April 2015

A snapshot of complaints 

received from 

Servicemembers, 

Veterans, and their 

families
2 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

Message from 

Holly Petraeus

Assistant Director for the Office of 

Servicemember Affairs

Hello and welcome from the Office of Servicemember Affairs (OSA) at the Consumer Financial 

Protection Bureau (CFPB)!

This is our third complaint report1 detailing the data and trends surrounding complaints 

submitted to the CFPB by servicemembers, veterans and their families. As you can see in the 

report, our complaint volume has steadily risen since July 2011 when we first started taking 

complaints. In 2014, we received more than 17,000 complaints from servicemembers, veterans, 

and their family members, and I am particularly pleased to report that this population has

recovered more than $1.6 million by submitting complaints to the CFPB. 

Since the Bureau began accepting consumer complaints, the CFPB has regularly received reports 

from servicemembers and their families who are dealing with troublesome credit card and bank 

account fees. Servicemembers tend to be at a disadvantage in this area because these fees may 

be assessed when the account holder is unable to use the account due to a deployment or a 

mandatory move. And the problem can be made even worse if a family member the 

servicemember has designated to act as their agent is not permitted to gain access to the account

and take appropriate action while the account holder is away. This year, we will highlight this 

 

1 http://files.consumerfinance.gov/f/201403_cfpb_snapshot-report_complaints-received-servicemembers.pdf
3 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

concern in a special section entitled “Spotlight on a financial concern associated with military 

life: The difficulty of managing accounts.”

The CFPB was involved in dozens of enforcement actions in 2014, three of which particularly 

impacted servicemembers. These enforcement actions, detailed in Section 1.3, provided millions 

of dollars in relief to servicemembers and their families. Enforcement actions can also spotlight

systemic vulnerabilities that enable predatory lenders to target and take advantage of military 

members and veterans. An example would be the CFPB’s 2013 enforcement action2 against a 

sub-prime auto lending program. As a result of that action, an interagency team was formed to 

take a closer look at the military pay-by-allotment system. The findings of this team led the U.S. 

Department of Defense to announce critical changes to protect servicemembers using the 

military discretionary allotment system, effective January 2015.

While much has happened with the work of the Office of Servicemember Affairs over the past 

year, our mission remains the same – to work on consumer financial challenges affecting 

military personnel, veterans, and their families. Those who serve, or have served, our country 

should not have to worry about falling victim to unfair, deceptive, or abusive financial practices. 

It’s an honor for me and my staff to represent the military community here at the CFPB and to 

make sure that its concerns are heard – and that we do something about them.

Sincerely, 

Holly Petraeus

 

2 http://www.consumerfinance.gov/newsroom/cfpb-orders-auto-lenders-to-refund-approximately-6-5-million-toservicemembers/
4 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

Table of contents

Message from Holly Petraeus ...................................................................................2

Table of contents.........................................................................................................4

1. Fulfilling OSA’s mission ......................................................................................5

1.1 Monitoring complaints ............................................................................. 5

1.2 Outreach .................................................................................................26

1.3 Enforcement actions...............................................................................29

2. Spotlight on a financial concern associated with military life: The 

difficulty of managing accounts........................................................................31

Appendix A: ...............................................................................................................37

More about the CFPB ...................................................................................... 37
5 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

1. Fulfilling OSA’s mission

1.1 Monitoring complaints

In keeping with the CFPB’s statutory responsibility and its commitment to accountability, the 

following pages provide an overview of the handling and analysis of complaints submitted by 

servicemembers, veterans, and their families to the Bureau from July 21, 2011 through 

December 31, 2014.

The CFPB’s Office of Consumer Response screens all complaints submitted by consumers based 

on several criteria, including whether the complaint should be sent to another regulator, 

whether the complaint is complete, and whether the complaint is duplicative of a prior 

submission by the same consumer. Screened complaints are forwarded via a secure web portal 

to the appropriate company.3 The company’s role is to review the information, communicate 

with the consumer as needed, and determine what action to take in response. The company then 

reports back to the consumer and the CFPB via the secure company portal, and the Bureau 

invites the consumer to review the response and provide feedback. Consumer Response reviews 

the feedback consumers provide about company responses, using this information along with 

other information such as the timeliness of the company’s response, for example, to help 

prioritize complaints for investigation.4 Consumers who have submitted complaints to the 

Bureau through Consumer Response can log onto the secure consumer portal available on the 

 

3 Consumer Response may refer a complaint to the appropriate regulator if, among other reasons, it does not involve 

a product or market that is within the Bureau’s jurisdiction or that is currently being handled by the Bureau.

4 The CFPB requests that companies respond to complaints within 15 calendar days. If a complaint cannot be closed 

within 15 calendar days, a company may indicate that its work on the complaint is “In progress” and provide a final 

response within 60 calendar days.
6 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

CFPB’s website, or call a toll-free number, to receive status updates, provide additional 

information, and review responses provided to the consumer by the company.

Throughout this process, subject-matter experts help monitor certain complaints. For example, 

the Office of Servicemember Affairs coordinates with Consumer Response on complaints 

submitted by those who self-identify as servicemembers, veterans or their dependents.

The Bureau continually strives to improve data quality and protect sensitive information, while 

increasingly making data about the complaints the CFPB receives available through reports to 

Congress and the public, and by sharing certain data with the public through the Consumer 

Complaint Database.

1.1.1 Complaints handled by the CFPB

Between July 21, 2011 and December 31, 2014, the CFPB handled approximately 518,400

consumer complaints.5 Approximately 59% of all consumer complaints were submitted through 

the CFPB’s website and 9% via telephone calls. Referrals accounted for 22% of all complaints 

received, with the remainder submitted by mail, email, and fax.6

 

5 Unless otherwise noted or the context suggests otherwise, the various tables and complaint tabulations appearing 

herein cover this period.

6 This analysis excludes multiple complaints submitted by a given consumer on the same issue and whistleblower tips. 

All data are current as of December 31, 2014. 
7 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

1.1.2 Servicemembers’ complaints handled by the CFPB 

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) created 

the Office of Servicemember Affairs (OSA) to see that military personnel and their families 

receive a strong financial education so they can make better-informed consumer decisions; to 

monitor their complaints about consumer financial products or services; and to coordinate the 

efforts of Federal and State agencies to improve consumer protection measures relating to those 

products or services for military families. While Dodd-Frank defined servicemembers as ActiveDuty, Reserve, or National Guard, OSA works for military retirees, veterans, and their families 

as well (collectively “servicemembers”), serving all who have worn the uniform. 

Between July 21, 2011 and December 31, 2014, approximately 29,500 complaints were 

submitted by servicemembers.

