Financial Pain Points for Older Consumers: A Look at the CFPB Complaint Database - AARP Spotlight
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A ARP PUBLIC POLICY INSTITUTE SEPTEMBER 2021 Spotlight Financial Pain Points for Older Consumers: A Look at the CFPB Complaint Database Joe Valenti AARP Public Policy Institute In the 10 years since the federal Consumer Financial transfer, virtual currency, and money service Protection Bureau (CFPB) opened its doors, it has businesses. While most complaints are closed with received roughly three million complaints about an explanation by the company involved, between financial products and services from consumers 15 percent and 22 percent of complaints made each across the country. Filing these complaints is a way year by people self-identifying as older adults result for people who have been treated unfairly—or who in some form of relief—whether monetary, such as have not been able to get issues resolved with their fees refunded, or nonmonetary, such as removal of bank, credit card or mortgage company, or other incorrect information. financial firm about a problem—to ultimately get This Spotlight examines complaints filed with answers and, in some cases, relief. the CFPB from individuals self-reporting as older Yet while the complaint mechanism serves as a adults. In part, it presents general findings about tool for the individual consumer, collectively these complaints filed since the establishment of the complaints become a powerful tool for research complaint database. But, due to changes in data and planning. Policy makers can use them to direct collection and reporting over time, it largely focuses supervision and enforcement of financial firms and on the time period from January 1, 2018, through to identify new policy challenges that need to be June 30, 2021. Notably, data from 2017 and earlier addressed. Meanwhile, companies and watchdogs years are often not directly comparable with current alike can use the public data to see whether high- complaint database statistics.2 level commitments are being kept. Each complaint to the CFPB includes the type of Among complaints published by the CFPB since product involved in that complaint, the name of the its inception, nearly 126,000 have come from company involved, and the specific issue the customer consumers who self-identified as being age 62 or is experiencing. Products and issues are also broken older—the CFPB’s statutory definition of older down into smaller categories of subproducts and adults.1 The most frequent complaints received from subissues. In addition, since 2015, a consumer also older adults included issues with errors on their has had the choice to make public the substance of credit reports, difficulties with mortgage payments, his or her complaint by sharing the actual complaint problems they experience when managing a narrative with any identifying details removed—a checking or savings account, and trouble dealing handful of which are included in this paper.3 While with debt collectors. Emerging trends appear in the each complaint is important on its own, these data data as well, including a small but growing number points all make it possible to highlight issues of of complaints about scams and fraud within money particular importance to older adults.
A ARP PUBLIC POLICY INSTITUTE SEPTEMBER 2021 Complaint Database Basics: The Number legacy of historical discrimination and differences in and Origin of Consumer Complaints the types of products seen in different communities.7 By mid-2021, the CFPB had published a total State-by-state breakdowns—another type of of nearly 2.2 million consumer complaints geographic variation captured by the database—also about financial products and services within its show wide variation in the number of complaints jurisdiction.4 New complaints per year across all submitted by people self-identifying as older adults. ages increased steadily from over 72,000 in 2012 In 15 states, over 1,000 of these complaints have to over 277,000 in 2019, before jumping to nearly been reported to the CFPB since 2018. Floridians half a million in 2020. Complaints received from who self-reported as age 62 or older had the highest people self-identifying as older adults (age 62 or total number of complaints during this time older) totaled 16,444 in 2020, the third highest year period—7,257 complaints between January 2018 on record after 2016 (18,366 complaints) and 2015 and June 2021—with California close behind with (16,803 complaints). In the first six months of 2021, 7,204 complaints. North Dakotans who self-reported more than 237,000 additional complaints overall— as age 62 or older submitted the fewest, with only including 8,897 complaints by older adults—put the agency on track to potentially exceed 2020’s 40 complaints. Comparing the total number of older