ACA International, the largest trade group for the third-party collection industry, released a white paper Thursday analyzing Consumer Financial Protection Bureau consumer complaints regarding debt collection. ACA commissioned Ernst & Young to review 5,625 consumer complaints made public in early November by the CFPB.

The following are key findings identified by Ernst & Young based on analysis of the data released by the CFPB including product, sub-product, issue, complaint submission date and response timeliness:

· CFPB data comingles first-party and third-party collection complaints. Of the 5,625 consumer complaints made public, approximately 1,221 or 22% were made against companies conducting first-party collections (financial companies or other direct creditors).

· Of the 597 third-party collection companies listed, 511 had fewer than 10 complaints. Moreover, 430 third-party companies had fewer than five complaints.

· The highest number of identifiable complaints was for credit card and medical debts.  The most reported concern for consumers was being contacted about a debt they did not believe they owed.

· Nearly all of the complaints received by the CFPB were responded to in a timely fashion.

· Ninety-three percent of complaints were “closed, closed with non-monetary relief or closed with explanation” in the database; of these about 1% of complaints were listed as “closed with monetary relief."

While the CFPB complaint resolution process is a step in the right direction compared to other federal consumer complaint repositories, ACA offers the following suggestions to the CFPB to improve the complaint database:

· Distinguish between first-party or third-party debt collection companies to remove uncertainty about complaints being reported more than once.

· Provide more consumer detail to debt collectors who are the subject of a complaint to increase the likelihood of more easily identifying the information needed to resolve the consumer’s complaint.

· Adopt a definition of a complaint that is limited to consumer allegations of wrongful conduct and does not include the amorphous concept of general consumer dissatisfaction outside of wrongful conduct. The CFPB’s description of a complaint, coupled with the fact that it does not investigate whether any real wrongdoing has occurred or whether it is an inquiry/request for additional information, enables the data to create an inaccurate perception of the extent of wrongful conduct.

“ACA International members take consumer complaints very seriously,” ACA International CEO Pat Morris said.  “As an industry that makes approximately 1 billion consumer contacts per year, and actively encourages communication between consumers and a third-party debt collector, looking beyond the traditional topline complaint volumes provides valuable perspective.”

To access ACA's white paper, click here.

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