually going to be
scrubbing all the narratives we get. So, the Bureau takes privacy very seriously. They
are privacy issues inside and outside the building.
So, these complaints that we get are absolutely full of the consumer’s very personal information.
So, it has got their name, sometimes their Social Security Number, their account number,
what happened to them. Oftentimes, in narratives they will put medical conditions they have.
There’s all kinds of stuff there. As I talked, we want to share that stuff inside
the building as much as we possibly can because it helps folks do their jobs. At the same
time, there are certain elements of those complaints that folks inside the building
don’t need to know. So, we are going to be scrubbing. We are setting
up operation to scrub all narratives. So, while we are sharing it with someone in Enforcement
or Supervision, they may not need to know the Social Security Number or the medical
condition, or whatever that this individual has.
So, as far as kind of cost goes, we are going to amortize that across all complaints that
we get. But you raise a very, very good point, which is at some point when volume you know,
volume times cost per complaint equals potentially a big number. The ability for computers to scrub direct
identifiers  that is the things, you know, numbers, names, account numbers, all that
stuff, the stuff that helps you directly identify people, they are very, very good at. So, you
can run that through a computer; 99.99 percent they’ll scrub it out.
The tough part gets with indirect identifiers. So, let’s say we’ve got the zip code in one
column and the person wrote in their narrative, “You know, I’ve been the fire chief for five
years here in kind of Greenfield, Wisconsin, and I broke my leg last…,” whatever.
So, those things that you just normally wouldn’t be able to read and say I know who this is,
once you start providing other clues, like zip code and some other things, eventually
someone will be able to figure out who that is. And those are indirect identifiers. Computers
are not very good at scrubbing those out. So, not to get too far into the methodology
of how we will be scrubbing this, because, frankly, the more you disclose your methodology,
the easier it is for people who are outside the building who want to re-engineer it and
identify folks, it gets easier. So, a little bit ambiguous about that.
But I would suspect that the amount of eyeballs on the public-facing narratives would be higher
than the things that we share inside the building, I think for obvious reasons.
And so, yes, there is a concern about cost. I think the methodology we are putting together
will capture that, but that is obviously something we are going to monitor. But, as of right
now, I feel pretty good about the cost constraints on this initiative. The second thing is already in the public
database there is a column that has the name of the institution. So, today you can go and
you can sort and you can see which companies have the most complaints, both in absolute
terms and you could do some normalization. Obviously, to the extent that the narrative
is available, that will, then, become part of, you know, text analytics would, then,
become part of that analysis by company potentially. Let me just add that what Scott describes,
automating some of the scrubbing, really wouldn’t have been possible probably as recently as
ten years ago maybe five years ago. There has been a lot of technology that has developed
around things like HIPAA, the Medical Privacy Act, where they want to find ways to have
information be useful, but scrub out the kind of things that create legal issues. So, this
has made leaps and bounds. But, also, it is, again, a reflection, I want
to say again, about Scott’s team. They faced problems and challenges every day to get to
this point. I mean, it is remarkable what they have done in three years. When I was Attorney General of Ohio, we had
a complaint response function that was quite rudimentary, and they have been at it for
decades decades. So, you know, we will work this through. The
other thing I want to say is we are trying to be very careful, we are very careful about
privacy. There are plenty of consumers who come to the database and they are quite happy
to be public. They don’t mind being identified. Many of them are also people who might go
and talk to their newspaper or their local television station and have a story on the
air about how they felt they were mistreated and what happened with it.
So, you know, there is a certain number of consumers here who are pretty hardy and this
won’t even affect, but we are going to be looking at privacy, regardless of what their
own outlook or temperament might be about that. Can you speak to the overall value of making
this out to the public? And then, what your all’s intentions are specifically to bringing
this out to the public, especially when it is going to be sort of scrubbed?
I will take that one. Right now, we already have a public complaint database that Scott
described. You can already go there and, for example, as you said, there is some value
in being able to go and look at Institution A or Institution B. What kind of problems
do you see? What kind of concerns do you have? Do I want to do business with that institution? You know, again, if it was just a handful
of complaints, you might feel pretty skeptical about whether it is worth bothering, but if
there are many, then you start to get a sense that there is a certain pattern at this institution
that doesn’t seem to be the same pattern as another institution. And the more data we
have, the better filled-in that picture is, as Scott happily described.
Similarly, right now, all of that still broken down in fairly-generic categories, though.
