Monthly Complaint Report

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April 2017Monthly ComplaintReportVol. 22

Table of contentsTable of contents . 11.Complaint volume . 21.1Complaint volume by product . 31.2Complaint volume by state . 71.3Complaint volume by company . 92. Product spotlight: Student loan . 112.1Student loan complaints by type . 112.2 Student loan complaints by state . 142.3 Student loan complaints by company . 163. Geographic spotlight: Nevada . 183.1Nevada complaints by product . 193.2 Nevada complaints over time . 203.3 Nevada complaints by company . 21Appendix A:. 221MONTHLY COMPLAINT REPORT: APRIL 2017

1. Complaint volumeThe Consumer Financial Protection Bureau (CFPB) is the first federal agency solely focused onconsumer financial protection,1 and consumer complaints2 are an integral part of that work. TheCFPB helps connect consumers with financial companies to make their voices heard. Whenconsumers submit a complaint, we work with companies to get the consumer a response,generally within 15 days. We also publish basic information about complaints in our publicConsumer Complaint Database to empower consumers, inform consumer advocates andcompanies, and improve the functioning of the marketplace. This Monthly Complaint Reportprovides a high-level snapshot of trends in consumer complaints. The Monthly ComplaintReport uses a three-month rolling average, comparing the current average to the same period inthe prior year where appropriate, to account for monthly and seasonal fluctuations. In somecases, we use month-to-month comparisons to highlight more immediate trends. For companylevel complaint data, we use a three-month rolling average of complaints sent to companies forresponse. This company-level complaint data lags other complaint data in this report by twomonths to reflect the 60 days companies have to respond to complaints, confirming acommercial relationship with the consumer. This is consistent with complaints found in thepublic Consumer Complaint Database.31The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, Pub. L. No. 111-203 (“Dodd-Frank Act”)created the CFPB to protect consumers of financial products or services and to encourage the fair and competitiveoperation of consumer financial markets.2Consumer complaints are submissions that express dissatisfaction with, or communicate suspicion of wrongfulconduct by, an identifiable entity related to a consumer’s personal experience with a financial product or service.3This report is based on dynamic data and may slightly differ from other public reports. Company-level informationshould be considered in context of company size and/or market share. Complaints referred to other regulators, suchas complaints about depository institutions with less than 10 billion in assets, are not published in the ConsumerComplaint Database.2MONTHLY COMPLAINT REPORT: APRIL 2017

Visit consumerfinance.gov/complaint to learn about how we handle complaints or to submit acomplaint. Visit our Consumer Complaint Database at consumerfinance.gov/complaintdatabaseto search, sort, filter, and export complaints.1.1Complaint volume by productAs of April 1, 2017, the CFPB has handled approximately 1,163,200 complaints, includingapproximately 28,000 complaints in March 2017. Table 1 shows the percentage change incomplaint volume by product, comparing January - March 2016 with January - March 2017.4Part of this year-to-year increase can be attributed to the CFPB updating its student loancomplaint form to accept complaints about Federal student loan servicing, starting in lateFebruary 2016. The Bureau also initiated an enforcement action against a large student loanservicer during the time period covered by this report.TABLE 1: CHANGE IN COMPLAINT VOLUME% change325%Student loan3 month average:Jan - Mar 20163 month average:Jan - Mar 20177733,284Bank account or service25%1,9932,488Consumer loan25%1,2581,568Credit reporting23%3,9784,911Credit card18%2,0172,372Debt collection9%7,3207,989Prepaid-3%225219Other financial service-9%187170Money transfer-12%202178Mortgage-14%4,5313,902Payday loan-29%41729823,14627,590Total4319%Complaint totals include all complaints with product breakdowns focusing on the most-complained-about consumerfinancial products and services.MONTHLY COMPLAINT REPORT: APRIL 2017

