Webinar: The CFPB consumer complaint system


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have any objections, you may disconnect at this time. Host you may begin. Great. Thank you everyone. This is the CFPB
Office of Financial Education. I’m very excited to have everyone here today for our Webinar
on the CFPB Consumer Complaint System. So I will say my usual few quick introductory
notes, if only I can get the slides to advance. There we go. So first of all, our standard
disclaimer that this does not constitute legal guidance and is points of view of the speakers
rather than the Bureau. Just quickly, as I think I’ve said and many
of you have probably heard before, the CFPB helps consumer finance markets work by making
rules more effective, enforcing those rules and empowering consumers. We do this through educating consumers. Enforcing
and supervising banks, credit unions and other financial companies. And also, studying, gathering,
analyzing information to better understand consumers and markets. And within the Bureau, the Office of Financial
Education, who’s hosting this call, is within the Consumer Education and Engagement Division.
That’s the part of the Bureau that sort of is consumer-facing in terms of education and
other resources. And our goal is to educate and empower consumers to make better, informed
decisions. And we do that by strengthening channels for
delivering financial education. And by that, we really mean working with folks like you
through FinEx and financial educators and people who are working directly with consumers
who want to help you all do your work as well as you can. And also by supporting consumers directly
and researching and identifying trends and effective practices. And then, as always,
I do my quick plug for FinEx which is the Financial Education Exchange. I assume you’re all signed up but if you know
others who would like to, they can email our inbox [email protected] We will continue
to have Webinars and additional activities being added as we progress We launched only about a couple of months
ago. Just one quick advertisement for the future which is that our next Webinar – they’re
usually the third or fourth week of the month but due to the (unintelligible) of August,
we’re going to do it in the first week of September on the Your Money, Your Goals toolkit
which is a resource that you can use now with clients. And then we have additional ones planned every
month after that. We’re still lining up the topics for those. You’ll hear about those
as they get planned. I always call attention to our resource inventory which you can see
on our Web site. The address is on the screen. Consumerfinance.gov/adult-financial-education.
And that’s the place where you can find almost all the resources you’ll hear about today.
In a few cases, there are new things that haven’t been uploaded yet though they will
soon. So we invite you all to use that. And then my last kind of standard invitation
is to join the Financial Education Discussion Group on LinkedIn which we moderate and which
allows – we put our material up there, but we also encourage all of you to post things
that you are working on or also post questions to the group. It’s about 1100 people on that group now.
So it’s a nice resource I think. So we’ll turn to the content now. I do want to just
quickly note that I know sometimes people have had trouble with the logging into the
live meeting software. I’m hoping everyone on the line today has
either been able to do that or if anyone’s having trouble, I can send you a PDF of the
PowerPoint deck. So just send an email if you need that. We’re hoping that everybody
just can at least follow along on a deck even if they’re not able to get into the Webinar. And so for those who are doing that we are
now on Slide 10, Office of Consumer Response. Our speaker for the day is the Chief of Staff
for the Consumer Response Unit. And she will tell you about what Consumer
Response does and how the complaint system can help you both directly in working with
your clients and consumers and also in learning about what’s happening in the broader consumer
financial marketplace. So welcome. Thank you. So as indicated, I am the Chief
of Staff for the Office of Consumer Response, but the easiest way to think about what we
do – think about three things. We answer consumer questions, we handle complaints and we analyze
and share data. Much of what I talk about today will really
emphasize the handling of complaints and the analysis and sharing of data. But just so
you have a general sense, we really, for this, try to use, you know, the latest technologies
to kind of stay on top of answering questions, routing consumer complaints. And then we also really think of sharing data
as a way to empower consumers, inform consumer advocates and companies and improve the functioning
of the marketplace overall. So I’ll talk a little bit about how we help
because this is important to understand, particularly given the volume of complaints that we handle.
And I want to make sure everyone has a common understanding of what’s possible. On the one hand, we are able to offer a degree
of individual assistance. So we are able to take complaints and in many cases get them
to companies, and companies have about 15 days to provide a response. So that’s one of the ways that we can help.