complaint levels. adult complaints against the population age 65 and older gives a rough estimate of per capita complaint The true number of complaints coming from older levels.8 On a per capita basis, older Floridians had adults is unclear, since respondents are not required the fourth-highest number of complaints, behind to give their age. In 2019, about 20 percent of all the District of Columbia, Nevada, and Delaware. US residents were age 62 or older.5 From 2014 to 2016, about 1 in 10 CFPB complaints was filed by an older adult. This percentage dropped to only Other Consumer Complaint Databases 3.7 percent in 2020 and the first six months of 2021. This underrepresentation of older adults in The Consumer Financial Protection Bureau (CFPB) the CFPB database may reflect people not giving Consumer Complaint Database is not the only their age when filing a complaint, or it may be complaint database managed by the federal caused by differences in awareness of the CFPB government that takes complaints from the general and its complaint database, in the types of financial public and publishes them. However, the CFPB concerns about which people may be inclined to file database is notable for the number of individual a complaint, or other factors. Notably, the CFPB is data points made publicly available. The Federal not the only federal agency to maintain a consumer Trade Commission’s Consumer Sentinel database tracks complaints about practices across a wide complaint database, but certain aspects make it range of consumer products. The database also unique (see sidebar, “Other Consumer Complaint includes cases of fraud and identity theft, but only Databases”). aggregate complaint statistics are publicly available. In addition to the data gaps resulting from age The Consumer Product Safety Commission (CPSC)’s disclosure being optional for complaint filers complaint database, http://www.saferproducts.gov, (service-member status is as well), demographic tracks safety-related complaints and distinguishes data from CFPB complaints contain other gaps—in complaints by victims age 65 or older. Like the part, intentionally so, to protect consumer privacy. CFPB’s database, the CPSC also publishes complaint narratives. The National Highway Transportation Although data on complaints by race and ethnicity Safety Administration collects and publishes are not available, a 2021 study by the agency found complaints on vehicles including a narrative, but not that, in general, more diverse counties—specifically, the filing driver’s age.9 Airline consumer complaints where more than 60 percent of the population was are compiled by the US Department of Transportation Hispanic or non-White—filed more complaints by airline and category,10 but customer ages and overall, and that this trend was evident across many narratives are not publicly available. major financial products.6 This may reflect both the 2
A ARP PUBLIC POLICY INSTITUTE SEPTEMBER 2021 There are several ways that people can file a other commercial purposes, as well as companies complaint with the CFPB. In recent years, over that offer credit repair services. 90 percent of complaints from older adults came Meanwhile, credit or prepaid card complaints have either through the CFPB’s website or by phone, grown as a share of older adult complaints in recent which is consistent with how people overall submit years, forming the second largest category for 2020 complaints. The CFPB received a smaller share of (at 23 percent) and the third largest category in the complaints by mail, through a referral from another first six months of 2021 (19 percent). Complaints government agency, or by fax. about debt collection have declined somewhat in Credit Reporting, Mortgage, and Credit recent years as a relative share of all complaints, Card Products Receive the Most Older from 17 percent in 2018 to 12 percent in 2020 and Adult Complaints early 2021. Complaints about banking products The top five products for which the CFPB received such as checking or savings accounts have ranged complaints have been largely consistent over time from 9 percent to 13 percent between 2018 and (figure 1). About 90 percent of complaints deal early 2021, placing them in fifth place for the first with five types of products: checking or savings three years and narrowly overtaking debt collection accounts, credit or prepaid cards, credit reporting, for fourth place in the first half of 2021. A smaller debt collection, and mortgages. Since 2018, the share of complaints deal with other product areas largest share of older adult complaints have such as money transfers, payday and title loans, concerned credit reporting, with about one-quarter student loans, and vehicle loans. In addition to the of all complaints in this category, which includes a distribution of complaints, the overall volume of wide range of