FIGURE 1: SERVICEMEMBERS’ COMPLAINTS BY PRODUCT

0.3%

0.3%

0.4%

2%

3%

5%

8%

8%

9%

24%

39%

Other Financial Service

Prepaid

Money Transfers

Payday Loan

Student Loans

Consumer Loan

Bank Account or Service

Credit Card

Credit Reporting

Mortgage

Debt Collection
8 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

The tables and figures presented below show complaints by type, actions taken, company 

responses, and servicemembers’ feedback about company responses.7

Debt collection complaints 

Table 1 shows the types of debt collection complaints for the approximately 11,600 debt

collection complaints the CFPB has received from servicemembers.

TABLE 1: TYPES OF DEBT COLLECTION COMPLAINTS REPORTED BY SERVICEMEMBERS

Types of Debt Collection Complaints %

Continued attempts to collect debt not owed (Debt was discharged in 

bankruptcy, debt resulted from identity theft, debt was paid, debt is not 

mine)

41%

Communication tactics (Frequent or repeated calls, called outside of 

8am-9pm, used obscene, profane or other abusive language, threatened to 

take legal action, called after sent written cease of communication notice)

19%

Taking/threatening an illegal action (Threatened to arrest me or take me to 

jail if I do not pay, threatened to sue me on debt that is too old to be sued 

on, sued me without properly notifying me of lawsuit, sued me where I did 

not live or did not sign for the debt, attempted to/collected exempt funds, 

seized or attempted to seize property)

12%

Disclosures/verification of debt (Did not receive notice of right to dispute, 

not enough information to verify debt, did not disclose communication was 

an attempt to collect a debt)

12%

False statements or representation (Attempted to collect wrong amount, 

impersonated attorney, law enforcement or government official, indicated 

committing crime by not paying debt, indicated should not respond to 

lawsuit)

10%

 

7 Percentages may not sum to 100% due to rounding.
9 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

Improper contact or sharing of information (Contacted me after I asked not 

to be, contacted my employer, contacted me instead of my attorney, talked 

to a third party about my debt)

6%

Total debt collection complaints 100%

As the table illustrates, the most common type of debt collection complaint is about continued 

attempts to collect a debt that is not owed. In many of these cases, the attempt to collect the debt 

is not itself the problem; rather, servicemembers assert that the calculation of the underlying 

debt is inaccurate or unfair. Complaints about communication tactics, particularly telephone 

collections, are another common type of consumer complaint. Servicemembers complain about 

telephone collections that are too frequent and that come at inconvenient times of the day. They 

also complain about debt collectors calling their place of employment or third parties. This is of 

particular interest to the CFPB since we have received reports that some debt collectors are 

threatening servicemembers by claiming that they will report unpaid debts to their commanding 

officer, have the servicemember demoted in rank, or even have their security clearance revoked 

if they don’t pay up. Read our blog post8 on this topic to learn more.

Many servicemembers who have submitted debt collection complaints report troubles with the 

collection of unpaid amounts on their military-affiliated credit cards. Specifically, 

servicemembers have reported garnishment of their wages and tax refunds years after the 

original debt was incurred. Many also note that the total garnishment is significantly more than 

the original unpaid balance. Often, these military consumers have trouble understanding the 

total amount they owe and when the garnishment will end. 

Mortgage complaints

Table 2 shows the types of mortgage complaints for the approximately 7,100 mortgage

complaints the CFPB has received from servicemembers.

 

8 http://www.consumerfinance.gov/blog/are-unpaid-debts-a-military-career-killer/
10 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

TABLE 2: TYPES OF MORTGAGE COMPLAINTS REPORTED BY SERVICEMEMBERS

The most common type of mortgage complaint involves problems servicemembers face when 

they are unable to make payments, such as issues relating to loan modifications, collections, or 

foreclosures. Servicemembers with successfully completed loan modifications have complained 

that some servicers do not amend derogatory credit reporting accrued by servicemembers

during trial periods – even when documents provided to the consumers by servicers indicated 

that they would do so. Some servicemembers seeking short sales have reported that second-lien 

holders refuse to accept or subordinate in a short sale, whereas some servicemembers who do 

obtain a short sale have concerns with the loan account being incorrectly reported as a 

foreclosure.

Specifically, servicemembers experience troubles with loss mitigation when receiving PCS 

orders. We highlighted this issue in 20129 yet still receive reports of troubles with some 

frequency. There are, however, new rules10 that address some of the worst problems in the 

mortgage servicing industry and bring new rights and protections to borrowers, including 

servicemembers.

 

9 http://files.consumerfinance.gov/f/201206_cfpb_PCS_Orders_Guidance.pdf

10 http://www.consumerfinance.gov/blog/servicemembers-you-have-new-mortgage-protections-in-2014/

Types of Mortgage Complaints %

Problems when you are unable to pay (Loan modification, collection, foreclosure) 53%

Making payments (Loan servicing, payments, escrow accounts) 28%

Applying for the loan (Application, originator, mortgage broker) 11%

Signing the agreement (Settlement process and costs) 5%

Receiving a credit offer (Credit decision/Underwriting) 3%

Total mortgage complaints 100%
11 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

Credit reporting complaints 

Table 3 shows the types of credit reporting complaints for the approximately 2,700 credit

reporting complaints the CFPB has received from servicemembers. 

TABLE 3: TYPES OF CREDIT REPORTING COMPLAINTS REPORTED BY SERVICEMEMBERS

Types of Credit Reporting Complaints %

Incorrect information on credit report (Information is not mine, Account terms, Account 

status, Personal information, Public record, Reinserted previously deleted information) 72%

Credit reporting company’s investigation (Investigation took too long, Did not get proper 

notice of investigation status or results, Did not receive adequate help over the phone, 

Problem with statement of dispute)

11%

Unable to get my credit report or credit score (Problem getting free annual report, Problem 

getting report or credit score) 7%

Credit monitoring or identity protection services (Problem cancelling or closing account, 

Billing dispute, Receiving unwanted marketing or advertising, Account or product terms and 

changes, Problem with fraud alerts)

5%

Improper use of my credit report (Report improperly shared by credit reporting company, 

Received marketing offers after opting out, Report provided to employer without written 

authorization)

5%

Total credit reporting complaints 100%

This table illustrates that the most common type of credit reporting complaint is about incorrect 

information appearing on the consumer’s credit report, such as information that does not 

belong to the consumer, incorrect account status, and incorrect personal information.

Many servicemembers who submit credit reporting complaints highlight the ongoing fear that 

any negative information on their credit report may cause their security clearance to be pulled 

when it’s up for review. Military consumers have an added fear that any missed payments or 
12 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

inaccurate reporting could potentially affect their military career. Read more11 on this topic on 

the CFPB blog.

Credit card complaints

Table 4 shows the most common types of credit card complaints that the CFPB has received.