So for a lot of consumers who have been unable to get a response from a company or find themselves
having difficulty, this is one of things that our complaint process can really help them
do which is get a response from a company in writing to their specific issues. The other thing that we do to help is we have
market-wide information. So these complaints kind of taken together and currently there
are – we’ve handled over 650,000 consumer complaints. All of those complaints each have some insights
but when you look at them together can provide a lot of insight into the problems that consumers
are experiencing. So I’ll talk a little bit about how we answer
questions and handle complaints. So this is just a quick screenshot of our main landing
page for the consumerfinance.gov. So this is always the thing I say. If there’s
one thing you take away from this Webinar know that our Web address is consumerfinance.gov
because from there you can find all kinds of resources and tools. Ask CFPB is something that the Bureau has,
which has I believe over 1100 answers to consumer questions. That same information that’s available
at Ask CFPB on our Web site is also available through our toll-free phone number which is
found at the top of the Web site. So all of those same questions can be answered
over the phone. In addition, we can accept complaints over the phone. And through our
phone line, we can connect consumers to services in over 180 languages and that phone number
is available Monday through Friday from 8:00 am to 8:00 pm Eastern Time. But you can also see here that there’s a Submit
a Complaint option right at the top of our Web site. So we make that really prominently
available so that you don’t have to do a bunch of searching. If you have a complaint, we
want to know about it. So I’ll talk a little bit about a complaint is and so what the definition
is. And you’ll see this is a nice legal definition
that, you know, consumer complaints are submissions that express dissatisfaction or communicate
suspicion of wrongful conduct by an identifiable entity related to a consumer’s personal experience
with a financial product or service which is a really long way of saying it is a consumer
that is dissatisfied with a company that provided a financial product or service. It’s really as simple as that. And so that’s
the definition that kind of governs. It’s just good to kind of all be on the same page
in terms of what that is. There are other ways for whistleblowers and others to get
to us but for complaints, this is the definition that we use. So I’ll talk a little bit about the complaint
process and…This is Slide 16 for those of you following at home. Yes. So the complaint process is fairly straightforward.
The first step is submitting a complaint. So if you go to the next slide, you’ll see
all the ways that we take complaints. Oh sorry. It requires me to pay attention. So from the – to submit a complaint, and I
kind of touched on this just a minute ago, but we really accept complaints through a
number of channels. Web complaints are one of the most common ways for consumers to submit
complaints to us. For consumers that feel comfortable submitting
complaints over the Web, it’s a really good way to get a very quick response to your complaint.
We route complaints — because we have some automation built in the background — we are
able to route complaints 24 hours a day, 7 days a week. So if you come onto our Web site and submit
a complaint, it’s entirely possible that we’ll send that complaint to the company within
minutes. In addition, the Web is where you are able to opt-in if you so choose to have
your complaint narrative. So the words in the complaint published in the Consumer Complaint
Database. That’s only available over the Web and it’s
only available to consumers submitting complaints directly to us. So not through a third-party
because we want to ensure that we have the consent of the individual that the experience
is about. So – but through the Web, you can opt-in and
have that information published in the Consumer Complaint Database which I’ll come back to
in a minute. But we also accept complaints through a number of other channels. We accept complaints by phone, referral, fax,
mail and the occasional email that gets through. But, generally, Weband phone and referral
are the main ways that we receive complaints. I’ll talk a little bit about – let’s go back
up one slide. Sorry. So I just want to give you a sense of the products that we accept
complaints about. You can see some of the most common – mortgage complaints. We can have groups submitting loans and products
and services, but credit cards, pre-paid cards, mortgages, bank accounts and services, student
loans, credit reporting, debt collection, money transfer, vehicle loans and leases,
payday loans. Really the full range – as well as bank accounts and services complaints. So just a full range of products and services
that we accept complaints about. And when you get to our consumerfinance.gov/complaint,
you’ll be able to kind of pick the one that best describes the issue. Once you’re there — on the next slide — you
will see this is a debt collection example. You can see it’s as simple as this. Let’s,
you know, kind of – the issues that we take complaints about in the debt collection space
in this example and the Get Started button will enable you to start actually submitting
a complaint. Once you do that on the very first kind of
step — go to the next slide — you’ll be able to check a box and this is what I was
talking about just a minute ago. And this is new as of mid-March. But if you’re submitting a complaint directly
for yourself, you can actually check the box that says you want CFPB to publish the description
of what you write in the What Happened field so that others can learn from your experience. And what we do after we have it is we take
some steps to remove the personal information from that before we actually publish it. And
I’ll show you a little bit about what that looks like in a few minutes. Now shifting gears for just a moment. If you
are going to submit a complaint on behalf of someone else, so you can check that box
because of the sort of opt-in consent complaint submitted on behalf of someone else. Those narratives are not actually subject
to publication for the policy, but there are other good reasons why you may want to do
that. But I want to make sure if you do opt to submit a complaint on behalf of someone
else, you understand how to do it correctly so that you get the proper updates and that
type of thing. So the first tip I have is when you get to
the part of the form that says your contact information goes in the My Information section,
it is indeed your information goes in the My Information. So you really fill it out
in the first person. You don’t have to kind of guess. Just put your information in the
My Information section. And you being you the financial educators,
right?Yes. You the financial educators. Okay. Thank you. If they decide to do this. You enter your
information right there. And if you were the consumer filling it out yourself you would
do it there too. So. Just don’t try to guess. Don’t try to outthink it. Just fill it out
as though you are yourself. And then you’ll be able to do – the other