Student loan complaints showed the greatest percentage increase from January - March2016 (773 complaints) to January - March 2017 (3,284 complaints), representing about a325 percent increase. Part of this year-to-year increase can be attributed to the CFPBupdating its student loan complaint form to accept complaints about Federal studentloan servicing in late February 2016. The CFPB also initiated an enforcement actionagainst a student loan servicer during this time period. Payday loan complaints showed the greatest percentage decrease from January - March2016 (417 complaints) to January - March 2017 (298 complaints), representing about a29 percent decline.Table 2 shows the complaint volume this month by product. The graphic at the end of each rowunder the heading “Monthly complaints” shows the volume trend from when the CFPB beganaccepting complaints about that product (green bullet) to the current month (blue bullet). Themonthly average reflects complaints handled per month since we began accepting thosecomplaints.554The CFPB has used a phased-in approach to expand its complaint handling over time to include multiple productsand services under its authority. Complaint-handling capacity was expanded as follows: credit card complaints onJuly 21, 2011, mortgage complaints on December 1, 2011, bank accounts and services, private student loans, andconsumer loans on March 1, 2012, credit reporting on October 22, 2012, money transfers on April 4, 2013, debtcollection on July 10, 2013, payday loans on November 6, 2013, prepaid cards, credit repair, debt settlement, andpawn and title loans on July 19, 2014, virtual currency on August 11, 2014, and Federal student loan servicing onFebruary 26, 2016. See Table 2.MONTHLY COMPLAINT REPORT: APRIL 2017

TABLE 2: MONTHLY PRODUCT TRENDS665Gray bars show /- 1 standard deviation for monthly complaints since we began accepting those complaints. Totalcomplaints column includes 8,700 complaints where no specific consumer financial product was selected byconsumers.MONTHLY COMPLAINT REPORT: APRIL 2017

Debt collection complaints represented about 31 percent of complaints submitted inMarch 2017. Money transfer complaints showed the greatest month-over-month percentage increase(34 percent). Student loan complaints showed the greatest month-over-month percentage decrease (20 percent). Debt collection, credit reporting and mortgage were the top three most-complainedabout consumer financial products and services, collectively representing about 65percent of complaints submitted in March 2017.6MONTHLY COMPLAINT REPORT: APRIL 2017

1.2Complaint volume by stateTABLE 3: CHANGE IN COMPLAINT VOLUME BY STATE7MONTHLY COMPLAINT REPORT: APRIL 2017

Part of this year-to-year increase reflected in Table 3 can be attributed to the CFPBupdating its student loan complaint form to accept complaints about Federal studentloan servicing, starting in late February 2016. The Bureau also initiated an enforcementaction against a large student loan servicer during the time period covered by this report. Montana (54 percent), Georgia (46 percent), and Wyoming (45 percent) experienced thegreatest complaint volume percentage increase from January - March 2016 to January March 2017. New Mexico (-20 percent), Iowa (-5 percent), and Kansas (-0.7 percent) experienced thegreatest complaint volume percentage decrease from January - March 2016 to January March 2017.7 Of the five most populated states, Texas (35 percent) experienced the greatest complaintvolume percentage increase and Florida (8 percent) experienced the least complaintvolume percentage increase from January - March 2016 to January - March 2017.7Complaints per 100k population are defined as cumulative complaints divided by Census estimated 2015 population.Census population data source: 5/index.html8MONTHLY COMPLAINT REPORT: APRIL 2017

1.3Complaint volume by companyComplaint data in this section lags other complaint data by two months to reflect the 60 dayscompanies have to respond to complaints, confirming a commercial relationship with theconsumer. Figure 1 and Table 4 show the top 10 most-complained-about companies forNovember 2016 - January 2017. Figure 1 also shows which products consumers complainedabout for each company. The “Other” category includes consumer loans, money transfers,payday loans, prepaid cards, and other financial service complaints. Company-level informationshould be considered in context of company size and/or market share. In addition, during thetime period covered by this report the CFPB updated its student loan complaint form to acceptcomplaints about Federal student loan servicing, starting in late February 2016.November 2016 - January 2017 average monthly complaintsFIGURE 1: TOP 10 MOST-COMPLAINED-ABOUT 96386003954002852000NavientSolutions,LLC% changevs. 3monthperiodlast year813%ProductsBank acct/serviceCredit cardCredit reporting91,003Equifax17%Experian TransUnion25%30%Debt collectionMortgageOtherMONTHLY COMPLAINT REPORT: APRIL 2017WellsFargoBank inancial30%7%9%27%32%16%Student Loan