About 70% of the approximately 2,500 credit card complaints received from servicemembers

fell into these 10 categories.

TABLE 4: MOST COMMON CREDIT CARD COMPLAINTS REPORTED BY SERVICEMEMBERS

Complaint %

Billing disputes 15%

Other 10%

Identity theft/Fraud/Embezzlement 10%

APR or interest rate 8%

Closing/Cancelling account 7%

Credit reporting 4%

Credit card protection / Debt protection 4%

Late fee 4%

Advertising and marketing 4%

Customer service / Customer relations 4%

Credit card complaints in top 10 types 70%

 

11 http://www.consumerfinance.gov/blog/are-unpaid-debts-a-military-career-killer/
13 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

As the table illustrates, billing disputes are the most common type of credit card complaint.

Servicemembers and their families have reported frustration with fee assessments during 

deployments or mandatory moves. For more information about this issue, refer to section 2 of 

this report, entitled “Spotlight on a financial concern associated with military life: The difficulty

of managing accounts.”

Bank account and service complaints

Table 5 shows types of bank account and service complaints, such as complaints about checking 

and savings accounts, for the approximately 2,400 bank account and service complaints 

received by the CFPB from servicemembers. 

TABLE 5: TYPES OF BANK ACCOUNT AND SERVICE COMPLAINTS REPORTED BY SERVICEMEMBERS

Types of Bank Account and Service Complaints %

Account opening, closing, or management (Confusing marketing, denial, disclosure, 

fees, closure, interest, statements, joint accounts) 46%

Deposits and withdrawals (Availability of deposits, withdrawal problems and 

penalties, unauthorized transactions, check cashing, payroll deposit problems, lost 

or missing funds, transaction holds)

28%

Making or receiving payments, sending money to others (Problems with payments 

by check, card, phone or online, unauthorized or fraudulent transactions, 

money/wire transfers)

10%

Problems caused by my funds being low (Overdraft fees, late fees, bounced checks, 

credit reporting) 10%

Using a debit or ATM card (Disputed transaction, unauthorized card use, ATM or 

debit card fees, ATM problems) 5%

Total bank account and service complaints 100%

As the table illustrates, the most common type of bank account and service complaint relates to 

opening, closing, or managing the account. These complaints address issues such as account 

maintenance fees, legal processing fees for judgments and levies, changes in account terms, 

confusing marketing, early withdrawal penalties for certificates of deposit, and involuntary 

account closures. Other common complaints relate to deposit and withdrawal issues, such as 
14 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

transaction holds, the company's right to offset deposit accounts, and unauthorized debit card 

charges. In this area, many consumers are frustrated by companies’ handling of error disputes 

and requests to stop payment on preauthorized electronic debits. 

Along the topic of deposit and withdrawal issues, military families have detailed many 

difficulties accessing their servicemember’s accounts even when they had a valid Power of 

Attorney (POA). They encountered obstacles communicating with their banks, and were unable 

to decipher what was necessary to lawfully gain access to accounts that were being assessed fees 

or penalties while their servicemember was deployed. For more information, refer to section 2 

of this report.

Consumer loan complaints

Table 6 shows the types of consumer loan complaints, such as complaints about installment 

loans, vehicle loans and leases, personal lines of credit, and pawn and title loans for the 

approximately 1,400 consumer loan complaints received by the CFPB from servicemembers.

12

TABLE 6: TYPES OF CONSUMER LOAN COMPLAINTS REPORTED BY SERVICEMEMBERS

Types of Consumer Loan Complaints %

Managing the loan, lease, or line of credit (Billing, late fees, damage or loss, insurance 

(GAP, credit, etc.), credit reporting, privacy) 43%

Taking out the loan or lease / Account terms and changes (Term changes (mid-deal 

changes, changes after closing, rates, fees, etc.), required add-on products, trade-in 

payoff, fraud)

23%

Problems when you are unable to pay (Debt collection, repossession, set-off from bank 

account, deficiency, bankruptcy, default) 21%

Shopping for a loan, lease, or line of credit (Sales tactics or pressure, credit denial, 

confusing advertising or marketing) 11%

 

12 The Bureau began handling complaints about pawn and title loans as part of the consumer loan complaint category 

on July 2014.
15 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

Other (Charged fees or interest I did not expect, identity theft/fraud/embezzlement, 

billing disputes, credit reporting, other) 3%

Total consumer loan complaints 100%

The table illustrates that the most common type of 

consumer loan complaint pertains to managing the 

loan, lease, or line of credit. Other common types of 

complaints address problems consumers have when 

taking out the loan or lease, such as term changes, 

and problems when they are unable to pay, including 

issues related to debt collection, bankruptcy, and 

default.

Military consumers have reported concerns with high 

interest rates on their auto loans, often citing rates as 

high as 29.00%. These high interest rates contribute 

to payment defaults when a servicemember gets into 

financial trouble and ultimately the risk of 

repossession and abusive debt collection practices. One such consumer, a soldier on active duty, 

explained to us that not only was his car repossessed, the company went so far as to contact 

multiple superiors in his chain of command about his missed payments. Read a personal story 

about protecting servicemembers from predatory auto loans13.

Student loan complaints

Table 7 shows the types of student loan complaints for the approximately 700 student loan 

complaints received by the CFPB from servicemembers.

14

 

13 http://www.consumerfinance.gov/blog/protecting-servicemembers-from-predatory-auto-loans-harry-and-arisstory/

14 Prior to December 18, 2013, consumers submitting student loan complaints could select from three types of 

complaint categories: Getting a loan, Repaying your loan, and Problems when you are unable to pay. Beginning 

“My car was repossessed in 2012. I had a big 

financial issue which caused me to miss two 

non-consecutive payments. Since then the 

car loan company [redacted] calls me at 

work. I’m in the military and for some odd 

reason they find phone numbers and emails 

of my Chain of command. They email and 

call anybody that is in the command...I want 

the calls and emails to stop to my work place. 

The car was sold two weeks after it was 

repossessed and I was never given the 

opportunity to recover the vehicle.”

