The Consumer Financial Protection Bureau (“CFPB”) released its first “Consumer Response Annual Report” on March 31, 2012 (“Annual Report”), summarizing over 6,000 consumer credit card complaints that the CFPB received from July 21 through December 31, 2011. According to the Annual Report, the most common complaints related to billing disputes, identity theft/fraud/embezzlement and APR/interest rates, accounting for over 34% of all complaints. The least common complaints involved collection practices and fees (approximately 11%). The year-end findings are consistent with the CFPB’s earlier findings revealed in its November 30, 2011 interim report.
Credit card companies and other financial services providers should take note – not only for their own customer service purposes, but also because the information in these reports likely signals where the CFPB will focus its attention next with respect to credit cards. In its interim report, for example, the CFPB found that the data revealed consumers were “struggling” to understand the terms of their credit cards and associated services. Moreover, the complaints suggested that there was a “mismatch” between consumer understanding and product function or issuer practices. Consequently, based on the annual report findings, one might expect the CFPB to take further supervisory or enforcement action to improve the disclosures relating to issuers’ billing practices and interest rate calculations in response to the high number of complaints in these particular areas. Such action may include increased scrutiny of cardholder agreements and disclosures with respect to their compliance with Regulation Z, UDAAP, and other applicable laws and regulations.