CFPB Complaints: It’s Not All About Loans!

2016 marked a CFPB milestone of one million complaints!  Based on the CFPB’s Consumer Response Annual Report for Diane11that year, the majority had to do with loans but other products and services weren’t totally neglected either.  Almost half of the complaints geared towards other bank products and services had to do with account opening, closing, and management.  One example, a consumer applies for an offer only to find out they weren’t eligible to begin with.  That got us to thinking, are you clearly presenting your products and services and/or offers?

Other notable complaints included when funds are made available (including for mobile deposits); overdrafts (amount and transaction ordering); and error resolution procedures. Good for the CFPB, though, in clarifying that some complaints stemmed from a consumer’s dissatisfaction with a product or service, which doesn’t mean the transaction is unauthorized under Regulation E.

Interestingly enough, there were also a number of deposit-related complaints related to getting information and access to accounts of someone who has died.  On the loan side, complaints in this area have led to more regulation for “successors in interest”.  Understandably, this is a tough spot for bankers because we’re so tuned in to privacy and non-disclosure.  We recommend getting together with legal counsel to determine what a person needs to provide to you in order to demonstrate they should have access to an account when a death occurs.  Not knowing what you need or asking for more than you need will likely cause you some headaches.

Diane Dean

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