- Army E5-E7, Texas
16 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

TABLE 7: TYPES OF STUDENT LOAN COMPLAINTS REPORTED BY SERVICEMEMBERS

Types of Student Loan Complaints %

Dealing with my lender or servicer (Making payments, getting information about my 

loan, managing my account) 49%

Can’t repay my loan (Deferment, forbearance, default, bankruptcy, payment plan, 

refinancing) 47%

Getting a loan (Confusing terms, rates, denial, confusing advertising or 

marketing, sales tactics or pressure, financial aid services, recruiting) 4%

Total student loan complaints 100%

 

on December 18, 2013, the student loan complaint form was updated to make it easier for consumers submitting a 

complaint to categorize the problems they are having with their student loan. Consumers now select from the 

following three types of complaint categories: Getting a loan, Can’t pay my loan, and Dealing with my lender or 

servicer. This report includes the types of complaints submitted under both the original and updated forms. The 

Repaying your loan category is under Dealing with my lender or servicer, and Problems when you are unable to 

pay is under Can't repay my loan.
17 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

The most common type of student loan complaint

from servicemembers relates to dealing with a 

lender or servicer and includes issues such as 

making payments, getting information about a loan, 

and how the account is managed. Servicemembers

raised concerns about a range of servicing 

problems, including payment processing problems, 

challenges obtaining necessary documentation 

about their private student loans, difficulty 

obtaining accurate information about their loan 

status and repayment options, and obstacles to 

accessing basic account information. Another 

common type of complaint addresses problems 

consumers confront when they are unable to pay, 

such as issues related to default, student debt 

collection, and bankruptcy. Some servicemembers

report that they continue to struggle with the 

limited affordable payment options permitted in 

their loan agreements. Specifically, some servicemembers say they are unable to refinance or 

restructure the repayment terms of their loan, either to lower monthly payments during periods 

of financial hardship, or to improve existing terms based upon the consumer’s improved credit 

profile and creditworthiness.

Servicemembers continue to report frustration in obtaining the rights afforded to them under 

the Servicemembers Civil Relief Act. We heard from one servicemember who had struggled to 

retain his SCRA rights from his servicer. He was getting ready to deploy and was very concerned 

that his servicer continued to deny his interest-rate benefits. As with the other financial 

products detailed in this report, the servicemember expressed fear of distraction while deployed 

if the issues were not resolved prior to departure.

Payday loan complaints 

Table 8 shows the types of payday loan complaints for the approximately 600 payday loan

complaints the CFPB has received from servicemembers.

“I am Active Duty military.... As of two 

months ago the interest rate on two of my 

loans (was) increased to 7.25%. I have 

contacted the company trying to get them to 

apply the mandate of the Servicemember 

Civil Relief Act. My last communication with 

them was three days ago during which I was 

told I'd be receiving a document via email. As 

of this complaint I have yet to receive it. I 

fear this delay tactic will continue past the 

time I have stateside and then I'll no longer 

be around to fight it. I am on orders to deploy 

to Afghanistan this month. I need help. I 

can't continue to fight this when my attention 

should be on matters that will literally 

involve life or death decisions.”

- Army O1-O3, New York
18 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

TABLE 8: TYPES OF PAYDAY LOAN COMPLAINTS REPORTED BY SERVICEMEMBERS, BY TYPE OF LOAN

Type of Payday Complaint In person / 

at a store

Online Not 

Stated Total

Charged fees or interest I did not expect 33% 39% 21% 34%

Cannot contact lender 22% 16% 21% 18%

Applied for a loan, but didn't receive money 12% 16% 20% 16%

Received a loan I did not apply for 3% 11% 24% 12%

Payment to account not credited 12% 9% 7% 10%

Can’t stop lender from charging my bank 

account

13% 6% 4% 7%

Lender charged my bank account on wrong day 

or for wrong amount 5% 3% 3% 3%

Total 100% 100% 100% 100%

Of the 600 payday loan complaints submitted by servicemembers, approximately 420 (68%) 

were about problems they experienced after obtaining a payday loan online. Approximately 80

(12%) reported problems when obtaining a payday loan in person / at a store. For the remaining 

approximately 120 (20%) complaints, the consumer did not indicate how the loan was obtained. 

The cost and structure of a particular loan can make it difficult for servicemembers to repay. 

Some servicemembers voiced concerns about being unable to repay a loan and not having 

enough money left over for other expenses, the high cost of the loan, and aggressive debt 

collection practices in the event of delinquency or default.

Many servicemembers also submit debt collection complaints to the Bureau that are related to 

payday loans. In addition to servicemembers’ payday complaints the CFPB has also handled 

approximately 1000 debt collection complaints related to a payday loan or loans. These paydayrelated debt collection complaints account for nearly 9% of all debt collection complaints 

handled by the CFPB.
19 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

Money transfer, prepaid card, and other financial services complaints 

Table 9 shows the types of money transfer, prepaid card, and other financial services complaints 

for the approximately 80 other financial services complaints the CFPB has received from 

servicemembers.

15

TABLE 9: TYPES OF MONEY TRANSFER, PREPAID CARD, AND OTHER FINANCIAL SERVICES 

COMPLAINTS REPORTED BY SERVICEMEMBERS

Of the 80 other financial services complaints submitted by servicemembers, approximately 45% 

dealt with misleading advertising or scams. Approximately 21% of complaints covered 

insufficient customer service, while approximately 12% of complaints dealt with excessive or 

 

15 CFPB began accepting complaints about check cashing, credit repair, debt settlement, foreign currency exchange, 

money orders, refund anticipation checks, travelers’ and cashiers’ checks and prepaid cards on July 19, 2014.

Types of Other Financial Services Complaints %

Fraud or scam 45%

Customer service or customer relations 21%

Disclosures 10%

Excessive fees 8%

Advertising and marketing 6%

Unexpected or other fees 4%

Lost or stolen check 4%

Other 3%

Total other financial services complaints 100%
20 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

unexpected fees while using other financial services. The remaining complaints for other 

financial services involved other issues such as dealing with misleading advertising or 

marketing, improper disclosures, and lost or stolen checks. 

How companies respond to servicemembers’ complaints

Approximately 18,900 (or 64%) of all servicemember complaints received between July 21, 2011

and December 31, 2014 were sent by Consumer Response to companies for review and 

response.16 Table 10 shows how companies responded to these complaints during this time 

period. 

Company responses include descriptions of steps taken or that will be taken, communications 

received from the consumer, any follow-up actions or planned follow-up actions, and a 

categorization of the response. Response category options include “Closed with monetary relief,” 

“Closed with non-monetary relief,” “Closed with explanation,” “Closed,” “In progress,” and other 

administrative options. “Monetary relief” is defined as objective, measurable, and verifiable 

monetary relief to the consumer as a direct result of the steps taken or that will be taken in 

response to the complaint. “Closed with non-monetary relief” indicates that the steps taken by 

the company in response to the complaint did not result in monetary relief to the consumer that 

is objective, measurable, and verifiable, but may have addressed some or all of the consumer’s 

complaint involving non-monetary requests. “Non-monetary relief” is defined as objective and 

verifiable relief other than monetary relief to the consumer as a direct result of the steps taken 

or that will be taken in response to the complaint. “Closed with explanation” indicates that the 

steps taken by the company in response to the complaint included an explanation that was 

tailored to the individual consumer’s complaint. For example, this category would be used if the 

explanation substantively meets the consumer’s desired resolution or explains why no further 

action will be taken. “Closed” indicates that the company closed the complaint without relief –

monetary or non-monetary – or explanation. Consumers are given the option to review and 

dispute all company closure responses. 