TABLE 4: TOP 10 MOST-COMPLAINED-ABOUT COMPANIES3 month average:November 2016 January 2017% change vs. 3month period lastyearMonthlyaverage8TotalcomplaintsNavient 936,344Wells Fargo97030%83051,441Bank of America8027%1,03063,842JPMorgan Chase7199%65940,857Citibank63827%53232,993Capital 7Company By average monthly complaint volume, Navient Solutions, LLC. (1,439), Equifax (1,181),and Experian (1,063) were the most-complained-about companies for November 2016 January 2017. Navient Solutions, LLC experienced the greatest percentage increase in average monthlycomplaint volume (813 percent) from November 2015 - January 2016 to November 2016- January 2017. The CFPB announced an enforcement action against Navient during thistime period. Part of this year-to-year increase can also be attributed to the CFPBupdating its student loan complaint form to accept complaints about Federal studentloan servicing in late February 2016. Bank of America experienced the least percentage increase in average monthly complaintvolume (7 percent) from November 2015 - January 2016 to November 2016 - January2017.8Monthly average calculated from the month the CFPB first handled complaints for the company. Total complaintsrepresent cumulative complaints sent to companies through January 2017.10MONTHLY COMPLAINT REPORT: APRIL 2017

2. Product spotlight: StudentloanThe CFPB has handled approximately 44,400 student loan complaints since July 21, 2011,representing 4 percent of total complaints.Approximately 32,700 (or 74 percent) of all student loan complaints handled by the CFPB fromJuly 21, 2011 through March 31, 2017 were sent by the CFPB to companies for review andresponse. The remaining complaints have been found to be incomplete (7 percent), referred toother regulatory agencies (19 percent), or are pending with the CFPB or the consumer (0.5percent and 0.4 percent, respectively).Complaints handled by the Bureau, including those sent to other regulators, serve to inform theBureau in its work to supervise companies, to enforce consumer financial laws, to write betterrules and regulations, and to educate and engage consumers.2.1Student loan complaints by typeThe CFPB continually strives to collect reliable complaint data while ensuring the system’s easeof-use and effectiveness for consumers. When consumers submit complaints, they select theconsumer financial product or service as well as the issue they are having with that product orservice from a list. This provides structured data that can be used to group complaints to get asense of which financial products and services consumers complain about and what issues theyare having in the marketplace.Figures 2 and 3 show the types of student loan complaints consumers submitted as a percentageof all student loan complaints handled. The most common issues identified by consumers are11MONTHLY COMPLAINT REPORT: APRIL 2017

problems dealing with their lenders or servicers (64 percent) and being unable to repay theirloans (33 percent).FIGURE 2: TYPES OF STUDENT LOAN COMPLAINTS REPORTED BY CONSUMERSFIGURE 3: TYPES OF STUDENT LOAN PRODUCTS CONSUMER COMPLAIN ABOUT9We also collect unstructured data from consumers and companies during the complaint process.The consumer’s narrative description of what happened, consumer-provided documents, thecompany’s response, and company-provided documents are examples of unstructured data. TheBureau uses a variety of approaches to analyze consumer complaints including, for example,cohort and text analytics to identify trends and possible consumer harm. Our review andanalysis of unstructured data offers deeper insights into consumers’ complaints and helps theBureau understand problems consumers are experiencing with student loans. Federal student loan borrowers reported that when contacting their loan servicersregarding financial distress, servicers provided them with information on hardshipforbearance or deferment, instead of potentially more beneficial repayment options likeincome-driven repayment plans. Federal student loan borrowers complained of difficulty enrolling in income-drivenrepayment plans. Borrowers reported lost documentation, extended application9The CFPB updated its student loan complaint form to accept complaints about Federal student loan servicing in lateFebruary 2016.12MONTHLY COMPLAINT REPORT: APRIL 2017