tip I have is to be sure you enter your email address. So just – the same thing. When it
says, “My Contact Information” make sure it’s your contact information because that’s the
email address that you will use to log-in and be able to view the complaint, view the
company’s response and so on. So it’s really important to have that email
address. The next tip is if you are submitting on behalf of someone else, this is where we’ll
know who that My Information section person was. So here you would just say, “I’m filing on
behalf of either myself or someone else.” So if you check the Someone Else box, we know
that the information above for My Information belongs to you. And then you can let us know, what’s your
relationship to this person? So this is helpful for us to know kind of who’s submitting complaints
on behalf of others. So many advocates choose advocate attorney,
helping counselor. It really just depends on kind of how you view yourself and your
relationship to the client or to the consumer. The other tip I would have is to then, after
you’ve done that, when it says, “Someone Else” then you provide the information for the someone
else. So you would put the consumer’s contact information in that space. If you’re submitting
on behalf of a consumer, you’d put their information there. It’s very important, obviously, to have things
like the mailing address because that’s what the company will use to try to match this
complaint in their records and understand. I – one of things that we note here at the
top of this page is filing on behalf of someone else may require signed written permission. So the company — and you can imagine this
is a good safeguard — may not be able to discuss a complaint with someone that is not
anywhere on the account. So it’s important before you submit a complaint on behalf of
someone else, you actually need to be authorized to discuss that account or that mortgage or
whatever the issue is on that person’s behalf. If you don’t have that level of authorization,
if you’re trying to assist someone who maybe just needs, you know, some data entry help
or just isn’t very comfortable with government processes or whatever the case may be, you
may not want to submit on behalf of them. But instead, help them do the initial submission
and kind of be, you know, be their fingertips as you type in the complaint, but not submit
on behalf of them unless you were actually going to be on their account and really acting
in their place throughout the process. Can I ask you one question, Darian that I
suspect may come up… Yes. …when we open for questions later. You mentioned
advocate attorney and housing counselor. Are there any other choices that are closer to
financial educator or financial advisor? Do you know offhand… That’s a good question….or are those there
– because those may not encapsulate some of the other types of people who might be working
with… If memory serves that there’s about seven
or eight options. I don’t recall what all of them are, but it’s helpful for us to know
if you’re family or friend or attorney. Right. But there may even be another option in that
space. Yes. But kind of really whatever best fits. It’s
more just for the benefit of us kind of having a general sense of, you know, whether we’re
getting all of the complaints from attorneys or getting all the complaints from family
friends. I see. So it’s not rigid. No definitely not. If they’re not actually a housing counselor
but are doing something like that, you may be able to… Choose a – just like grade school. Choose
the option that best fits. Ready for the next slide? Yes. Okay. So I touched on a little bit of this about
the importance of making sure the email address that you enter on the My Information section
– that’s the email address you’ll use to log-in into the consumer portal. So once you’re in the consumer portal, and
this is whether you submit a complaint or for someone else, you’ll be able to view the
complaint you submitted, you’ll be able to check the status of the complaint and you’ll
be able to review a0nd provide feedback about any company responses to the complaint. This would include any attachments. So it’s
important that that email address be a real email address that you can access and get
updates on. Then the other thing I noted was that companies may require authorization to
communicate with a consumer’s representative before responding. So if you are submitting on behalf of someone
else and truly in that role, then you’ll want to make sure that you’re authorized on that
account or mortgage or whatever the case may be. And, as I indicated though, you could check
the box to consent to publishing when submitting a complaint on behalf of someone else. Only
consent directly given by consumer lets the CFPB publish their experience in the Consumer
Complaint Database. So I just wanted to make those three highlights. Can I ask one other question again… Yes. …possibly anticipating – so if you – if
the written permission is required, that’s something the company would always – already
need to have the (still way) to sort of upload that here. Darian Dorsey: You can attach it at the same
time. Irene Skricki: Okay. Darian Dorsey: It’s just going to – then it
will just depend on the company reviewing that. Irene Skricki: Okay. But it’s always a good idea, you know, to
be proactive in that space just to avoid some kind of cycle of, “Oh you’re not authorized.
Oh wait. Oh maybe you are.” You know, it’s good to kind of settle that before if you
can. And I – one other question I think for, again,
for a financial educator, do you – is it – are there reasons why it’s better to submit on
behalf versus having them do it themselves? Unless it was a function of whether you are
in a position to play that follow up role, if you’re likely to see them again.
Right. Is there any other things people should think
about in making that determination? Yes I think – that’s a good question. I think
it’s really – it really depends on the depth of the relationship you have with the consumer.
If they are your client and you are their, you know, their case worker or something akin
to a case worker, then it may be appropriate to submit on behalf of – if you are really
and truly acting in their place. You should almost think of this to some extent
– it’s almost like power of attorney level kind of ability to act on their behalf. You’re
going to have to review the company’s response. You’re going to have to dispute the company’s
response. You’re going to have to provide any additional
documentation. So you really want to be kind of – decide kind of – make a decision on whether
you are really acting in that way or if you really just want to kind of assist someone
of getting their complaint in at the front end of the process. Right. So you should do it cautiously. Right. And that’s if – so only if you’re very clear
that you’re going to have an ongoing relationship or feel that (like). Okay. Thank you. So once we’ve done that and submitted a complaint
– and it’s honestly taken me longer to describe submitting a complaint than it will probably
take for you to submit a complaint. So that’s a good thing. It’s a fairly easy form and
we’re continually looking at ways to make it better. But it’s a pretty straightforward process.