 

16 The remaining complaints have been referred to other regulatory agencies (27%), found to be incomplete (7%), or 

were pending with the consumer or the CFPB (0.5% and 1%, respectively) as of December 31, 2014.
21 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

Companies have responded to approximately 95% of servicemembers’ complaints17 sent to them 

and report having closed 92% of servicemembers’ complaints. Table 10 shows how companies 

have responded to servicemembers complaints and Table 11 shows untimely company responses 

as a percentage of complaints sent to companies for response as of December 31, 2014.

TABLE 10: HOW COMPANIES HAVE RESPONDED TO SERVICEMEMBER COMPLAINTS18

Closed 

with 

monetary 

relief

Closed 

with nonmonetary 

relief

Closed 

with 

explanation

Closed 

(without 

relief or 

explanation)

Administrative 

response

Company 

reviewing

Company 

did not 

provide a 

timely 

response

Debt 

collection 2% 17% 66% 4% 1% 2% 8%

Mortgage 3% 7% 80% 2% 4% 2% 3%

Credit 

reporting 1% 32% 64% 0% 1% 2% 1%

Bank 

account 

or service

19% 6% 66% 3% 3% 1% 1%

Credit 

card 32% 8% 53% 1% 2% 1% 3%

Consumer 

loan 7% 9% 74% 2% 2% 3% 4%

Student 

loans 8% 12% 68% 0% 2% 3% 6%

Money 

transfers 4% 0% 94% 0% 1% 1% 0%

Payday 

loan 26% 0% 63% 0% 0% 3% 9%

 

17 Companies have responded to approximately 17,900 of the 18,900 servicemembers’ complaints sent to them for 

response. 

18 While companies’ responses under previous categorizations were maintained for operational and reporting

purposes, responses categorized as “full resolution provided,” “partial resolution provided,” and “closed with relief”

are considered a subset of “closed with monetary relief,” and responses categorized as “no resolution provided” and

“closed without relief” are categorized as “closed with explanation.” “Closed with non-monetary relief” and 

“closed”reflect only those responses provided by companies after June 1, 2012.” 91% of complaints from 

servicemembers were received after this recategorization.
22 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

Other 

financial 

services

14% 14% 50% 0% 5% 9% 9%

Prepaid 26% 0% 63% 0% 0% 3% 9%

All 7% 12% 70% 2% 3% 2% 4%

TABLE 11: UNTIMELY COMPANY RESPONSES AS A PERCENTAGE OF COMPLAINTS SENT TO COMPANY

Closed 

with 

monetary 

relief

Closed 

with nonmonetary 

relief

Closed 

with 

explanation

Closed 

(without 

relief or 

explanation)

Administrative 

response

Company 

reviewing

No 

response 

Debt 

collection 1% 10% 71% 6% 3% 0% 10%

Mortgage 3% 6% 70% 1% 8% 0% 11%

Credit 

reporting 0% 5% 84% 0% 0% 0% 11%

Bank 

account 

or service

15% 0% 69% 0% 15% 0% 0%

Credit 

card 15% 11% 59% 1% 2% 2% 10%

Consumer 

loan 8% 6% 69% 3% 6% 0% 8%

Student 

loans 0% 3% 83% 10% 3% 0% 0%

Payday 

loan 7% 0% 61% 0% 11% 0% 21%

Other 

financial 

services

0% 0% 67% 0% 0% 0% 33%

Prepaid 25% 0% 50% 0% 0% 0% 25%

All 3% 8% 70% 4% 5% <1% 10%
23 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

After Consumer Response forwards a complaint to a company, the company has 15 days to 

respond and 60 days to provide a final response, where applicable. Company responses 

provided outside of these windows are deemed untimely. As shown in Table 11, these 

servicemembers eventually received responses in 90% of cases where companies did not 

respond to the complaint in a timely manner. Where companies eventually responded to the 

consumer, most often they provided a response of “Closed with explanation”. However, 

approximately 10% of the total servicemember complaints with untimely company responses 

never received a response. 

Companies have the option to report an amount of monetary relief, where applicable. As of 

December 31, 2014, companies provided relief amounts in response to more than 1,400

complaints. For companies which have reported monetary relief, the median amount of relief 

reported was $200; however, the amount varies by product. For the approximately 440 credit 

card complaints where companies provided a relief amount, the median amount of relief 

reported was approximately $143. For the more than 330 bank account and service complaints 

where companies provided a relief amount, the median amount of relief reported was 

approximately $132. For the approximately 180 mortgage complaints where companies 

provided a relief amount, the median amount of relief reported was approximately $470. For the 

approximately 100 debt collection complaints where companies provided a relief amount, the 

median amount of relief reported was approximately $401. For the approximately 60 consumer 

loan complaints where companies provided a relief amount, the median amount of relief 

reported was approximately $200. Companies rarely report providing monetary relief in 

response to consumers’ debt collection and credit reporting complaints.

Companies also have the option to provide non-monetary relief in response to complaints. 

Servicemembers have received a range of non-monetary relief in response to their complaints, 

such as: 

 providing mortgage foreclosure alternatives that did not include direct monetary 

payments to the consumer, but that helped them to keep their home; 

 stopping harassment from debt collectors;

 cleaning up consumers’ credit reports by correcting submissions to credit bureaus or

restoring or removing a credit line;

 correcting account information; and 
24 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

 addressing formerly unmet customer service issues.

Servicemembers’ reviews of companies’ responses

Once the company responds, the CFPB provides the company’s response to the servicemember 

for review. Where the company responds “Closed with monetary relief,” “Closed with nonmonetary relief,” “Closed with explanation,” or “Closed,” consumers are given the option to 

provide feedback on the company’s response. Figure 3 shows how servicemembers responded to 

the approximately 17,300 complaints where they were given the option to provide feedback, as 

of December 31, 2014. 

