ACA’s new white paper questions CFPB’s complaint database
ACA International recently released a new white paper as part of its ongoing initiative to collect original data about the credit and collection industry and show how debt collection companies impact the economy.
In its paper titled “Methodological and Analytical Limitations of the CFPB Consumer Complaint Database,” ACA highlighted that the Consumer Financial Protection Bureau’s consumer complaint database is “rife” with methodological and analytical flaws.
The white paper examined “specific concerns with the measures used to elicit and organize complaints, bias introduced into the data-collection process, and the means by which complaints are categorized by industry.” According to the white paper, problems with the database include non-exclusive reporting categories for complaints, self-selection and confirmation biases, and human error when a consumer misclassifies a complaint.
Because of the confusing complaint categories in the CFPB’s complaint portal, where the bureau gets its information for the database, many consumers accidentally submit debt collection complaints when they meant to identify a different financial service. CFPB director Richard Cordray acknowledged as much during a hearing before the U.S. House Financial Services Committee. Cordray testified that “when we look at debt, some of these complaints are simply misclassified.”
The white paper, which can be downloaded here, asserted that if the CFPB does not provide the appropriate context for complaints in its broad database, then consumers will lack important information for how to understand various complaints; it’s nearly impossible to interpret data that has not been presented in context.
“The CFPB is able to paint an unfairly negative picture of the credit and collection industry, and other legitimate businesses, because it relies on flawed data that has no context to it,” ACA International chief executive officer Patrick Morris said. “While the credit and collection industry continually seeks to strengthen its practices and reduce the number of complaints, the fact is, compared to the billion calls debt collectors make each year, the complaint rate is very small.”
Morris emphasized that ACA has continuously urged the CFPB to ensure that the complaint information it shares is based on meaningful, normalized data. In August of last year, ACA submitted comments to the CFPB in response to its request for information on data normalization, highlighting the particular importance of context when evaluating debt-collection complaints and the critical need for the CFPB to develop and implement data normalization procedures.
This ACA International white paper is part of a larger research initiative to collect more original data about the credit and collection industry that quantifies the ways in which debt collectors help consumers and the overall economy.
With debt collection as one of the most highly regulated industries in the country, the upcoming ACA International Convention and Expo will be highlighting important details any creditor and its employees who engage in debt collection should understand about the laws, as well as how to successfully comply with the CFPB and other state and federal regulators.
ACA International offers an intensive, three-day event that includes sessions focused on advanced debt collection compliance education, how to build a debt collection function, and how to engage a third-party debt collector. Businesses that provide loans of any kind should attend.
This year the event will be held June 16-18 at the Hyatt Regency Denver and Colorado Convention Center. Auto Remarketing, SubPrime Auto News and BHPH Report readers can use the code AUTO100 to register and receive a $100 discount by going to this website.
There is good reason for businesses in the auto finance space to attend. The largest and most influential event in the credit and collection industry, the 2016 ACA International Convention will include an exclusive, specialized education such as:
—Advanced compliance: conducting a risk assessment
—Advanced compliance: controls and corrective action
—Elements of a compliance management program
—How to select and review third-party agencies
Jim Donald, the former CEO of Starbucks and one of the Top 25 CEOs in the World as named by The Best Practice Institute, will present the event’s keynote speech.