Skeletons in the Database: an Early Analysis of the Cfpb's Consumer Complaints

Analyzing a new dataset of 110,000 consumer complaints lodged with the Consumer Financial Protection Bureau (the "CFPB" or the "Bureau"), the authors find that: (i) Bank of America, Citibank, and PNC Bank were significantly less timely in responding to consumer complaints than the average financial institution; (ii) consumers of some of the largest financial services providers, including Wells Fargo, American Express ("Amex"), and Bank of America, were significantly more likely than the average consumer to dispute the provider's response to their initial complaints; and (iii) among the companies included in the database that provide mortgages, OneWest Bank, HSBC, Nationstar Mortgage, and Bank of America all received more mortgage complaints relative to mortgages sold than other mortgage providers. In addition, regression analysis suggests that consumer financial companies respond differently to complaints, depending on the type of product and issues involved, thereby generating significant differences in the timeliness of responses and whether consumers dispute those responses. Moreover, demographics matter: mortgage complaints per mortgage significantly increased in ZIP codes with larger proportions of certain populations, including Blacks and Hispanics. Companies were also less timely, and more likely to have their responses disputed, in areas with higher concentrations of senior citizens and college students, groups on which the CFPB is mandated to focus. *Participants in Yale Law School's Empirical Law and Economics seminar and Nancy Welsh provided helpful comments. Ian Ayres has served as an economic expert for proposed plaintiff classes in several cases relating in part to alleged untimely decisionmaking regarding permanent mortgage modifications under the Home Affordable Mortgage Program.