Servicemembers are asked to notify the CFPB within 30 days if they want to provide feedback by 

disputing a company’s response. Approximately 69% of such consumers did not dispute the 

responses provided, while approximately 22% of servicemembers did dispute the response 

provided. The rest were pending with consumers as of December 31, 2014.
25 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

FIGURE 2: SERVICEMEMBER FEEDBACK ABOUT COMPANY RESPONSES

Consumer response investigation and analysis

After requesting that companies respond to complaints sent to them for response, and giving 

consumers the opportunity to review and provide feedback on company responses, Consumer 

Response prioritizes complaints for investigation based on a review of the complaint, the 

company’s response, and the consumer’s feedback. Consumer Response seeks to determine why 

a company failed to provide a timely response (if applicable) and whether the consumer’s 

69%

71%

65%

73%

65%

64%

77%

70%

80%

42%

59%

69%

19%

25%

20%

21%

23%

25%

16%

14%

15%

23%

12%

22%

11%

5%

15%

6%

12%

11%

7%

16%

5%

35%

29%

9%

Debt collection

Mortgage

Credit reporting

Bank account or service

Credit card

Consumer loan

Student loan

Payday loan

Money transfer

Prepaid

Other financial service

All

Servicemember did not dispute company's response

Servicemember disputed company's response

Pending servicemember review of company's response
26 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

feedback about the company’s response (if applicable) justifies additional review of the 

company’s minimum required actions under the consumer financial protection laws within the 

CFPB’s authority. In the course of an investigation, Consumer Response may ask companies and 

consumers for additional information. In some cases, Consumer Response has referred 

complaints to colleagues in the CFPB’s Division of Supervision, Enforcement, and Fair Lending 

for further consideration. The Office of Servicemembers Affairs works closely with Consumer 

Response, and monitors and analyzes many individual servicemember complaints. 

Listening to consumers and reviewing and analyzing their complaints is an integral part of the 

CFPB’s work in understanding issues in the consumer financial marketplace, and in helping the 

market work better for consumers. The information shared by consumers and companies 

throughout the complaint process informs the Bureau about business practices that may pose 

risks to consumers and helps the Bureau supervise companies, enforce federal consumer 

financial laws, and write better rules and regulations.

1.2 Outreach

In addition to monitoring and analyzing complaints submitted to the Bureau by members of the 

military community, OSA routinely engages in outreach that supports its mission to educate and 

empower servicemembers about financial matters while also coordinating with other agencies 

on military consumer protection measures.

OSA conducted its outreach through a series of activities designed to reach servicemembers at 

the places where they live and work, and to encourage them to use CFPB resources, including 

the complaint system.

INSTALLATION VISITS

During 2014, OSA connected with approximately 7,000 servicemembers, veterans, military 

families, and other stakeholders through a number of live events across the United States and 

abroad. 

Of that number, OSA interacted with more than 4,000 active-duty servicemembers and 

National Guard personnel by conducting leadership roundtables and town hall style “listening 

sessions” at 34 military installations. These sessions were hosted to give servicemembers and 

families a forum to relay their real-world financial challenges and to provide consumer 

information to help them make better-informed financial decisions. The 34 installations visited 
27 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

were representative of all five service branches of the armed forces and included: regional 

commands; senior leadership development schools; wounded warrior care centers; military 

recruit induction stations; overseas installations and Unified Combatant Commands. 

Holly Petraeus, Assistant Director of Servicemember Affairs, spends time with Coast Guard personnel 

during an outreach event at U.S. Coast Guard Base Miami, FL. (Photo by PAC Ryan Doss, 7th Coast Guard 

District)

EDUCATIONAL BRIEFINGS, OUTREACH EVENTS AND COMMUNITY COLLABORATIONS

Along with the installation visits, OSA conducted 20 outreach events across the United States to 

engage various stakeholder groups and deliver consumer resources directly to the military 

community. These stakeholder groups consisted of a diverse field of leaders, educators, 

practitioners and military consumer protection advocates in the armed services, academia, law, 

financial industry groups, federal and state governments, and others. 

The outreach events also varied in scope and included efforts such as conducting military 

consumer legal protection briefings at Judge Advocate General schools for the Army, Air Force 

and Marine Corps; providing training at professional development seminars for financial 
28 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

educators; exhibiting at financial education fairs; and having OSA leadership address influential 

industry groups about financially empowering servicemembers. 

VETERANS OUTREACH EVENTS

OSA expanded its engagement campaign geared towards the nation’s 22 million veterans by 

conducting 14 veteran outreach events that focused on forming resource-building collaborations 

with veteran-support organizations that promote consumer protection.

This bridge-building effort included providing “CFPB 101” and other issue-specific briefings to 

prominent veterans service organizations; engaging with public policy groups to identify 

baseline consumer issues for older veterans; establishing relationships with local veterans’

courts, faith-based service providers, neighborhood partnerships and women’s groups looking 

for resources to address financial risk factors for veterans; working with veterans authorities to 

create distribution pipelines for CFPB educational materials at the state and local levels; and 

engaging military retirees directly at installation retiree appreciation events. 

DIGITAL ENGAGEMENT

OSA continued to deliver financial education, information and resources to consumers using its 

digital distribution and social media channels. In addition to its routine social media 

engagement, we also partnered with other federal agencies and some non-profit organizations to 

host several social-media town halls. These joint social media events provided an opportunity 

for military consumers and stakeholders to have their questions answered by OSA and its 

content partners in real-time. 

The Office expanded its catalogue of online training courses for military financial educators by 

creating two new forums that spotlighted critical information and common misperceptions in 

“Veteran Consumer Issues” and “Credit Reporting and the Military”. The forums are available 

online19.

NATIONAL PARTNERSHIPS AND PROMOTIONS

We collaborated with other federal agencies and select non-governmental organizations to 

support nationwide savings, financial literacy and consumer protection campaigns geared to the 

 

19 http://www.consumerfinance.gov/servicemembers/on-demand-forums-and-tools/
29 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

military community. OSA supported both Military Saves Week in February and Military 

Consumer Protection Day in July by conducting a series of activities that included giving 

financial readiness presentations to servicemembers at various military installations around the 

United States; conducting social media events, setting up and staffing information kiosks at 

events around the country; and creating multimedia promotional content for the campaigns.

1.3 Enforcement actions

The Bureau was a party in dozens of public enforcement actions in 2014. Three of these 

particularly impacted servicemembers and provided them with over $94 million in refunds and 

other relief.

Consumer Financial Protection Bureau, et al., v. Freedom Stores, Inc., et al. (E.D. 

Va. No. 2:14-cv-00643-AWA-TEM) (stipulated final judgment and order entered January 8, 

2015).

The CFPB and the Attorneys General of North Carolina and Virginia took action against 

Freedom Stores, Inc., Freedom Acceptance Corporation, and Military Credit Services LLC. The 

Bureau and the states filed a consent order in federal court to require the three companies and 

their owners and chief officers to provide over $2.5 million in consumer redress and to pay a 

$100,000 civil penalty. The CFPB’s investigation found that the companies and their owners 

engaged in illegal debt-collection practices in violation of the Consumer Financial Protection Act

of 2010. These illegal practices included filing thousands of lawsuits in Virginia against 

consumers who lived and entered their contracts far away from the place of suit, collecting more 

than – and sometimes double – what was owed in a single billing cycle, and disclosing debts to 

third parties, including military commanding officers.