You can attach attachments, for example, when you’re doing that, when you’re submitting
a complaint and that can, you know, be a pretty quick process. But however we get the complaint whether it’s
through the Web or the phone or some other channel, we check for completeness and jurisdiction.
We send it to the company. And if we can’t send it to a company, then we can actually
refer it to another regulator. So we have referral relationships. But that typically happens – we’re typically
able to send complaints to companies in under one day including weekends. And so it’s a
fairly quick process after you submit a complaint. Next slide. So once we’ve done that, the company has 15
days to respond to the consumer and to the CFPB. They have to use a secure Web portal
to respond to us. And that means that they – their response is available through that
consumer portal. So once they provide it in their secure portal, it’s then available in
the consumer portal as well. Companies are expected to respond within 15
days, but have up to 60 days to provide a final response. So some complaints, particularly
in the mortgage space, may take longer than 15 days. But either way, they have to have let us and
the consumer know that within 15 days that they are going to need up to 60 days. Next
slide. So once the company responds, the consumer
reviews the company’s response including the steps taken to respond to the complaint, the
communication to and from the consumer, the follow-up actions or planned follow-up actions,
and at that point, can provide some feedback about that response. Should we look at the next slide? The feedback
kind of comes, again, through that consumer portal that I talked about and is used to
inform a whole host of kind of prioritization exercises that we do to try to understand
which issues and companies and products we want to kind of focus our limited investigations
resources on. So the last step – I’ll talk a little bit
about what happens after a consumer provides feedback. At that point, we analyze the consumer’s
feedback. We use it and a whole bunch of other information to try to identify market problems
and consumer educational opportunities whether it’s through that individual or just more
broadly. We also report and share data with internal
and external stakeholders. So we work very closely with our colleagues in supervision
and enforcement as well as share information through government portals with federal and
state regulators. We also push data into the Federal Trade Commission’s
Consumer Sentinel Network. And we also report rather frequently to Congress through an annual
consumer response – a report to Congress from consumer response. As well as sizeable contributions to the Bureau’s
semi-annual reports to Congress along with some other reports that our other offices
in – such as the Office of Servicemember Affairs, the Office of Students, the Office of Older
Americans who also do reports on complaints. And I’ll talk about the last one of these
things, on the next slide, which is the Consumer Complaint Database. Something that you should
really think of as a tool for finding out more about what kind of issues consumers are
having. And what you’ll see here is a screenshot on
the landing page for the Consumer Complaint Database which was just updated on June 25
to include narratives. And what you’ll see here is you’ll see three options. And I like
to think of these as, you know, easy, you know, medium and hard. So the thing on the left with the exclamation
point, that’s the easiest way. If you want to read narratives, you can click on Read
Narratives there and be able to just quickly skim through and read narratives. The middle option to view, sort and filter
data gives you the ability to see something that looks like an Excel spreadsheet and do
some filtering. Many of the same functionality but just gives you all the complaints. So the first option gives you just the narratives
that consumers have opted to share, and I believe last I checked this morning, it was
about 12,000 complaint narratives are in the Complaint Database and this is only since
June 25. So it’s quite a few narratives have already been added to the Complaint Database. What percentage of the total complaints are
doing narratives? So consumers are opting in – so it’s only
available over the Web. But for consumers that are submitting complaints over the Web,
it’s around 58% of consumers are opting to share their narratives through the Web. But again we do receive complaints through
other channels and those don’t have the same kind of consent. In the middle section here,
you’ll see the view, sort and filter data and that’s again the Excel view. And then on the right-hand side you can see
this is for people who want to export and use APIs and more sophisticated things. So
depending on your level of data love, you can kind of move along from left to right
to get more information. So I’ll talk about, on the next slide, a little
bit about how we put narratives in the Complaint Database. So protecting consumer’s privacy
is a priority. So we’ve published anonymized data about over 417,000 complaints on our
Web site. So in addition to the ones that have narratives
which is very recent, there are a total of 417,000 complaints in the Complaint Database.
Since June 25, we’ve published about 12,000 narratives. And what we do is before we publish them,
and only for those where the consumer opts in, we scrub out information that can be used
to identify consumers. So if you were to look at some of those narratives,
you would see x’s where some kind of information that might be used to re-identify a consumer
has been removed from the narratives. The other thing beyond kind of the importance
of privacy is the idea that the database is available to the public. So, really, anyone
could be interested in it. And the idea is that, you know, we know how valuable complaints
are to CFPB and how much they inform our work. And we believe that they also can be very
useful for other work. So companies can use it to see what products their competitors
are putting out and what kind of complaints they’re seeing. And they can use that to inform
the products that they’re developing. At the same time, researchers can look at
it and see where there are patterns and trends by geography, by issue and so on. And kind
of on down the line. Just think it’s an important resource that can hopefully be helpful to
the market. Again, consumers can opt-in to put the narrative
in the Consumer Complaint Database. We remove sensitive information and personal identifiers.