processing times, and unclear guidance when seeking to switch from one income-drivenrepayment plan to another. Federal student loan borrowers described their experiences when trying to obtainguidance in completing annual income recertification for their income-driven repaymentplan. Borrowers reported receiving insufficient information from their servicers to meetrecertification deadlines and lengthy processing times. Some federal student loan borrowers stated their payments were misapplied. Borrowersreported overpayments were not applied to specified accounts but rather applied to allaccounts managed by the servicer. Additionally, some borrowers’ overpayments—intended to reduce principal balance—were credited to the account as an early payment,resulting in their account reflecting a paid ahead status. Concerns about Public Student Loan Forgiveness (PSLF) and other forgiveness programswere expressed by borrowers. Some borrowers stated that after years of makingpayments, they are not enrolled in a qualifying payment program. Some indicated thattheir servicer’s reason for the declination was because their loan had been previouslyconsolidated. Many consumers expressed concern that their payments are not beingcounted toward their PSLF 120 payments requirement because of delays in IncomeDriven Repayment (IDR) plan enrollment and recertification. Borrowers who are eligiblefor other forgiveness programs (e.g., teachers) reported problems with their servicers asthey were declined for loan forgiveness based on inaccurate employment data. Borrowers who submitted complaints for non-Federal student loans selected the subissue of trouble with how payments are handled more frequently than other issues.These borrowers complained of misapplied payments and inaccurate accounting ofpayments. Non-Federal and Federal student loan borrowers reported issues of incorrect reportingof their loans to the credit reporting companies. Borrowers stated their loan accountswere paid in full or not in a delinquent status but were being reported negatively. Someborrowers reported being contacted by collection companies for accounts that had beenpaid in full or for debts that were not owed.13MONTHLY COMPLAINT REPORT: APRIL 2017

2.2Student loan complaints by stateTable 5 shows the student loan complaint volume percentage change by state.10 Some state-levelincreases can be attributed to the CFPB updating its student loan complaint form to acceptcomplaints about Federal student loan servicing, starting in late February 2016. The Bureau alsoinitiated an enforcement action against a large student loan servicer during the time periodcovered by this report. Some of the highlights include: Louisiana (846 percent), Washington (732 percent), and Kansas (691 percent)experienced the greatest percentage increase in student loan complaints from January March 2016 to January - March 2017. Wyoming (0 percent), Utah (57 percent), and Delaware (100 percent) experienced theleast percentage increase in student loan complaints from January - March 2016 toJanuary - March 2017. Of the five most populated states, Texas (601 percent) experienced the greatestpercentage increase and California (228 percent) experienced the least percentageincrease in student loan complaints from January - March 2016 to January - March2017.1014Three-month averages are rounded, and percentage changes are based on non-rounded averages.MONTHLY COMPLAINT REPORT: APRIL 2017

TABLE 5: STUDENT LOAN COMPLAINT VOLUME PERCENT CHANGE BY STATE15MONTHLY COMPLAINT REPORT: APRIL 2017

2.3Student loan complaints by companyEach month, this section highlights the most-complained-about companies to which we sentcomplaints.Companies are expected to respond to complaints sent to them within 15 days. If a complaintcannot be closed within 15 days, the company may indicate that its work on the complaint is “Inprogress” and provide a final response within 60 days. Company responses provided outside ofthose windows are considered untimely.Companies can alert the Bureau if they determine that a complaint is a duplicate or wassubmitted by an unauthorized third party, or when they are otherwise unable to confirm acurrent or prior commercial relationship with the consumer. Such complaints are not publishedin the Consumer Complaint Database or included in company-specific complaint volumepresented in this report.The most-complained-about companies highlighted in Table 6 received about 90 percent of allstudent loan complaints sent to companies for response in November 2016 - January 2017. Thissection highlights those complaints. Company-level information should be considered in contextof company size and/or market share. In addition, during the time period covered by this reportthe CFPB updated its student loan complaint form to accept complaints about Federal studentloan servicing, starting in late February 2016.16MONTHLY COMPLAINT REPORT: APRIL 2017

TABLE 6: MOST-COMPLAINED-ABOUT COMPANIES FOR STUDENT LOAN113 monthaverage: Nov2016 - Jan 2017% change vs. 3month periodlast year3 monthaverage %untimely:Nov 2016 Jan 2017Total Studentloan net73.07,200%0%756Sallie Mae46.7133%0%1,090Great Lakes40.33,933%0.8%420Wells yNavient Solutions,LLC.AES/PHEAAACS EducationServicesTransworldSystems Inc. Of these companies, Nelnet saw the greatest percentage increase in student loancomplaints (7,200 percent) from November 2015 - January 2016 to November 2016 January 2017. Of these companies, Transworld Systems, Inc. saw the least percentage increase instudent loan complaints (9 percent) during the same period. Wells Fargo had the greatest rate of untimely responses (17 percent) during the threemonth period of November 2016 - January 2017.11Three-month averages are rounded, and percentage changes are based on non-rounded averages.17MONTHLY COMPLAINT REPORT: APRIL 2017