In the Matter of: USA Discounters, Ltd. (File No. 2014-CFPB-0011) (consent order 

entered August 14, 2014).

The CFPB ordered USA Discounters to refund approximately $350,000 to servicemembers for 

unfair and deceptive practices relating to installment loans for furniture, electronics, and other 

home goods. USA Discounters charged active-duty servicemembers a fee for a company called 

SCRA Specialists LLC, purportedly to assist servicemembers in availing themselves of their 

rights under the Servicemembers Civil Relief Act (SCRA). In fact, SCRA Specialists never 

actually performed most of the services offered to servicemembers. The consent order requires 
30 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

USA Discounters to cease engaging in this unlawful conduct, to provide full restitution to all 

consumers who paid the SCRA Specialists fee since 2009, and to pay a $50,000 civil money 

penalty.

In the Matter of: Colfax Capital Corp., et al. (File No. 2014-CFPB-0009) (consent order 

entered July 29, 2014).

The Bureau took action against Colfax Capital and Culver Capital, also collectively known as 

“Rome Finance,” and two of its owners for violating Regulation Z (Truth in Lending) by failing 

to accurately disclose credit information in financing for consumer goods sold online or near 

military bases, and the Consumer Financial Protection Act of 2010 by servicing and collecting on 

financing agreements that state laws rendered void or limited the consumer’s obligation to 

repay. Under the consent order, Rome Finance will cease efforts to collect on any of the 

outstanding finance agreements, and it paid $1 in civil penalties (a larger penalty was not 

assessed because Colfax is bankrupt). Additionally, under the order, Rome and two of its 

principals are permanently banned from consumer lending.
31 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

2. Spotlight on a financial 

concern associated with 

military life: The difficulty of 

managing accounts

Fees associated with the use of financial products are commonplace. Credit cards might charge

yearly membership fees, late fees, or penalty interest fees; bank accounts might charge fees for 

the use of the account, overdraft fees, minimum balance fees, and other types of fees. For many 

American consumers, these fees are disclosed, understood, and can be avoided by using the 

account/card in accordance with the terms and conditions provided by the company. For 

members of the military and their families, however, the story is not always so simple.

Throughout 2014, we received numerous complaints from servicemembers and their families 

telling their stories about fees. These complaints all underscored one central fact: due to an 

aspect of their military service, fees associated with their credit cards or bank accounts were 

difficult to avoid, causing unnecessary stress and additional financial hardship.

For example, one issue cited by servicemembers and their families in complaints was the 

occurrence of a monthly fee charged to their bank account for what these servicemembers 

generally categorized as “misuse.” “Misuse” is a broad term implying that the consumer has not 

kept the necessary minimum daily balance, has not set up a direct deposit required by the terms 

of the account, or simply did not perform any transactions for the monthly period.

Misuse frequently stems from a bank’s changes to the terms and conditions of an account, 

changes that may take place years after the account was originally opened. Due to the nature of 

military life, many servicemembers have trouble receiving notices informing them of these 
32 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

changes - whether due to extended deployments, the operational tempo of a dangerous job, or 

frequent moves to new addresses. Of particular concern, servicemembers reported instances 

where accounts initially opened as Military No-Fee accounts were changed by the financial 

institution to a new product that required a minimum balance or automatic deposit in order to 

avoid new monthly charges. While these new requirements may have been disclosed in updated 

terms and conditions sent to the account holder, the challenges of military life limited the 

servicemember’s ability to effectively receive notice and adjust or close their account accordingly 

to avoid the monthly charge. 

We have also seen a dormancy/inactivity fee charged based on lack of use of the account, which 

can be particularly problematic for military families and their unique situation. One military 

spouse, for example, wrote to us about fees associated with an emergency account she opened 

while her spouse was in a war zone. The account she originally opened was a “free” account, and 

was even advertised as such. But after a year, her bank converted her account from a free one to 

one with fees. With the new account, the consumer was faced with a new $12.00 monthly 

maintenance fee, as well as a $7.50 inactivity fee. She explained that as a military spouse, she 

opened the “free” checking account in order to use it for emergencies and was unaware of these 

new fees, which were triggered if she did not use the account for twelve consecutive months. For 

this military consumer, the terms and conditions of her “free” checking account were changed a 

year after opening; the fees quickly eroded her checking account, and morphed it from a useful 

product to one that no longer provided her with the security she needed during her husband’s 

deployments. 

In the course of OSA’s outreach efforts to the military community overseas, we routinely hear 

from servicemembers and their spouses that because they regularly make internet purchases 

while serving abroad, they will often add an additional checking account to protect against 

potential fraud. Unfortunately for these consumers, what may begin as a smart decision 

designed to protect their finances can become a financial albatross. Because of their 

international assignments, their ability to receive bank notices may be hampered, and often they 

are unaware of new account attributes, including maintenance fees, being applied to their 

accounts if the terms and conditions change. Many consumers report that over time, the 

multiple monthly charges deplete the accounts and some even mentioned additional overdraft 

fees being triggered.
33 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

POOR COMMUNICATION RELATING TO ACCOUNT ACCESS MAY EXACERBATE FEES FOR 

SERVICEMEMBERS

The story extends beyond the issue of fees associated with “misuse.” Many times, once the 

charges are noticed by servicemembers or their family representatives, they still encounter 

obstacles communicating with the company to get the issue resolved. Complaints raise concerns 

that financial institutions have yet to put into place proper procedures and protections for our 

military families, especially when a servicemember is deployed overseas.

For example, we received a complaint from one servicemember who attempted to deal with his 

fee problems while he was deployed overseas. The company’s communication systems made 

handling his problem impossible. While deployed, the servicemember did not have access to a 

telephone. His only methods of communication were through email and other online systems, 

which did not provide him with access to company representatives who had the authority to 

resolve his problems. When the servicemember used the credit card company’s live-chat feature 

in order to speak with a company representative, he reached an employee who admitted that he 

did not have sufficient access to the servicemember’s account information to adequately solve 

his problem. Moreover, the representative was unwilling or unable to elevate the 

servicemember’s complaint to management. 

The servicemember expressed his concerns to us in his complaint: 

“My inquiry remains unresolved and may soon unnecessarily cost me upwards of $500 

in fees. The company's underlying policies that serve to block account holder 

communications with empowered employees poses the likelihood of injuring customers 

throughout the U.S.--especially harming service members deployed overseas.”

Deployment is not a time when members of the military should be concerned about their 

finances, especially when they have proactively attempted to communicate with their financial 

companies. If some financial trouble should arise while they are overseas, companies should 

have procedures in place that allow a servicemember to effectively and efficiently communicate 

with their representatives to resolve the issue and restore their peace of mind. 

