Compliance Blog

Sep 02, 2015

CFPB August Complaint Report; OIG Complaint Database Audit; Cute Overload

Written by Elizabeth M. Young LaBerge, Regulatory Compliance Counsel

CFPB Monthly Complaint Report for August, 2015

Beginning last month, the CFPB is releasing a monthly snapshot Complaint Report that will report the volume of complaint data received by the bureau, highlight any identified trends, spotlight data from a certain geographic location, and name the most-complained-about-companies.

The Monthly Complaint Report for August indicated that the CFPB handled 26,700 complaints in the month of July, bringing the total number to approximately 677,200 as of August 1, 2015.

The good news is that complaints about bank accounts and services represent the greatest decrease in the report: complaints are down 2% from the previous month and 4% from the previous year. Complaints surrounding debt collection remain the highest in terms of volume, with the CFPB receiving 8,224 in the month of July. The second highest in terms of volume and the highest increase over the previous month was related to credit reporting. Credit reporting complaints increased 56% over the previous month and 45% over the previous year. 97% of these complaints were directed at one of the three major credit reporting agencies.

Company level data is reported on a three-month rolling basis, so the majority of data on any given report is largely repetitive of the data on the previous report. July's report on complaint volume by company covered data from February April of 2015, and August's report covered data from March-May of 2015. Both reports named Equifax and Experian as the first and second most-complained-about-companies, respectively, and TransUnion as the fourth most-complained-about-company.

Between the high increase in complaints about credit reporting and the continued presence of the three major credit reporting agencies in the top four most-complained-about-companies, it is not surprising the CFPB made credit reporting the focus of the monthly report. The report stated that 77% of complaints to the CFPB regarding credit reporting involve incorrect information on reports, including the appearance of paid debts and debt belonging to other persons on consumers reports.

If you are the kind of person that reads about credit reporting complaints and immediately becomes nervous about whether your credit union is in compliance with Regulation V, now might be a good time to revisit Subpart E regarding the duties of furnishers of information and Appendix E containing the Inter-agency Guidelines Concerning the Accuracy and Integrity of Information Furnished to Consumer Reporting Agencies.

Recent and Future OIG Reviews of the Complaint Database

In April, this blog discussed concerns about releasing complaint narrative data without any kind of investigation, which raises safety and soundness concerns and unduly places financial institutions' reputation at risk. Further, we have previously discussed the concern that disclosing narrative information could lead to the inadvertent release of personal information about consumers. In late July, the Office of the Inspector General evaluated the effectiveness of the information securities controls and techniques related to the Complaint Database and reported several control deficiencies. Recommendations were made to protect consumer information, and the OIG reported that the CFPB's Chief Information Officer is working to implement those changes. A few weeks ago, the Office of the Inspector General released its ongoing Work Plan which announced its intentions to conduct an audit of the Complaint Database in the third quarter of 2015. The audit's objective will be to assess the effectiveness of the CFPB's controls over the accuracy and completeness of the public complaint database.

Cute Overload

On a personal note, in addition to being new at NAFCU, I am new to DC. I only just moved from Portland, Maine to DC this summer with my husband and our two dogs: Boomer and Ollie.


Travel

Moving isn't always easy for dogs, but our two boys do pretty well with travel.


Boomer Ollie

Boomer (left) is a 6 year-old bichon fris rescue from Missouri. Luckily for my husband and me, a good attitude comes with the breed. Ollie (right) is a 4 year-old rescue from Pennsylvania. We are not sure of his breed we suspect he is a combo of two adorable breeds but it is hard to say which ones. Ollie is a sweet boy who usually takes Boomer's lead. I'll let you all know how they get on in the big city.