CFPB Updates 2020 Complaint Bulletin and Again Focuses on COVID-19 Related Complaints
On July 16, 2020, the Consumer Financial Protection Bureau (CFPB) issued an updated 2020 Complaint Bulletin and again focused on complaints related to COVID-19.
The Complaint Bulletin reflects 2020 consumer complaint data through June 15, 2020, and focuses on complaints filed through May 31, 2020 that mention COVID-19 keywords. Of the 187,547 complaints received in 2020, 8,357 included a COVID-19 keyword. The highest number of complaints (1,575 or about 19%) concerned mortgage loans, with credit cards and credit or consumer reporting running a close second and third. A little over half of the complaints related to mortgage loans identified struggles to make payments as the primary issue. Mortgage-related complaints also cited that borrowers with loans in a COVID-19 forbearance were being advised that a lump sum payment would be required at the end of the forbearance, which is contrary to government guidance. As previously reported, the CFPB and Conference of State Bank Supervisors issued warnings to industry members about not following requirements for a COVID-19 forbearance or offering limited repayment options with regard to a forbearance. Other issues cited by consumers include:
- Credit card issuers who offered deferment programs did not implement the options as advertised, such as not waiving interest as advertised.
- A significant drop in their credit scores based on the manner in which a student loan servicer reported their loans.
- Being charged overdraft fees despite banks making public statements that the fees would be waived.
- Short term, small dollar loan companies using aggressive collection tactics.
It would appear that counting only complaints that expressly mention a COVID-19 keyword may significantly understate the number of complaints that are in some way related to COVID-19. In the prior version of the Complaint Bulletin, the CFPB noted that the average monthly complaint volume in 2019 was 29,000, and that in March and April of 2020 the complaint volume set records in each month at 36,700 and 42,500, respectively. In the current Bulletin, the CFPB cites April and May 2020 volumes of 42,400 and 44,100 respectively.
Copyright © 2020 by Ballard Spahr LLP.
(No claim to original U.S. government material.)
All rights reserved. No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.
This alert is a periodic publication of Ballard Spahr LLP and is intended to notify recipients of new developments in the law. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.