3. Geographic spotlight:NevadaEach month we spotlight the complaints from one part of the country. This month we arehighlighting complaint trends in Nevada and the Las Vegas metro area. As of April 1, 2017,about 14,600 complaints were from Nevada consumers, and about 10,800 were from LasVegas.1212The Las Vegas metro area is defined as zip codes from the Las Vegas-Paradise, NV Core-Based Statistical Areas(CBSA). http://www.census.gov/population/metro/files/zip07 cbsa06.zip. Complaint counts are based onconsumer-provided ZIP code and unless otherwise noted the geographic spotlight section reflects cumulativecomplaint data since July 21, 2011.18MONTHLY COMPLAINT REPORT: APRIL 2017

3.1Nevada complaints by productFigure 4 shows the distribution of complaints by product for Las Vegas, Nevada, and the UnitedStates as a whole.FIGURE 4: LAS VEGAS VS. NEVADA AND NATIONAL SHARE OF COMPLAINTS BY PRODUCT Consumers in both Las Vegas and Nevada submitted debt collection complaints at a rateof 29 percent. These rates are similar to the 27 percent national average. Consumers in Las Vegas and Nevada complained about mortgages at a rate of 22 percentand 23 percent respectively, similar to the 23 percent national average.19MONTHLY COMPLAINT REPORT: APRIL 2017

Consumers in Las Vegas and Nevada complained about credit reporting at a rate of 19 percent and 18 percent respectively, similar to the 17 percent national average.3.2Nevada complaints over timeAverage monthly complaints increased 17 percent from January 2016 through March 2016 (292complaints per month) to January 2017 through March 2017 (343 complaints per month),similar to the national rate of 19 percent.FIGURE 5: NEVADA MONTHLY COMPLAINT VOLUME TREND20MONTHLY COMPLAINT REPORT: APRIL 2017

3.3Nevada complaints by companyFIGURE 6: MOST-COMPLAINED-ABOUT COMPANIES BY NEVADA CONSUMERS220206February 2016 - January 2017 Nevada 62OcwenUSAASavings6040200Wells Fargo ExperianProductsBank acct/serviceCredit cardCredit reportingEquifaxTransUnionDebt collectionMortgageOtherBank ofAmericaJPMorganChaseCitibankU.S.BancorpStudent LoanCompany-level information should be considered in context of company size and/or marketshare in a given geographic area. In the February 2016 - January 2017 period, Wells Fargo, Experian, and Equifax led thelist of most-complained-about companies by Nevada consumers.21MONTHLY COMPLAINT REPORT: APRIL 2017

APPENDIX eportingCredit cardConsumerloanBankaccount orservicesTABLE 7: TOTAL COMPLAINTS BY MONTH AND 385440915,63322MONTHLY COMPLAINT REPORT: APRIL 2017

ferDebtcollectionCreditreportingCredit cardConsumerloanBankaccount 3MONTHLY COMPLAINT REPORT: APRIL 2017

ingCredit cardConsumerloanBankaccount ,4997,25644,4031,163,15613Total column includes approximately 8,700 complaints where no specific consumer financial product was selectedby consumers.24MONTHLY COMPLAINT REPORT: APRIL 2017

ortingCredit cardConsumerloanBankaccount orservicesTABLE 8: TOTAL COMPLAINTS BY LOCALITY AND ,2364582,918111,559GeorgiaArizonaDelawareDistrict ofColumbiaFederatedStates 4292203,974MaineMarshallIslands25MONTHLY COMPLAINT REPORT: APRIL 2017

ortingCredit cardConsumerloanBankaccount 268312574,983New ,65043,462New Mexico5443305341,1611,925571,10530127292056,095New York9,4142,61010,44512,5861

provides a high-level snapshot of trends in consumer complaints. The Monthly Complaint Report uses a three-month rolling average, comparing the current average to the same period in . Student loan complaints showed the greatest percentage increase from January - March 2016 (773 complaints) to January - March 2017 (3,284 complaints .

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