You know, it is just not as descriptive as having the detail around what actually happened
to someone and what the problem really was. The other thing is, when we did a panel on
this  we did a field hearing on this a couple of months ago there were some industry folks
who made a point to say more detail often creates more credibility. Anybody can give
a generalized, you know, somebody stinks or somebody isn’t doing a good job. That doesn’t
mean anything. Nobody can make much of that. If there is more detail, you can really get
a sense of whether that seems to be a legitimate problem or not. So, in that respect, it is
helpful. Also, it is more vivid. It is just more vivid.
You know how it is. You draw a conclusion in the abstract as opposed to you tell a story
around somebody’s real-life event. It is just different.
And by the way, Scott didn’t mention, but there are two agencies of the federal government
that have already been doing this for some time. The National Highway Traffic Safety
Administration, you can go to their website and you can look at the narratives of complaints
people have about particular vehicles. I’ve looked at my own car. It was a little bothersome
because there were some problems with the generic make. I haven’t had them myself, but
it makes you think. And the Consumer Products Safety Commission,
an analog to us, but not for financial products, for general products like toys and toasters
and cribs, they put up the narratives. So, it is already being done in some elements
of the federal government. So, we are not the first ones to cross the rubicon here and
do something brand-new. So, again, we are at a stage where we have
just gotten a lot of public comment, a certain amount of consternation in some quarters.
We will digest all of that and think hard about it, but these are the reasons why we
moved forward with the proposal in the first place. And we will see where we go from here
without prejudging it. But those were some of the thoughts that were in our mind as we
started in on this. If you want to add anything, you have been
the one who has thought most carefully about this.
No, not at all. As usual, very good. Scott, have you given any thought to assisting
in screening some of the complaints at the entry-level of the website? And I apologize,
I have not viewed it. And what I am referring to would be you are
the Consumer Financial Protection Bureau, and there are many consumers who would think
that any complaint that they would have, even an employee of an institution might feel that
they could bring a complaint to you, where it would be best served at EEOC or some other
place. So, are there any disclaimers or any information
at the beginning of the process that would help people to know that they could go to
another place or another portal might be a better choice for that complaint? Right. So, good question. We do get folks
that call us, just through the contact center, we get folks that call us about a range of
issues. It is nice when you’ve got a human on the phone. You can go back and forth. To
the extent that we identify that this doesn’t meet the definition  you know, this is just
an inquiry, it is not complaint, then we answer their question.
If it is a complaint and it meets our definition, which is the satisfaction, then it goes down
our complaint channel. If they are actually calling about EEOC or similar type of matters,
we do our best to refer them to the other place.
So, at least through the phone, we are actually fairly effective at triaging what is ours
and what isn’t ours. The stuff that comes over the web and, also the mail-in/fax, that
gets digitized and goes into a universal queue. To the extent that we get it, we send it to
the company, and the company has the chance to say, before it goes up in the public database,
before we start down this train, either “Hey, this isn’t ours. This isn’t our customer,”
which I think is a very important distinction between  you know, some of the comparison
have been made between what we do and potentially what some private sector actors do.
One of the issues they have is this controlling where you have people actually talk about
products and services and restaurants, and they are never going to actually use the product,
service, or restaurant. So, we do confirm, in fact, there is a commercial
relationship there. So, we get it. It is in our jurisdiction. It meets our definition
of a complaint. It has everything we need to treat it as a complaint. We send it to
the institution. They say, “Yes, this is our consumer.”
So that is the verification that we do for the complaint. And then, at that point, you
know, it goes on to the company. I have talked about this before, so some folks
have heard this. But one of the analogies that I use to talk about our system is the
airline industry. So, everyone here has flown on an airplane. Everyone here has flown on
an airplane with a bag. Everyone here has flown on an airplane with a bag and that bag
has been lost. And you just understand that. So, airlines lose baggage. Everybody loses
baggage. And that’s fine. There’s kind of judgment is not passed on it. Everyone does
that. What you don’t want to be, though, is the
airline that loses the most bags relative to your peers, right? So, people lose bags;
that’s fine. You don’t want to be the No. 1 airline that loses the most bags.
