ACA International’s Research Department has released a white paper analyzing 14,328 complaints received by the Consumer Financial Protection Bureau from July 2013 to mid-February 2014. ACA plans to analyze this data on a quarterly basis and will keep members informed of the findings.

The following key findings, which are consistent with ACA’s previous study in November 2013, are based on analysis of the data released by the CFPB including product, sub-product, issue, complaint submission date and response timeliness:

  • The average balance of accounts in third-party debt collection increased from $1,458 in the third quarter of 2013 to $1,520 in the fourth quarter of 2013, representing a 4.29 percent increase.
  • The highest number of identifiable complaints was for credit card and medical debts. However, taking into account the category "others" and "not specified" together, 50.41 percent of the complaints were not associated with a particular debt collection product.
  • The most reported consumer concern was being contacted about "a debt they did not believe they owed." In second place was "communication tactics" followed by "disclosure verification of a debt."
  • Almost all the complaints received by the CFPB were responded to in a timely fashion. Based on the data, 96 percent of the complaints were responded to with a timely response.
  • Of the 14,328 complaints analyzed, 94 percent were "closed," "closed with nonmonetary relief" or "closed with explanation."

While the CFPB complaint resolution process is a step in the right direction compared to other federal consumer complaint repositories, ACA offers the following suggestions to the CFPB to improve the complaint database:

  • Clearly identify first-party collections from third-party collections to ensure accuracy in complaint reporting and avoid the potential for double counting.
  • Maintain context by resisting the temptation to use a broad-brush to paint debt collectors negatively or make assumptions about the behavior of an entire industry solely on top line volume data.
  • Provide more consumer detail to debt collectors who are the subject of a complaint to increase the likelihood of more easily identifying the information needed to resolve the consumer’s complaint.
  • Adopt a definition of a complaint that is limited to consumer allegations of wrongful conduct and does not include the amorphous concept of general consumer dissatisfaction outside of wrongful conduct.


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