When consumers submit complaints to the Consumer Financial Protection Bureau (CFPB), they have the option of choosing the categories most relevant to their problem.

Recently, the CFPB changed hundreds of combinations of Product / Sub Product / Issue / Sub Issue mapping in its form. These changes did not garner media attention. Yet, they are significant and they matter.

In August 2023, the CFPB released the Consumer complaint form product and issue options document, based on five years of feedback from stakeholders and consumers. As a result, the CFPB made “improvements including changes to certain products, sub-products, issues, and sub-issues; as well as some reorganization, language revisions, additions, and removals.” 

As you read this article, please consider how the CFPB “dropdown” changes will impact:

  • Consumers: How will these changes influence consumers’ choices when submitting complaints to the CFPB?
  • Financial institutions: How will these choices impact financial institutions’ understanding of their consumers’ pain points?
  • CFPB and other regulators: How will these changes impact regulatory reviews and examinations of financial institutions?

Using the PositivityTech® platform, we explored three changes:

  • “Opened without my consent or knowledge”
  • “Problem with a company’s investigation into an existing problem”
  • “Debt or credit management”

This Sub Issue was revised for Products and Issues, including: 

  • Checking or savings: Opening an account 
  • Credit card: Getting a credit card 

View the visuals below from the PositivityTech platform, followed by observations:

Checking or savings (Sub Issue) 

Pre-CFPB Change: “Account opened as a result of fraud”

Checking or savings (Sub Issue) 

Post-CFPB Change: “Account opened without my consent or knowledge”

Observations

  • Bank of America’s percentage of complaints decreased while Chime’s percentage of complaints increased.
  • Early Warning Services, Citizens, and Navy Federal Credit Union complaints became more prominent about “account opened without my consent or knowledge.”

Pre-CFPB Change: Complaint from Bank of America Customer

Post-CFPB Change: Complaint from Bank of America Customer

Observation

  • Regardless of the CFPB dropdown changes, consumers continue to focus on fraud in their complaints for this category.

Credit card or prepaid card (Sub Issue)

Pre-CFPB Change: “Card opened as a result of identity theft or fraud”

Credit card (Sub Issue)

Post-CFPB Change: “Card opened without my consent or knowledge”

Credit card or prepaid card (Issue): “Getting a credit card”

Observations

  • Since August 2023, JPMorgan Chase shows the highest percentage of complaints about “card opened without my consent or knowledge” and also reveals a steep increase in complaints about “getting a credit card.” 
  • TransUnion and Experian complaints became more prominent about “card opened without my consent or knowledge.”

Pre-CFPB Change: Complaint from JPMorgan Chase customer

Post-CFPB Change: Complaint from JPMorgan Chase customer

Observation

  • Regardless of the CFPB dropdown changes, consumers continue to focus on identity theft and fraud in their complaints for this category.

The CFPB expanded this issue, changing the focus from a “credit reporting company’s investigation into an existing problem” to any “company’s investigation into an existing problem.”

View the visuals below from the PositivityTech platform, followed by observations:

Pre-CFPB Change: “Problem with a credit reporting company’s investigation into an existing problem”

Post-CFPB Change: “Problem with a company’s investigation into an existing problem” 

Observation

  • While this issue was revised, 95% of the complaints about this issue were still submitted to the credit bureaus.

Pre-CFPB Change: Complaint from Experian Customer

Post-CFPB Change: Complaint from Discover Customer

Observation

  • Customer narratives continue to refer to credit bureau inaccuracies. In complaints submitted to companies, consumers request that the company address credit bureau inaccuracies. 

This brand new product now includes all issues related to credit repair services or debt settlement, which were previously associated with the credit reporting product. 

View the visuals below from the PositivityTech platform, followed by observations:

Pre-CFPB Change: “Credit reporting, credit repair services, and other personal consumer reports” / “Credit repair services”

Post-CFPB Change: “Debt or credit management” / “Credit repair services”

Observations

  • 54% of these complaints were directed to the credit bureaus when the credit repair services Sub Product was directly mapped to “Credit report, credit repair services, and other personal consumer reports.”
  • 22% of these complaints were directed to the credit bureaus and more than 30% were directed to credit repair service companies when the credit repair services Sub Product was mapped to “Debt or credit management.”

Pre-CFPB Change: Complaint from Lexington Law Customer

Post-CFPB Change: Complaint from Lexington Law Customer

Early Observations Based On The First Three Months of Data:  

  • Consumers: Consumers are making different choices when submitting CFPB complaints.
  • Financial institutions: With these changes, financial institutions find themselves receiving a greater variety of complaints. 
  • CFPB and other regulators: In the coming year, we expect that these changes will impact regulatory reviews and examinations of financial institutions.

As you can see, it is vital to track CFPB category changes. They are significant and they matter.

Using PositivityTech, financial institutions can see the impact that these changes have on their institution and across the industry in real-time.  Interested in getting ahead of this issue? Please reach out to me at marcia.tal@positivitytech.com. I look forward to helping you transform negatives into positives.