Second, when you lose a bag, you want to treat it like it is your mom’s bag. You don’t want
to treat it like it’s the bag that belongs to the guy down the street who you don’t like
very much. And so, there is a difference there. So, if you are a company and you pride yourself
on customer service, and you get a complaint and everyone gets complaints  you say, “Look,
relative to my peers, I get less complaints than everyone else.” If that is part of their
business model, it is part of your business model and you see this in the car industry
you can market on that and say, “We get all these awards. You know, we have a fantastic
product, and we have been independently recognized.” And the second thing on how you treat the
complaint, hey, when we get a complaint, like it’s important to us and we will do everything
we can to resolve this complaint. And then, consumers when they are thinking
about, well, gee, who should I do business with  and you can imagine the consumer that
says, “Things always go wrong for me. Like my bag always gets lost. I know something
is going to go wrong.” So, as I am thinking about a credit card company,
I want to go with somebody who I know, if there is an issue, they will be on top of
it and they will treat it like it is their mom’s issue, and not like it is the guy’s
issue down the street who they don’t like very much.
But some consumers don’t care about that. In that case, they don’t have to look at the
database. They don’t have to look at the data that comes out of it that people package and
make more user-friendly. But, to the extent that folks actually do
value that and they are thinking about where to put their dollars, and that is something
that has value to them, and they have certain expectations in making those decisions, then
that is where I think this information closes the gap between what people are paying for
and the customer service that they are expecting, particularly when things go wrong. Well, you basically answered it. I was getting
down to, if someone does come in and it is a complaint against a credit union or a bank,
and it should be referred to FDIC or NCUA, how you would handle that? And I think you
addressed that well by phone, but what about on the internet? Have you thought about links
or the like that would send them over that direction?
So, that is a good question. Right now, when we get a complaint, we will identify it as
belonging to another regulator and we will send it along.
I can envision a place  you know, we did some survey work, and what we found was, you
know, people have a certain level of satisfaction with our process. And one place where satisfaction
just goes off a cliff is if it is a referral, an incoming referral. I assume it mirrors
going out. So, just kind of being passed from one regulator to another causes a good 15
to 20 percent drop in satisfaction. So, our ability to in the future think of
a way to kind of design, get the appropriate consumer to the appropriate regulator instantaneously
is a goal. So, right now, it is a little kludgey. We get the complaint. We refer it out. Others
get their complaints; they refer it to us. In the future, just given that delta in consumer
satisfaction in my office we have three goals. One of our goals is an amazing user experience.
That is really important to us. And so, over time, that is something that we are going
to put resources against to try to fix. Thank you, Scott.
Do we have any other questions for Scott? I’m sorry. Jason? I’m sorry, I was just going to make a note.
There is already a lot of places out there that you can go as a consumer and look at
financial institutions, the BBB. I mean, a lot of credit unions and financial institutions
have Twitter accounts, Facebook. There’s all those interactions already.
Just kind of creating one more spot that somebody has to go monitor and make sure of the response
that it gets is going to be made public is politically correct, as Marcus was saying
earlier. So, those were my thoughts. I just will have more of a suggestion on the
layout. I think you said earlier, when you put the narrative out there, that the comments
are going to be side-by-side. And I guess I would encourage that, that they are side-by-side,
because people will only read the complaint and not read the response. And sometimes,
how you respond tells the consumer that that is really where I want to go. People do make
mistakes, but they handled it well and they were impressed with their response. So, just
in all fairness, I think it would be good to lay them side-by-side.
Okay. Okay. Well, thank you all.
It sounds like, Scott, that we have the same mission, to deliver an awesome member experience.
And so, you are going to deliver an awesome consumer experience. So, it looks like we’re
side-by-side on that front. But thank you for your work.  It is greatly
appreciated. And as we wrap up today, and as you have seen
today, the Bureau staff is very interested in our perspectives, our views, and how we
better the lives of our members, and that we are different from the other folks.
I really look forward to this Council’s contributions and as we move forward with our initiatives. Thank you for traveling to D.C. I know time
from your shops is very precious to you. But the work that I think that we are doing here
is benefitting our communities and our members as well.
I also want to thank Director Cordray, Zixta, and Delicia for their leadership and for their
time to giving us the opportunity to voice our perspectives. And I just think that that
is just amazing. It is an honor for me to be here as well as I’m sure for all of you
to be able to have the time of these folks, and, hopefully, put the thumbprint on some
policymaking decisions that come our way. So, with that, travel safe. We will see you
next time. Thank you for the public for being here. And we’re all accessible, as you have heard.
So, if you have any thoughts or any comments between the time that we meet, please feel
free to reach out to Delicia; also, myself and Kevin. Emails or telephone calls would
be great. So, thank you very much all and have a great
rest of the week, and travel safe.

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