We also hear from many military spouses who are asked by their active-duty spouses to help 

with the family’s finances during deployment. Many of these families contact the bank prior to 

departure and give authorization for their spouse’s access to the account. Often, these financial 

institutions have multiple levels of authorization giving access to various account attributes, i.e. 

verbal access over the phone, online account viewing, bill pay features, etc. Many spouses report 
34 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

to us that when problems arise with their servicemember’s account, including fee applications, 

the authorization given does not suffice to help solve the problem. Many institutions will not 

work with the spouse without speaking to the servicemember, who has limited spare time or 

telephone access while deployed to conference-call the company to take care of the problem. 

Even though these couples proactively seek to anticipate and head off potential problems, their 

financial providers are not always able to efficiently adapt to their needs. These companies often 

fail to communicate to their consumers how to properly access their accounts, which led to 

undue stress and valuable time wasted. 

Prior to departure for deployment or training, many servicemembers take legal steps to ensure 

their personal finances will be taken care of while they are away. It is common for 

servicemembers to seek and obtain Powers of Attorney (POA) through their military Legal 

Assistance Office so that family members or other trusted third parties can take care of affairs in 

their absence.20 The Army Legal Assistance Regulation lists the preparation of POAs as one type 

of legal document Legal Assistance attorneys are authorized to prepare, and provides a 

cautionary note about the broad reach of General POAs.21 In spite of the military’s emphasis on 

readiness, and the availability of POAs, these documents sometimes are not enough to cover the 

needs of servicemembers.

Many consumers still report that they experience trouble handling the financial affairs for a 

servicemember spouse or child even when they have a valid General POA. 

“The financial institution is blocking my access to the joint account I own with my 

Army active duty wife, currently deployed to Kuwait...In short, they are blocking 

access to our money and I can't even pay our bills...They claim that, despite already 

having both a General Power of Attorney and a Special Power of Attorney filed on my 

behalf prior to my wife's deployment (Army SOP), these comprehensive documents are 

insufficient and they are demanding a THIRD document "authorizing" my access 

electronically.”

 

20 Military OneSource, “Power of Attorney Basics”

21 Army Regulation 27-3, para 3-7(e).
35 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

A mother, who was appointed to be her son’s agent, wrote to us explaining her troubles 

communicating with his financial institution while he was away at training. The company 

was deducting double payments from her son’s bank account which caused a negative 

balance and additional overdraft charges. She made multiple attempts to contact the 

company about the problem. She reported that the first representative acknowledged the 

authorization she had on file and stated the issue was being reviewed. When she called back 

to check on the status, she was told by a new representative that no authorization existed 

and they could not speak to her regarding the account. 

She expressed her continued frustration even after the company agreed to fix the problem:

“The financial institution eventually refunded the money; however, the damage was 

already done to my son's credit and bank account. The negative impact their actions 

had are still being felt. Although [they] stated he was not financially responsible for 

this account, they continued to contact him regarding payments and he eventually had 

to get a personal loan and pay this account off - just to find some peace. Their actions 

and conduct are repugnant and certainly questionable with regard to ethical 

practices.”

In the complaints we’ve monitored, servicemembers have reported creating POAs to legally 

authorize their spouse or parent to control their finances. Companies may require a more 

targeted POA for added consumer protection; however, based on the complaint submissions, 

it appears this information is not being relayed to the military families at the appropriate 

time. And in some cases, it appears that even more specific POAs are not accepted. If a 

company knows they are dealing with a military consumer who is likely to need to provide 

for third-party access to an account, companies should clearly communicate the specific 

requirements to allow that access. Complaint submissions indicate that confusion about 

companies’ POA requirements has led to an exacerbation in fees and overall financial stress 

for many servicemembers and their families.

Account security is naturally a high priority for providers of financial products and services, 

but there should be clear measures in place to safely allow account access to third parties 

authorized by the account holder. It would benefit military families if they got simple, clear, 

and concise guidance about specific authorization requirements prior to servicemembers’ 

deployment, overseas service, or departure from their home station, as well as if financial 
36 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

companies took steps to enable clear and effective communication with their military 

customers.

Suggested Practices:

• Prior to altering military-specific account conditions of use, companies should seek to obtain 

an updated mailing address from their military consumers.

 Companies should provide clear instructions on how a person designated by a 

servicemember may gain access to an account, and what things that person can and 

cannot do with the account. If different levels of access exist, this should be clearly 

explained, along with instructions on how the servicemember account holder can 

authorize each level.

 Companies should proactively notify military consumers about any POA company 

policies. This should include whether or not POAs are accepted, and, if so, which type is 

required based on the consumer’s needs. If a company requires a specific format or 

language for a POA, that should be provided on its website. Legal Assistance offices 

within the military routinely prepare both General and Specific POAs, and can generally 

include whatever specific language a client needs within the Specific POAs. Companies 

should provide clear guidance to their military consumers about the language or format 

they require so that the servicemember can be sure to create a sufficient POA. 

 Companies should ensure they have feasible methods of communication for all their 

consumers. For military consumers, limiting communication to telephone or fax to 

resolve issues greatly impacts the ability of deployed servicemembers to conduct bank 

business, especially if that communication is only available during US business hours.
37 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

APPENDIX A:

More about the CFPB

GENERAL INFORMATION:

Email address: info@consumerfinance.gov

Phone number: (202) 435-7000

WEBSITE:

www.consumerfinance.gov

MAILING ADDRESS: 

Consumer Financial Protection Bureau

ATTN: Employee name, Division, and/or Office Number

1700 G Street, NW

Washington, DC 20552

CONSUMER COMPLAINTS AND QUESTIONS:

Webpage: consumerfinance.gov/complaint

Toll free number: (855) 411-CFPB (2372) 

TTY/TDD: (855) 729-CFPB (2372) 

Fax number: (855) 237-2392

Hours of operation: 8 a.m. - 8 p.m. EST, Monday-Friday, services in 180+ languages

Consumer Financial Protection Bureau

PO Box 4503

Iowa City, Iowa 52244

WHISTLEBLOWERS:

Email: whistleblower@consumerfinance.gov

Toll free number: (855) 695-7974
38 COMPLAINTS RECEIVED FROM SERVICEMEMBERS, VETERANS, AND THEIR FAMILIES, SPRING 2015

PRESS & MEDIA REQUESTS:

Email: press@consumerfinance.gov

OFFICE OF LEGISLATIVE AFFAIRS:

Legislative Affairs: (202) 435-7960

CFPB OMBUDSMAN’S OFFICE:

Email: CFPBOmbudsman@cfpb.gov

Webpage: consumerfinance.gov/ombudsman

Toll free number: (855) 830-7880

TTY number: (202) 435-9835 Fax number: (202) 435-7888