personal consumer reports that may complaints from filers who self-reported as being be used for banking, employment, insurance, or older adults over time is also important. FIGURE 1 Older Adult Complaints to the CFPB by Product Type (Top Five Products and All Others), 2018–2021* Credit reporting, credit repair services, or other personal consumer reports Mortgage Credit card or prepaid card Checking or savings account Debt collection All others 2018 25% 22% 17% 9% 17% 10% 2019 26% 20% 18% 13% 13% 10% 2020 25% 18% 23% 12% 12% 10% 2021* 25% 21% 19% 13% 12% 11% Source: AARP Public Policy Institute tabulations of CFPB Consumer Complaint Database. * 2021 data reflect January 1 through June 30. Totals may not equal 100 percent due to rounding. 3
A ARP PUBLIC POLICY INSTITUTE SEPTEMBER 2021 The number of complaints in most product areas such as payday and auto title loans—but people has increased over time (figure 2). Complaints in who use these products do still file numerous and just the first six months of 2021 also grew, in some significant complaints. Meanwhile, consumers do categories exceeding complaints for the entire not have a choice about whether they interact with year of 2018. This suggests that for some products, certain financial products or services, such as credit total complaint volume for 2021 may well exceed reporting and debt collection, but are nevertheless 2020 levels. There were some exceptions to these affected by them. For example, information on a increases: payday, title, student, or personal loan credit report could affect not just lending decisions complaints all declined slightly in 2020. Some of these declines might reflect changes in financial but also getting a job, renting an apartment, or behavior during the pandemic, including the obtaining a cell phone without a deposit. payment pause on student loans owned by the Top 10 Issues for Older Adults Remain federal government—the vast majority of all loans in this market. Largely Consistent from Year to Year Going beyond the product level, the issues raised It is important to note that complaint levels do in complaints from individuals self-identifying not simply reflect consumers’ satisfaction or dissatisfaction with a particular product, and as older adults provide an even clearer picture of official complaints may reflect only a fraction of particular concerns. Since 2018, nearly two-thirds of the challenges older adults face with that product. complaints each year have dealt with just 10 issues. Products that are broadly used, such as basic While the relative volume of each type of complaint checking and savings accounts, will potentially have has changed somewhat, many of these issues in a larger number of complaints than products used the top 10 are highly consistent from year to year by a much smaller percentage of older adults— (figure 3). FIGURE 2 Older Adult (Age 62+) Complaints to the CFPB by Product Type, 2018–2021* 2018 2019 2020 2021* 4,500 4,000 3,500 3,000 2,500 2,000 1,500 1,000 500 0 Credit Mortgage Credit card Debt Checking Money Vehicle Payday Student reporting, or prepaid collection or savings transfer, loan or loan, title loan credit repair card account virtual lease loan, or services, or currency, personal other personal or money loan consumer service reports Source: AARP Public Policy Institute tabulations of CFPB Consumer Complaint Database. * 2021 data reflect January 1 through June 30. 4
A ARP PUBLIC POLICY INSTITUTE SEPTEMBER 2021 FIGURE 3 Top 10 Financial Issues Identified by Older Adults (Age 62+) in the CFPB Complaint Database, 2020 Credit reporting: Incorrect information on your report 2,284 Mortgage: Trouble during payment process 1,491 Checking or savings account: Managing an account 1,336 Credit card or prepaid card: Problem with a purchase shown on your statement 1,331 Credit reporting: Problem with a credit reporting company’s 981 investigation into an existing problem Debt collection: Attempts to collect debt not owed 954 Mortgage: Struggling to pay mortgage 633 Mortgage: Applying for a mortgage or refinancing an existing mortgage 540 Credit card or prepaid card: Fees or interest 399 Credit card or prepaid card: Other features, terms, or problems 393 Source: AARP Public Policy Institute tabulations of CFPB Consumer Complaint Database. Similar to previous years, the top issue in 2020, the minimum payment due, not my actual with thousands of complaints filed on it, dealt with payment every month. The only thing I carry credit reporting: individuals complaining about a balance on is my newly acquired auto loan. incorrect information on their credit reports. These I have a zero balance on everything else. This complaints may have been filed against a credit is incomplete and incorrect information on reporting agency or directly against a “furnisher”— my credit report which causes my [score] to that is, the lender or other company submitting be erroneously lower than it should be. I am recently widowed and have always had a information to the credit bureaus. Some estimates [score] above X. This is causing me a great suggest that as many as one in five credit reports deal of stress.” contains an error that could be disputed.11 The —Complaint under “Credit reporting: Incorrect following are two examples of credit reporting information on your report,” Mississippi, 2019 complaints from older adults concerning incorrect information. “Company is wrongfully reporting that I was late in paying three of my son’s student loan “My credit score keeps going down and payments. I had no notice that payment was the reason given is that there’s a high ratio due for my son’s account nor did I know that between balances and credit limit. This payment had not been made. I should not is incorrect and incomplete information be reported as having been late in making because I pay my two credit card balances payments I did not know were due. When in full upon receipt of the monthly statement. the credit alert service I subscribe to notified What appears in my credit report is merely of company’s erroneous report regarding 5
A ARP PUBLIC POLICY INSTITUTE SEPTEMBER 2021 my credit I immediately contacted my son Another top-10 complaint each year was that people and made sure he rectified his accounts. In were struggling to pay their mortgage. According to addition, the report is misleading as it refers the CFPB, these complaints were particularly acute to three separate accounts and yet lists at the beginning of the COVID-19 pandemic.13 just one account number for each separate Notably, the CFPB’s mortgage product category erroneous report. This has caused substantial covers all types of mortgages: traditional “forward” harm as the summary is that I have ‘too mortgages and other mortgage products such as many’ installment accounts with a delinquent reverse mortgages and home equity loans or lines or derogatory payment status. Further it of credit. Of all mortgage complaints received is misleading as it does not reflect the fact concerning these two issues, the vast majority dealt that I was a co-signer who was not informed with forward mortgages, including conventional, a payment was due from the debtor. These Federal Housing Administration, and Veterans wrongful actions have caused me substantial Affairs–backed loans. Approximately 9 percent to damages and prohibit me from refinancing 14 percent of older adults’ mortgage complaints each my home. My credit would be perfect but for year were made regarding nonforward and home these wrongful reports.” equity mortgage products.14 —Complaint under “Credit reporting: Incorrect information on your report,” Oregon, 2020 In addition to specific credit reporting and mortgage issues, other issues remained prevalent during The second most common issue each year was this time period. Attempts to collect debt that was trouble during the payment process for mortgages. not owed, problems with a purchase shown on Payment process issues include applying principal a credit card statement, fees or interest on credit payments and taking advantage of forbearance cards, managing a checking or savings account, options as well as coming out of forbearance.12 In and problems with a credit reporting company’s some cases, these complaints also involve payment investigation were all among the top 10 in each year services handling payments incorrectly: from 2018 through the first six months of 2021.15 “My mortgage payments have not been Looking at the rankings from these years, some applied to my account. My husband and I issues have newly emerged while others have have never been 30 days late on mortgage declined in prevalence. During this time, problems payments. We continuously receive late with applying for a mortgage or refinancing an notices and foreclosure letters. This has been existing mortgage both moved up in the rankings, going on [for some time]. The mortgage as did closing on a mortgage. This trend potentially company is stating that we are approximately reflects the recent challenges faced by borrowers [$3,800.00] behind in our mortgage. I have during the pandemic. Most notably, while still not called the mortgage company to let them among the top 10, fraud or scam complaints also know that we have NEVER paid our mortgage increased markedly in the rankings, from 29th late. We pay our mortgage via [a payment in 2018 to 12th for the first half of 2021. These service] and we have all of our receipts. I accounted for a small number of complaints in tried to set up online payments through the total: 169 in the first six months of 2021 and 200 mortgage company’s website but was told in 2020. The vast majority of these fraud and by a customer service representative that scam complaints involved money transfer, virtual we must bring our account current. This is currency, or money service businesses. This increase very frustrating because our account is not mirrors a rise in older adults’ fraud complaints filed delinquent. The company did not apply our with the Federal Trade Commission.16 payments correctly.” Complaints about closing a checking or savings —Complaint under “Mortgage: Trouble during account have also increased, possibly as the pandemic payment process,” Virginia, 2020 and recession led to changes in financial habits.17 6