It’s all scrubbed out. Whether a consumer opts in or doesn’t has
no impact whatsoever on how we handle the complaint. It moves through the process exactly
the same way. And consumers also have the ability to withdraw consent at any time. They can just give us a call, let us know
and the next time the database is updated we can remove that narrative. So I’ll show
you just a quick screengrab to hopefully get you intrigued and excited to go check out
the Complaint Database. This is what happens if you click that left
side option, the Read Narratives. You’d see something that looks an awful lot like this.
And what you can see here is some really basic information. On the left side, you can find out when we
got the complaint, the product, the sub-product, the issue, sub-issue, the state, the zip code
and how we received it. So you can see these are both Web complaints, happened to be here
at the top. In the middle section, you’re actually going
to see the consumer’s complaint narrative. And this is in their own words submitted through
the Web form. And here’s where you can see a few of the x’s that block out – in this
case for the first one, they’re giving us the last four digits of their checking and
savings account. So it’s pretty darn important that we take those out and our system does. And then you can actually see below that the
company’s public response. So companies are given an option, after they’ve responded to
the complaint, to provide a public-facing response. And in this case – and in both of
these cases, the company choose not to provide a public response. But it’s their option. And in the far right-hand
column, you can see the actual name of the company. The date we sent it to the company.
So for these examples you can see the first complaint, I believe, we received on the 25th
and it looks like maybe we sent it to the company on the 29th. So in just a couple of
days, we sent it to the company. And then you can see how the company responded
to the consumer. You can find out whether the company’s response was timely, whether
the consumer disputed it and for people who are kind of avid data users, you have a complaint
ID number that’s distinct from the one we use internally in our system for authentication
reasons. But this enables you to kind of take data
at one point in time, match it up to data later. So if you’re interested to see how
a complaint was, you know, kind of changed over time, you can see that information by
matching the complaint IDs over time. So I want to just let you know about the types
of reports that are available based on complaint data. I kind of touched on this earlier. But
just last Thursday, I believe, if last Thursday was July 16 – it all kind of blurs together
a bit. We issued our first ever monthly complaint report. In this report, you can find the top ten most
complained about companies in the country as well as in this most recent one, there’s
a products focus which for July was debt collection. And there is a geographic focus which for
July was Milwaukee. So every month around the middle of the month,
we’ll be issuing these reports, updating the most complained about companies, updating
and giving a deeper dive into different products and into different geographies just to give
people a sense of what we’re seeing kind of over time. You’ll also see that we have some other snapshots
are available on our Web site. So information before the monthly complaint started coming
out that we would periodically release a snapshot as well as additional reports. So, for example, a snapshot of debt collection
complaints submitted by older consumers, by our Office of Older Americans. Our credit
reporting complaint snapshot. A report on complaints from servicemembers, veterans,
and their families by our Office of Servicemember Affairs. And so on kind of down the line. And older
Americans and mortgage debt, reverse mortgage complaints, annual report of the ombuds and
a mid-year snapshot of private student loan complaints. And all of this, I think, speaks to the fact
that complaints are kind of a key part of a lot of work here at the Bureau. So submitting
a complaint, you know, may or may not result in a particular outcome that a consumer desires.
We hope it does. But either way complaints are really at the
heart of what we do here and they’re really important for our colleagues throughout the
Bureau to really understand the issues that consumers are experiencing. So that they can
inform supervision and enforcement rule-making and a host of other Bureau activities. So there’s some real value in submitting a
complaint just because it enables the Bureau to have some insight and now with the publication
of narratives to give the public additional insight in to what consumers are experiencing. Right. I’m going to add something here which
is that all of these reports are on our Web site. And then, if you go to the resource
inventory, the report that I referenced at the very beginning which is also on our Web
site — resource inventory for financial educators — we have summaries – we have both the list
of these reports as well as short summaries. They’re a few paragraphs. So you can read
the highlights without having to read the entire report. And I think it’s interesting
the complaint system both allows consumers, obviously, to get their complaints heard and
responded to, but a lot of this data really is a very nice way to see what’s going on
in the marketplace. It’s actually quite interesting reading because
the reports can be quite specific about the specific types of challenges that folks are
facing around, you know, mortgage debt and student loans. And so, they’re actually interesting reading
I think for someone working with consumers to see what types of things other consumers
are facing. So I do encourage folks to look at that. And, again, those are all available
on our Web site. One note – two of them are not in our inventory
because they’re so new. The monthly complaint report and also the servicemembers one was
updated just recently. And so our inventory doesn’t have those, but
they are on the Web site and we will update the inventory fairly soon. So I think we just
have contact information now. Mm-hm. How to reach Consumer Response and the CFPB
generally. All right. So now we’ll turn to questions. So oh (Kathy) the Operator, we’re
going to take questions now from folks. So you can both submit a question through
the Q&A function which you should see at the top of your Webinar screen if you’re in the
Webinar software. Or if you want to ask by phone, (Kathy) will remind you how to do that. All right. And if you do want to ask a question
by the phone, please press the star 1 and please record your name. And to withdraw your
question on the phone, it’s star 2. Once again star 1 on the phone to ask a question. Thank
you. And right now I don’t have any emailed questions
and I know those of you who weren’t able to use the Webinar software can’t do that. I
will ask a question while we’re waiting. Can you tell us a little bit about what the
– of the 600 – what 675,000 or so complaints that have been received, what has happened
to those complaints in terms of the resolutions for consumers? I know there are some percentages
around that. Sure. So one of the big things that our process
can deliver is the ability to get a response. So of the 650,000 complaints, some complaints
we refer to other agencies, right, because they’re better able to handle them. They’re not about a product or service that’s
in our coverage or they’re about a bank under $10 billion, for example. So there’s some
number of those that they go off to other regulators. But there are – you know, over 400,000 consumers
have received responses from companies that, in many cases, address their concerns. There’s
a lot of different things that can come in a response and one of the things that we’ve
always said to companies is that we don’t place a particular value on one response over
the other. It’s rather more important that it actually
is tailored to what the consumer needs. So in some cases, it’s resulted in monetary relief.
