The Data Desk — Complaints Part I: “I’m Not Complaining But…?” Refocusing the Regulatory Lens Using the CFPB’s Complaint Database

As with nearly every industry, in banking, feedback can be in the form of suggestions from consumers, industry peers or, in the form of complaints. Whether it is through Yelp, Google Reviews, The Better Business Bureau, or individual company surveys, candid and mostly unfiltered customer feedback is critical to help companies see blind spots, catch errors, and enhance consumer experiences. 

For banks, there is a unique portal for such feedback, the Consumer Financial Protection Bureau’s (CFPB) Consumer Complaint Database. The Consumer Complaint Database was established in 2012 and is a collection of complaints about various financial products and services, including those provided by banks with over $10 billion in assets, that the Bureau then shares back with companies for a response. Once the company responds to confirm a commercial relationship with the consumer, or after 15 days (whichever comes first), the CFPB publishes the complaints.

As the Bureau notes, “[t]his database is not a statistical sample of consumers’ experiences in the marketplace. Complaints are not necessarily representative of all consumers’ experiences and complaints do not constitute “information” for purposes of the Information Quality Act.”

Each year the CFPB compiles their Consumer Response Annual Report (CFPB Annual Report), which analyzes complaints submitted by consumers to the CFPB in the previous year. As the 2023 CFPB Annual Report explains, “The CFPB uses this information to monitor risk in financial markets, assess risk at companies, and prioritize agency action. The CFPB makes complaint data and analyzes readily available to CFPB staff to support their supervisory, enforcement, and market monitoring activities.”

CBA analyzed recent data from the past four years to highlight specific areas that are receiving a higher number of complaints and where the complaint numbers are smaller than one might expect.

CBA analyzed complaint data from January 2020 through September 2024 and developed the following takeaways:

• Complaints about credit reporting made up nearly 80 percent of all complaints since January 2020;

• Debt collection is the second highest product cited in the consumer complaint database since 2020 with most complaints tied to attempts to collect debt the consumer stated they did not owe;

• Complaints about late fees and overdraft fees made up less than a percent of overall complaints since the beginning of 2020; and

• Analysis of consumer narratives shows that fraud and scam issues are likely more widespread than the CFPB’s database initially shows, with many complaints not labeled as fraud or scams having an origin related to a fraud or scam issue.

In Part II of our analysis, CBA will more closely analyze the CFPB complaints data with a focus on fraud and scams including how the CFPB and industry can work together to improve reporting and more effectively fight fraud and scams.  

Complaints Overall

From January 2020 through September 2024 there were nearly five million consumer complaints submitted and logged by the CFPB’s database. Of this, the vast majority (nearly four million or almost 80 percent) were complaints regarding credit reporting, including incorrect information on consumer reports and the improper use of consumer credit reports (see Figure 1). This reflects a growing trend in the CFPB Complaint Database since early 2017 where complaints about credit reporting have not only become the majority but have been increasing at a growing rate. There are a couple of reasons for this, namely that a consumer issue with a credit report may prompt multiple complaint submissions—one for each major Consumer Reporting Agency.

Excluding credit reporting complaints from CBA’s analysis provides a better picture of the top consumer complaints about traditional banking products.

When excluding credit reporting, the top three products in the complaint database since 2020 were debt collection, credit cards or prepaid cards, and checking or savings accounts (Figures 2a and 2b).

Debt Collection

Complaint submissions pertaining to debt collection were mostly centered around issues with “Attempts to collect debt not owed” which constituted 51 percent of complaints in the category over the studied period (Figure 3).

This suggests there could be ongoing issues with how debts are being recorded, furnished, and reported to the major CRA’s, debt collectors, and consumers as well as additional concerns around identity theft and fraud.

Additionally, the data shows that many of these complaints involve threatening, harassing, or downright illegal behavior used to contact or coerce customers to pay debts they often were not aware of. CBA found that complaints regarding this behavior were more prevalent among various debt settlement companies listed in the data—matching recent CFPB actions.

Credit Cards and Prepaid Cards

Out of the nearly five million complaints logged from January 2020 through September 2024, there were 225,485 complaints about credit cards and prepaid cards with an average of just under 10,000 complaints per year. While the number may seem like a lot of complaints for credit cards, when you consider that there are currently over six million credit cards in the hands of consumers, the number of complaints pales in comparison.  