A ARP PUBLIC POLICY INSTITUTE SEPTEMBER 2021 Meanwhile, credit card complaints about fees or For the remainder of complaints—roughly 15 percent interest as well as other features, terms, or problems to 22 percent of all complaints per year—the moved down in the rankings, as did debt collection customer making the complaint receives some type complaints about threatened or actual negative of relief from the company. Each year, 7 percent or legal action as well as complaints about debt to 9 percent of complaints result in monetary collectors’ communication tactics. Some of these may relief, and an additional 7 percent to 14 percent of reflect pandemic-related relief as well as limits on debt complaints result in nonmonetary relief, which may collection activity in certain jurisdictions, particularly include actions such as stopping collections calls while courthouses remained closed. and correcting account information or documents.18 At the state level, the top three issues vary Between January 2012 and June 2021, a total of 9,742 somewhat but remain fairly consistent. In all older adult complaints resulted in monetary relief, and 50 states as well as the District of Columbia and 13,199 resulted in nonmonetary relief. These reflect Puerto Rico, incorrect information on credit reports more than 18 percent of known complaints made to was among the top three. In 44 states, the District the CFPB by older adults during this time period. of Columbia, and Puerto Rico, trouble during the mortgage payment process was also among the Even in cases where customers do not individually top three. Several other issues rounded out the top receive relief, complaints may nevertheless be three, including managing a checking or savings helpful systemwide. They illustrate particular account (19 states, the District of Columbia, and flaws in products, or in people’s expectations about Puerto Rico), a problem with a purchase shown on a these products, that may improve product design credit card statement (19 states), and debt collectors or customer service practices. They also identify attempting to collect a debt that was not owed for both federal and state regulators whether new (16 states). In six states, the top three included a forms of regulation or enforcement are necessary to problem with a credit reporting company’s existing protect consumers. And as a public resource, these investigation. In South Dakota and Wyoming, it financial concerns are made available to a broad included applying for or refinancing a mortgage, range of researchers and individuals seeking to and in North Dakota, it included debt collection track challenges in the marketplace. communication tactics. FIGURE 4 Complaint Outcomes Include Relief for How Complaints Filed by Older Adults in 2020 about 23,000 Older Adults Were Closed by Companies After a complaint is filed with the CFPB, it is then sent to the financial company mentioned in that Monetary relief complaint. The company has a chance to verify it; 8.01% for example, for a bank account complaint, the bank Nonmonetary relief verifies that someone actually has an account at 7.89% that bank. The company must then investigate and Untimely response provide an initial response within 15 days as well as a Explanation 0.46% final response within 60 days. The way the company 83.64% In progress ultimately closed the complaint is then made public 0.01% (figure 4). The vast majority of complaints—three- quarters or more—are closed with an explanation. This may reflect a misunderstanding of how a product or service works, or what the financial company’s policies or obligations are. In a very small Source: AARP Public Policy Institute tabulations of CFPB share of complaints (less than 1 percent per year), the Consumer Complaint Database. company fails to provide a timely response. 7