So that can be anything, you know, such as returned late fees or it could be something,
you know, much larger than that. It just really depends on the consumer’s specific
situation. But monetary relief is sometimes possible. But in many cases it’s not really
what’s appropriate or what the consumers are asking for. So a consumer that’s looking for a modification
on their mortgage isn’t going to find a $100 gift card to be terribly, you know, a valuable
relief. So there’s is also non-monetary relief. So the refinancing of a mortgage or a modification
can have a lot of great value for consumers. So we’ve seen some consumers have outcomes
like those. In addition, we also have a good number of complaints where companies have
provided an explanation. So not surprising to anyone in the financial
education community, there’s a lot of confusion around how products and services work. And
so a lot of consumers have gotten explanations where they hadn’t really gotten clear explanations
before. They’re now getting them in writing which
has some value, as you might imagine, to be able to actually read in plain language, we
hope, the company’s explanation which maybe it’s some financial education information
that should have been provided initially, but nonetheless is provided now. And so, we’ve really seen, kind of, it really
spans the whole gambit of different types of resolution and relief. What I will say
is that of company responses, only about 20% of company responses have been disputed. So that means that, you know, the vast majority
of consumers – well so they may not have gotten exactly what they like, they felt like the
response that they got from the company more or less met their needs. At least so much
as they didn’t feel the need to dispute the company’s response. Actually I’ll just – there was actually a
very loosely related question that came in online which says a consumer has a complaint
regarding Capital One, should they file with the OCC and the CFPB? I – is that a function
of what the product is? So one of the things that’s in Dodd-Frank
is this concept – and 1034 for those who don’t have it committed to memory. In 1034, it talks
about the fact that the Bureau has to stand at this function, which wound up being the
Office of Consumer Response, to be the centralized place for complaints about consumer financial
products and services. And that’s really how you should think of
us. We’d actually prefer if you not submit complaints to multiple regulators. The result
being – in the case of a Capital One complaint, we would receive the complaint. OCC would also receive the complaint. OCC
would do data entry. Then OCC would let us know we had the complaint. And then we’d go
into OCC’s system and then take their data entry complaint, put it into our system and
merge it with the other complaint. So definitely, we have strong preference for
starting with the CFPB. If we are not the right place, we will absolutely get it to
the right place. But we operate at a very large scale, handling over 20,000 complaints
a month. And so we are really well situated to take
as much as people can give us. But it is much more laborious to kind of refer complaints
back and forth between agencies. So. Fantastic if you start with us and we’ll make sure that
if we’re not the right place, we’ll get it to the right place. Great. Aree there any phone questions that
have come in? We do have one. Go ahead and ask your question
please. Hello. During the presentation, I think you
said that there’s certain complaints that aren’t able to be sent to the company. Can
you elaborate on that? Sure. So one of the things that’s important
in being able to send a complaint to a company is kind of having complete information which
is fairly straightforward. But I usually kind of joke that the same, you know, the same
kids that didn’t put their names on their paper in the third grade, they grew up. We do occasionally get complaints from consumers
where they don’t have their name on them or their address or any other information. This
particularly happens with things like mail or fax. So, occasionally, we get things like
that. They’re just really incomplete. We also sometimes get complaints where the
consumer doesn’t know who they’re complaining about. And so, this can happen, for example,
in the debt collection space where they know they’re getting calls at all hours of the
day and night, but they can’t identify who the person is which is a strong indication
of a scam. And it’s one of the types of complaints that
we would, for example, send to the FTC for inclusion in the Sentinel Database because
it’s not a complaint that we could send to a company. Those are the most common, but it also includes
complaints as I indicated for, you know, in the example of a credit union that was under
$10 billion in assets. Those complaints we would refer to the National Credit Union Administration
for them to handle those complaints. So there are a broad range of things that
can kind of go into that bucket, but you can think of it as things that are incomplete,
things that can’t be tagged to a company, and things that otherwise, you know, kind
of have that sort of scam element are sent along to FTC Sentinel. So that’s kind of what makes up the difference
between what we’ve handled in total and what we’ve been able to get responses to. But,
in general, companies – of the complaints that we’ve sent to companies for response,
98% of those complaints have been responded to in a timely manner. I assume that there are cases when the company
can’t figure out if the – so the customer – this is not our customer or… Right. …you know, we can’t match this person. Yes. Does the consumer then have an opportunity
to update the complaint or what happens in this case? It’s – there is a process for that but that
is – it’s definitely one of the very small kind of edge cases where that happens. But,
in general, companies are expected to save any record or any kind of plausible belief
that this consumer might be a customer of theirs. So if someone, for example, submitted a complaint
about advertising, we would expect that the company respond if that’s their advertising
whether they have a record of that customer or not. That type of thing. So it’s not very common. And you can actually
see in our annual report to Congress, there’s actually a breakdown of those types of categories
of response. So if you’re curious about what percentage those are. But it’s very – a very small percentage of
things fall into that bucket. The vast majority of complaints can be sent to companies and
the very vast majority of the time, companies provide responses and provide timely responses. Okay. Are there other phone questions? Yes. Hello? Can you hear me? Yes we can. Okay. Good afternoon. I am not – I might want
you to reiterate, if you would, what would be something that would make sense for a complaint.
