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The CFPB issued its Monthly Report that provides a high-level snapshot of trends in consumer complaints and summarizes the volume of complaints by product category, company, and state. Additionally, the report highlights a different product type and geographic area each month. This month’s report highlights credit card products and provides some forecasting of where regulators are likely to focus in upcoming examinations.
Each month, the Report breaks down complaint volume by product, looking at a three-month average and comparing the same to the prior year. As has been the case in previous months, the Report continues to indicate the three products yielding the highest volume of complaints are debt collection, mortgage, and credit reporting. If there are any good takeaways, the Report does show that debt collection and credit reporting both saw a significant decrease in the number of complaints in September 2015. Debt collection showed a 10% decrease and credit reporting showed a 15% decrease. Interestingly, the products showing the largest increase in claims when comparing 2014 to 2015 were debt settlement, credit repair, and check cashing. Taking this into account, we are likely to see enforcement actions continue to increase across the debt settlement and credit repair industries.
This month’s focus on credit card products reveals that according to the CFPB Reports, credit card products are one of the most complained about financial service products, fourth only to debt collection, credit reporting, and mortgage. Credit card providers and servicers should pay close attention to this month’s report as it highlights what are likely to be points of emphasis with regulators in upcoming examinations – particularly with regard to the application of payments and billing disputes.
Overall, the Report did not contain any surprises. So what can the credit card industry expect to see from regulators in 2016? Based on the current complaint trends, the credit card industry can expect to see a continued focus on their application of credit card payments, as well as the accuracy of their disclosures for 0% balance transfers and other promotions.
Caren Enloe is a partner who concentrates her practice in consumer financial services litigation and compliance, bankruptcy, and commercial litigation with an emphasis on creditor’s rights. She has a deep understanding of the complex compliance environment surrounding the financial services industry and regularly advises financial service companies on licensing and compliance issues involving state and federal consumer protection and finance statutes. Caren is the author of a daily blog titled: Consumer Financial Services Litigation and Compliance where she posts timely and informative updates regarding the CFPB, FTC, and a host of topical litigation issues involving consumer protection law....LEARN MORE