A ARP PUBLIC POLICY INSTITUTE SEPTEMBER 2021 Conclusion data collection from the complaint portal, the Ten years after its creation, the Consumer Financial CFPB should also explore ways to enhance public Protection Bureau’s complaint database serves as complaint reporting and analysis based on age and a powerful tool for individuals to file complaints other demographic factors to identify particular about a financial product or service, to see that areas of concern for various communities. their voices are heard, and in some cases to obtain Otherwise, concerns frequently raised by older relief. While the true number of complaints filed by adults, or among people of a particular race or older adults is unknown, it is clear that older adults ethnicity, for example, might be overlooked. submit complaints to the CFPB about a wide range Meanwhile, financial services companies should take of financial products, with particularly frequent older adults’ CFPB complaints seriously and even concerns about credit reporting, mortgages, credit use the information obtained from the database as cards, bank accounts, and debt collection. a resource to support their business. In response to Such information makes these complaints and the recurring problems that older consumers raise, they data that result from them helpful not only to the should explore modifying their products, practices, individual filer but also to stakeholders who can and customer engagement to meet the needs of provide solutions. The CFPB and other stakeholders this growing demographic. Additionally, public and should expand awareness of the complaint portal private-sector entities should also consider these and its potential to community organizations, complaints when vetting potential financial services researchers, and advocates. This would increase company partners. These steps would increase the both the number of complaints received and complaint database’s utility in the years to come for their value. Given the limitations of demographic consumers, business, and government alike. 1 12 USC §5493 (g)(1). People filing complaints with the CFPB have the option to give their age and self-identify as an older adult, a service member, or both; this is the only available age-based distinction in these data. In this paper, “Older Adult” complaints refer to any record in the complaint database where the “Tags” field contains either “Older Adult” or “Older Adult, Servicemember.” According to the CFPB, 26 percent of complaints in 2020 included the complainant’s age (whether over or under 62), of which only those 62 or older were reported publicly. Consumer Financial Protection Bureau, “2020 Consumer Response Annual Report,” March 2021, https://files.consumerfinance.gov/f/documents/cfpb_2020-consumer-response- annual-report_03-2021.pdf. 2 Reporting categories in the database changed on April 24, 2017. As a result, 2017 complaints could fall under either old or new categories. For example, complaints about credit cards and prepaid cards were separate categories pre‑2017, while they were a single category afterward, and complaints about a bank account or service pre-2017 were relabeled as complaints about a checking or savings account. Complaint categories for debt collection, mortgages, student loans, and vehicle loans or leases remained consistent. For more information, see CFPB technical release notes: https://cfpb.github.io/api/ccdb/release-notes.html. Additionally, complaints during the CFPB’s early years did not reflect the full spectrum of financial products and services that the database covers today. 3 Complaints featured in this report have been lightly edited (e.g., removing misspellings, typos, or excess spaces). 4 The number of published complaints is lower than the number of total complaints received because many complaints the CFPB receives are ultimately referred to other agencies if they are outside the agency’s jurisdiction, such as complaints concerning banks and credit unions with less than $10 billion in assets. 5 US Census Bureau Current Population Survey, https://www2.census.gov/programs-surveys/demo/tables/age-and-sex/2019/ older-population/2019older_table1.xlsx. 6 Consumer Financial Protection Bureau, “Complaint Bulletin: County-Level Demographic Overview of Consumer Complaints,” April 2021, https://files.consumerfinance.gov/f/documents/cfpb_complaint-bulletin_county-level-demographic-overview- consumer-complaints_2021-04.pdf. 7 Joe Valenti and Danyelle Solomon, “Communities of Color Cannot Afford a Weakened CFPB,” Center for American Progress, 2017, https://www.americanprogress.org/issues/economy/reports/2017/03/28/429270/communities-color-cannot-afford- weakened-cfpb/. 8