Last night, I had clients that I was coaching and we were talking to one of their credit
card companies and they were indicating that they had a Collections Department, but they
would not put us through to them. The client repeated over and over again that
she was suffering financial hardship and needed to speak to someone in Collections in order
to work out a payment plan. We were told repeatedly that they did not have it. So she authorized
me to do the talking. When I got on the line, I was, again, told
that they would not give us the Collections Department number even though – at one point
they said they had a Collections Department and another it made it sound – and then at
another point it made it sound like they had a third-party collections. Yes. Then what happened is that the person went
offline about ten minutes when I said, “Have you ever heard of the Consumer Financial Protection
Bureau?” Yes. They came back on and I’m confident it was
the same person but talking with a bit of a different accent and knocked off $105. But
they still were telling her she has to pay an exorbitant amount and – they wouldn’t work
with us. It was ridiculous. Sure. So I will say that not everyone is enamored
of our definition of complaint. However, it is the definition that’s very consistent with
the other regulators. And I would say – I would kind of pose to
you if you’re thinking about that interaction, you experienced it. So there’s that. So yes
that’s true. There’s definitely a company involved. And I would say it’s fair to say
from your interaction, you’re dissatisfied. Yes. That’s the definition of a complaint. Yes.
You know, it’s – you’d kind of – it meets the sort of standard definition. Your client
– and it sounds like you both are, you know, have an expression of dissatisfaction with
an experience you had with that company. And that’s a perfect example of something
that could be a complaint. And, again, sometimes complaining to us much like sometimes mentioning
our name, can get companies to maybe pause, take a look and think about how they want
to address that concern. So, you know, if you feel like it’s a continuing
issue and you still need resolution, I think that that sounds like the kind of thing you
might want to submit a complaint about. Thank you. I will discuss it with the client.
Thank you. Wonderful. Okay. We have another emailed question here
which says, “Have you found that companies that out to scam consumers have diminished
their scams as a result of the CFPB oversight?” So I can’t speak entirely to scams. Just not
my area of expertise. But what I can say is we have heard from companies about changes
that they are making. Some of them they’ve told us. Some of them have been in the press. We have heard of companies that are hiring
executive level – so – and their very senior executives are hiring people dedicated to
focusing on complaints. We have seen stuff like that. We’ve also heard of executives having their
bonuses tied to complaint performance and the public Consumer Complaint Database and
how they do relative to their peers. We’ve also heard of companies who have done
things like, you know, that phone tree. So when you call a phone number and you get kind
of stuck in a loop of press 0 and then press 4 and then hope you don’t have to figure out
what’s next, right? That whole loop? We’ve actually been told that some companies,
to avoid complaints coming to the CFPB, are actually shortening that process and trying
not to kind of do so much run-around because they would rather address their consumers’
issues than have their consumers come to us which we would tend to share that we would
rather have them address their consumer issues than have to come to us as well. So I can’t speak specifically to scams, but
I do know at least some anecdotal – have anecdotal evidence around complaints which is my area
that companies are paying attention and taking some actions to better address consumer complaints. I’m going to jump in with another question
myself… Yes. Go ahead. …as moderator. What do we do when we – I
assume that sending the complaint to the company requires the portal connection, right, you
mentioned. What happens when we can’t find them? Are there companies that haven’t signed
up? Do they have to sign up? How does that work? So we have over 3000 companies not including
affiliates. So affiliates would make that number even larger. But over 3000 companies
have boarded to the company portal. Again, by and large, we’ve been able to find companies
if they are actual legitimate companies. And, by and large, companies have been willing
to kind of cooperate without kind of any additional process. It’s a simple process for them to
provide some basic information then we set them up with a portal. Provide them with a
manual and some training so they know how to use it. But for the most part, we’ve really had a
lot of success there. I will say one of the challenges that I know that the Federal Trade
Commission has dealt with for many years is scams. So things that may seem like legitimate businesses
– that’s really not our area and that’s why we send those complaints to the Federal Trade
Commission. We don’t have coverage over scams in quite that same way. And so our model of complaint handling is
about sending a complaint to a company. And if we can’t because it’s not a real company
or they’re kind of a fly-by-night operation, then that’s something that we put into the
FTC Sentinel Network for law enforcement – state, federal and international law enforcement. Do you have a sense of the percentage of complaints
about companies that turn out to be handed over for that reason? It’s fairly low. In the debt collection space,
it’s higher. But it’s very low in your bank spaces and in many of your non-bank spaces.