Complaints centered mostly around disputes as “Problem with a purchase shown on your statement” accounted for just nearly one quarter (22.46 percent) of all credit card and prepaid card complaints over the studied period and has continued to increase, nearly doubling since January of 2020 (Figure 4).

Digging into the listed sub-issues for credit card and prepaid card complaints shows that problems with dispute resolution are a large portion of these complaints, suggesting that consumers are increasingly using disputes to deal with fraudulent or mistaken transactions on their credit and prepaid card accounts. This data supports findings that show similar trends in disputes.

Complaints regarding “fees or interest” accounted for less than one tenth (8.19 percent) of all complaints submitted about credit cards and prepaid cards since January of 2020. When we break this down further by sub-issue:

• We estimate that complaints specifically about late fees represent just over one-third of these “fees and interest” complaints;

• Using this, we can further estimate that there were roughly 5,626 complaints in our dataset about late fees since January 2020 compared to nearly 60,000 comments on the CFPB’s Credit Card Penalty Fee Rule; and

• Our estimate suggests late fees represent 2.5 percent of all credit and prepaid card complaints and about one tenth of a percent of all complaints since the start of 2020.

CBA’s analysis also found that complaints regarding “Problem[s] with rewards from credit cards” made up just two percent of all credit card complaints since January 2020. While there are certainly some documented issues that arise in credit card reward programs, the level of complaints does not seem to match the characterization by the CFPB of industry-widespread use of “bait and switch” tactics.

While these complaints have grown since the pandemic, the growth is in line with the increase in spending and rewards earned on these cards over the same period.  Additionally, we found no outliers in the number of rewards complaints by company, with complaints correlating strongly with the number of accounts a company has.

Checking or Savings Accounts

There were a total of 179,109 complaints related to “Checking or savings accounts” in our dataset. Two-thirds of complaints for both checking and savings accounts revolved around the following sub-issues:

1. Making deposits or withdrawals (specifically funds availability and Certificates of Deposit);
2. Problems using debit or ATM cards;
3. Unauthorized transactions;
4. Funds not being handled or disbursed correctly;
5. Other bank errors; and
6. Companies closing consumer accounts for a variety of reasons.

Though CBA’s analyst team could not review every consumer complaint narrative individually, our analysis did note some of the trends that seem to be driving these complaints, specifically two notable issues:

• First, we noticed that many of the complaints were directly or indirectly related to fraud and scams, with consumers becoming frustrated as they tried to resolve issues stemming from unauthorized transactions on their accounts, debit, and ATM cards as well as the closure of their accounts due to fraudulent transactions occurring on them; and

• Second, many consumers struggled with funds availability, noting that they either expected funds to be made available faster than they were, or that bank associates told them funds would be available sooner than they ultimately were. There also seems to be issues in recovering long-term certificate of deposits (CDs) that likely rolled over multiple times and/or were opened with a bank that was subsequently taken over or merged with another bank. This caused confusion between the consumer, the bank representative, and the state entity in charge of administering unclaimed or abandoned funds.  

Notably, CBA’s analysis found that very few complaints had to do with overdrafts.

Across all possible product categories CBA found 7,419 complaints regarding overdraft and NSF fees. This constitutes less than one percent of all non-credit reporting complaints since January 2020. This is in stark contrast with the number of responses to the CFPB’s 2022 Request for Information regarding fees.

Additional analysis of the consumer narratives in overdraft-related complaints filed in 2023 shows that about eight percent were related to overdrafts caused by fraudulent transactions on a customer account showing how fraud can often multiply the financial impact on consumers.

Refocusing the Conversation on What Matters

Our analysis is not intended to downplay the work the CFPB has done over the past four years, but to shed light on some of the issues that may deserve greater attention. Our analysis highlights consistent issues consumers are having and where better collaboration between the CFPB, industry, and others could have a meaningful impact.

Stay tuned for Part II where we dive deeper by analyzing the same complaint data with a focus on fraud and scams, revealing ways that the CFPB can make subtle changes to improve our knowledge of fraud and scams and partner with industry and other organizations to join the fight in combatting it.