A ARP PUBLIC POLICY INSTITUTE SEPTEMBER 2021 8 While the age cutoff for the database is 62, per capita calculations are based on 2018 census population estimates as reported in Population Reference Bureau, “Which US States Have the Oldest Populations?,” March 16, 2019, https://www.prb.org/ resources/which-us-states-are-the-oldest/. 9 National Highway Traffic Safety Administration, “NHTSA Datasets and APIs,” https://www.nhtsa.gov/nhtsa-datasets-and-apis (last accessed June 2021). 10 US Department of Transportation, “Aviation Consumer Protection: File a Consumer Complaint,” https://www.transportation.gov/ airconsumer/file-consumer-complaint (last accessed June 2021). 11 Federal Trade Commission, “Report to Congress under Section 319 of the Fair and Accurate Credit Transactions Act of 2003,” December 2012, https://www.ftc.gov/sites/default/files/documents/reports/section-319-fair-and-accurate-credit- transactions-act-2003-fifth-interim-federal-trade-commission/130211factareport.pdf. 12 CFPB, “2020 Consumer Response Annual Report.” The CFPB also recognized that a large number of mortgage complaints dealt with navigating the forbearance process during the pandemic. Consumer Financial Protection Bureau, “Complaint Bulletin: Mortgage Forbearance Issues Described in Consumer Complaints,” May 2021, https://files.consumerfinance.gov/f/ documents/cfpb_mortgage-forbearance-issues_complaint-bulletin_2021-05.pdf. 13 CFPB, “2020 Consumer Response Annual Report.” 14 For example, among older adult consumers who reported in 2020 that they were struggling to pay their mortgages, 6.5 percent had a home equity loan or line of credit, and 3.5 percent had a reverse mortgage. Among older adult consumers who reported in 2020 having trouble with the payment process on their mortgage, 6.5 percent had a home equity loan or line of credit, and 4.4 percent had a reverse mortgage. In both cases, this was a smaller share of all older adult complaints regarding that particular mortgage issue than in 2018 or 2019. For complainants who did not self-identify as older adults (of which most are presumably younger than age 62), roughly 5 percent of 2020 mortgage complaints regarding these two specific issues pertained to home equity loans or lines of credit, and less than 1 percent pertained to a reverse mortgage. This is not surprising given that federally guaranteed reverse mortgages (known as Home Equity Conversion Mortgages, or HECMs) are available only to homeowners age 62 or older. 15 The debt collection issues above include being called about debts the individuals do not recognize, debts that belong to someone else, and collections for services or products they did not receive. Credit card statement disputes include fraud or identity theft as well as attempts to obtain refunds or chargebacks for canceled travel, sporting events, concerts, and so on. Managing a checking or savings account includes complaints about processes for deposits, withdrawals, ATM cards, funds availability, and bank branch closures. CFPB, “2020 Consumer Response Annual Report.” 16 AARP analysis of Federal Trade Commission Consumer Sentinel data, “Reported Frauds and Losses by Age,” https://public.tableau.com/app/profile/federal.trade.commission/viz/FraudReports/AgeFraud (last accessed July 2021). 17 For example, during the prior recession, people who lost jobs often closed bank accounts as a result. Across multiple cycles of the Federal Deposit Insurance Corporation’s survey of unbanked households, the most frequent reason those without a checking or savings account give for not having an account is a lack of money to put in it. Joe Valenti, “Financial Access Challenges for Older Adults,” AARP Public Policy Institute, September 9, 2020, https://www.aarp.org/ppi/info-2020/financial- access-challenges-for-older-adults.html. 18 “The Bureau defines ‘monetary relief’ as objective, measurable, and verifiable monetary relief to the consumer as a direct result of the steps that have or will be taken in response to the complaint. The Bureau defines ‘non-monetary Spotlight 1217900, September 2021 relief’ as other objective and verifiable relief to the consumer as a direct result of the steps that have or will be taken in response to the complaint. Examples © AARP PUBLIC POLICY INSTITUTE of non-monetary relief to consumers include stopping unwanted calls from debt 601 E Street, NW collectors; correcting account information; correcting inaccurate data provided Washington DC 20049 or reported in consumers’ credit reports; issuing corrected documents; restoring Follow us on Twitter @AARPpolicy account access; and addressing formerly unmet customer service issues. ‘Closed On facebook.com/AARPpolicy with explanation’ indicates that the steps taken by the company in response to the www.aarp.org/ppi complaint included an explanation that was tailored to the individual consumer’s complaint. For example, this category is used if the explanation substantively For more reports from the Public Policy meets the consumer’s desired resolution or explains why no further action will be Institute, visit http://www.aarp.org/ppi/. taken. Companies should select ‘Closed with explanation’ category when specific, verifiable monetary or non-monetary relief was not provided to the consumer https://doi.org/10.26419/ppi.00147.001 in response to issues raised in the complaint.” Consumer Financial Protection Bureau, “2020 Consumer Response Annual Report.” 9
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