But in your debt collection that’s where we see more complaints where we are not able
to identify the company and (unintelligible) and send it along for inclusion in the Sentinel. Okay. Great. Are there other phone questions? Hello. Can you hear me? Yes. Yes. Okay. Excellent. I have something I went through
recently and I’m just curious if you’re getting a lot of complaints about this subject. When
you purchase an item with a major credit card, it gets charged right away. However, when you return something or something
in addition ends up on your credit card, it takes days if not over a week for it to come
off your credit card. Yet they’re holding up your line of credit. Have you guys gotten a lot of complaints about
that? You know, I’m not entirely up-to-speed on
the exact numbers we’re seeing in credit cards, but what I would say is one of the really
cool features about the Consumer Complaint Database is the ability to search. So you can actually go there and do word searches.
It’s just right up that – once you click on any of those options, you can go up there
and search through them and see if we’re seeing more of that. It may be an issue that we see some of. I
know that the top issue for credit cards is billing disputes. I don’t know. You know,
it really kind of depends on how a consumer views that. Whether they decide that that’s
a billing dispute or some other kind of issue. But it might be something just to kind of
test drive the Consumer Complaint Database and see if others are complaining about it.
But I know that the – I believe over a 1/3 of our credit card complaints are about billing
disputes. Okay. Thank you. Okay. And we have a question. Hi. Why is – do you know the statistics on
the rate of companies allowing their responses to consumers to be published? Oh I have not done a breakout of that. So
let me – and this is may be part of your question. So one of things is when we send a complaint
to the company for a response that response is not optional, right? So we send that complaint and then they have
to provide that response which can be close of monetary relief, close of non-monetary
relief, so on down the line. That is not really up to them. That is published. Where they do have an option is if they want
to provide an additional optional public company response. And we have not seen – it kind of
varies by product and varies by industry and varies by whether you’re a bank or a non-bank. But some companies are using it. I don’t have
the latest and greatest numbers on it, but some companies are using that optional public
response. But they don’t have discretion about the response that – at least the category
of response that they provided the consumer. That’s not up to them. We publish that as
part of publishing the complaint. Okay thanks. Quick follow-up. Were you an
appropriate venue for CRA-related complaints? It depends. I’m assuming you mean Community
Reinvestment Act? Yes. As – I think if it’s related to a financial
product or service – if that’s the kind of the – the issue is if something you think
is a CRA issue but I don’t think – if it’s just the CRA or just some very CRA-specific
thing, but I don’t think that that’s us. Yes. I mean, generally, kind of – a lot of
CRA is around business and is around lending not to individuals. So that – we don’t cover
that like that type of – probably the service test which is the piece that deals with how
they’re serving individuals maybe. But I – your point is that if they decide
to send it us, we will get it to them, right? Right. And I think, yes. And I think it really
is, is does it fit into one of those product buckets? So you think there’s a CRA issue?
Is it a specific – it’s really about that definition of a complaint. It’s about a consumer’s
experience with a company. So if the issue is a single consumer which
is a little hard to imagine for Community Reinvestment Act, but I am very rusty on my
Community Reinvestment Act. But if probably not a single consumer has
an issue with a company that’s a CRA issue. It’s probably more – it sounds like maybe
more of a systemic observation and I don’t think that we are the – necessarily the right
place for broad CRA complaints. Thank you. Mm-hm. Do we have any other questions? No. There are no other questions at this time. Okay great. Well we’re down to just a couple
of minutes anyway. So I think – oh wait, it looks like we have – we may have one more
coming in. No. Apparently not. Okay. Well great. Well this has been – I found it really
interesting. Lots of interesting stuff here. And again,
so thank you everyone for joining us today. This Webinar was also recorded. So you can
– we will display it on our Web site in a week or two. We’ll send out an email to FinEx
participants to let them know when that is available. And, obviously, we urge everyone to use our
resources, look at our resources, check out some of the reports we talked about today,
and absolutely use the Submit a Complaint function. I think it will be a great resource for a
lot of you and your clients. So thank you very much. Let us know if you have any questions.
And I think this is the end of the Webinar. Thanks everyone. Thank you. This completes today’s conference.
You may disconnect at this time.

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