ACA International, the association of credit and collection professionals, has released an analysis of complaints submitted to the Consumer Financial Protection Bureau in a new white paper, “A Review of Debt Collection Complaints Submitted to the Consumer Financial Protection Bureau’s Complaint Database in 2017
In the white paper, ACA asserts that the CFPB fails to contextualize the number of complaints lodged with the CFPB within the larger context of the debt collection industry. For example, ACA’s analysis shows the total number of debt collection complaints received by the CFPB represents an incredibly small number of consumers (0.005%) who had contact with the debt collection industry during 2017 and are remarkably consistent with other financial services industries. Further, the complaints account for only .06% of all Americans estimated to have a debt in collection.
Additionally, while it has recently been noted in the media that debt collection is the leading category for complaints, ACA’s analysis found this to be simply untrue. While debt collection was the second most complained about product, it accounted for only 20% of complaints submitted to the CFPB. Furthermore, the leading complaint category, Credit reporting, credit repair services, or other personal consumer reports, received 61% more complaints than debt collection.
Of the debt collection complaints received, ACA’s analysis also demonstrates that the CFPB’s data suggests that many of the issues consumers complain about are associated with the technical aspects of credit, outstanding debt, and procedural aspects of debt collection. In fact, based on the CFPB’s own data, categories that measure the most negative stereotypes about the debt collection industry, such as harassment or illegal practices, were the responses consumers selected the least and represent an exceptionally small number of responses. Additionally, these categories continued to decline from 2016 to 2017. This finding stands in stark contrast to the misleading narrative about the debt collection industry being fostered by the CFPB.
ACA has also continually noted that the CFPB very broadly defines a “complaint” as “submissions that express dissatisfaction with, or communicate suspicion of wrongful conduct by, an identifiable entity related to a consumer’s personal experience with a financial product or service.” Additionally, it is important to note that the CFPB does not verify the complaints that it receives from consumers for accuracy. As such, these practices artificially inflate the number of debt collection complaints, yet the CFPB continues to publicly tout its consumer complaint data and uses the raw number of debt collection complaints to imply evidence of widespread industry harm.
ACA International’s new research initiative aims to collect more original data about the credit and collection industry. The goal of this exclusive research and analysis is to quantify the ways that debt collectors help consumers and the overall economy.