BUREAU OF CONSUMER FINANCIAL PROTECTION | MARCH 2019

Consumer Response 

Annual Report

January 1 – December 31, 2018
1 BUREAU OF CONSUMER FINANCIAL PROTECTION

Message from

the Director

I am pleased to present the Bureau of Consumer Financial 

Protection’s (CFPB or Bureau) Consumer Response 2018 

Annual Report, as required by Section 1013(b)(3)(C) of the 

Dodd-Frank Wall Street Reform and Consumer Protection Act 

(Dodd-Frank Act).

Since I was confirmed as the Bureau’s new Director in 

December 2018, I have emphasized that the Bureau must hold stability, consistency, and 

transparency as hallmarks as we mature the agency. This report is one way we are delivering on 

the promise of transparency. 

From January 1 through December 31, 2018, the Bureau received approximately 329,800 

complaints. Financial markets are complex, rapidly changing environments, which are best 

viewed over time. This Annual Report not only details the trends Consumer Response has seen 

through the lens of consumer complaints during the past year, but also compares them to 

trends observed in the prior year. Additionally, this report provides information about the 

Bureau’s complaint handling process to provide context for the complaint analyses. 

In 2018, the Bureau issued two Requests for Information (RFIs) that were specific to the work 

detailed in this report. These RFIs, about complaint reporting practices and complaint and 

inquiry handling processes, received over 25,000 public comments. The Bureau continues to 

consider this and other input received from the public. The insights we gain from our review will 

inform how our complaint program will evolve and how we will serve and interact with the 

program’s various stakeholders, including consumers, companies, and other regulators. 

For America’s financial system to run successfully, consumers should be treated fairly, financial 

institutions that serve them should have a level playing field on which to compete, and the 

marketplace should innovate in ways that give consumers more choices and meet their needs.

In keeping with our statutory obligations and commitment to transparency, we are issuing this 
2 BUREAU OF CONSUMER FINANCIAL PROTECTION

report to inform the public about our operations and the insights we have gleaned from 

complaints to help maintain a financial system that works for all. 

Sincerely, 

Kathleen L. Kraninger
3 BUREAU OF CONSUMER FINANCIAL PROTECTION

Table of Contents

Message from the Director.........................................................................................1

Table of Contents........................................................................................................3

1. Introduction...........................................................................................................4

2. Complaint Numbers..............................................................................................7

3. Complaint Resolution.........................................................................................14

4. Complaint Types.................................................................................................16

4.1 Credit or consumer reporting..................................................................17

4.2 Debt collection........................................................................................24

4.3 Mortgages ...............................................................................................30

4.4 Credit cards.............................................................................................36

4.5 Checking or savings ................................................................................40

4.6 Student loans ..........................................................................................45

4.7 Money transfers, money services, and virtual currencies .....................49

4.8 Vehicle loans or lease ............................................................................. 52

4.9 Personal loans......................................................................................... 56

4.10 Prepaid cards .......................................................................................... 59

4.11 Payday loans ...........................................................................................62

4.12 Credit repair............................................................................................65

4.13 Title loans ...............................................................................................66

5. Conclusion ..........................................................................................................70

Appendix....................................................................................................................71
4 BUREAU OF CONSUMER FINANCIAL PROTECTION

1. Introduction

One of the primary functions of the Bureau of Consumer Financial Protection (CFPB or Bureau) 

is collecting, investigating, and responding to consumer complaints.1 Created by the Bureau,

under the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Office of 

Consumer Response (Consumer Response)2 handles consumer complaints, and analyzes and 

shares complaint data to level the playing field and empower consumers to take more control 

over their financial lives.3

In 2018, the Bureau received approximately 329,800 consumer complaints.4 The Bureau 

receives consumer complaints through its website, by referral from the White House, 

congressional offices, and other federal and state agencies, and by telephone,5 mail, email, and 

fax.6 Consumers submitted approximately 86% of complaints by visiting the CFPB’s website or 

by calling the CFPB’s toll-free telephone number.

When consumers submit complaints online or over the phone, the Bureau asks them to identify

the consumer financial product or service with which they have a problem, as well as the type of 

problem they are having with that product or service. This provides information that the Bureau 

can use to analyze complaints. The Bureau’s complaint form also requires consumers to affirm 

that the information provided in their complaint is true to the best of their knowledge and belief.

 1 See Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, Pub. L. No. 111-203 (Dodd-Frank Act), 

Section 1021(c)(2). See also § 1002(4) (“The term ‘consumer’ means an individual or an agent, trustee, or 

representative acting on behalf of an individual.”).

2 Id. § 1013(b)(3)(A).

3 Consumer complaints are submissions that express dissatisfaction with, or communicate suspicion of wrongful 

conduct by, an identifiable entity related to a consumer’s personal experience with a financial product or service.

4 This report covers complaints submitted in calendar year 2018 about a variety of consumer financial products and 

services: credit or consumer reporting; debt collection; mortgages; credit cards; checking or savings; student loans; 

money transfers, money services, and virtual currencies; vehicle loans or leases; personal loans; payday loans; 

prepaid cards; credit repair; and, title loans.

5 In addition to taking consumers’ complaints and providing complaint status updates over the telephone via a tollfree number, the Bureau also provides consumers with timely and understandable information about consumer 

financial products and services over the telephone. Representatives at the Bureau’s U.S.-based contact center answer 

consumers’ inquiries, providing clear, unbiased answers and pointing them to CFPB-created tools like Ask CFPB and 

“Buying a House.” The Bureau provides services to consumers in more than 180 languages and to consumers who are 

deaf, have hearing loss, or have speech disabilities. In 2018, the Bureau received an average of more than 21,200 

telephone calls per month.

6 See Dodd-Frank Act § 1013(b)(3).
5 BUREAU OF CONSUMER FINANCIAL PROTECTION

The Bureau encourages consumers to submit complaints through its website whenever possible. 

The online complaint form helps to ensure completeness of information and enables Consumer 

Response to send the complaint to the named company quickly—on average, in one day or less. 

The online complaint form allows consumers to attach supporting documentation to their 

complaint, which often helps companies assess issues raised by consumers. Consumers can also 

check on the status of their complaint and access relevant educational resources in the webbased Consumer Portal.

The Bureau routes consumers’ complaints about financial products and services—and any 

documents they provide—directly to financial companies, and works to get consumers a timely 

response, generally within 15 days. Secure, web-based Company and Consumer Portals protect 

consumer and company privacy. Where appropriate, the Bureau securely routes complaints to 

other federal agencies.7

After a consumer receives the company’s response to their complaint, the consumer can provide 

feedback by completing an optional survey. Consumers have 60 days from the date the company 

responded to complete the survey.

Consumer Response analyzes consumer complaints, company responses, and consumer 

feedback to assess the accuracy, completeness, and timeliness of company responses so that the 

Bureau, other regulators, consumers, and the marketplace have relevant information about 

consumers’ challenges with financial products and services. Consumer Response uses a variety 

of approaches to analyze consumer complaints, including cohort and text analytics to identify 

trends and possible consumer harm. These analyses support the Bureau’s work to supervise 

companies, enforce federal consumer financial laws, propose rules, and develop tools that help

empower consumers to make informed financial decisions. 

The Bureau also shares consumer complaint information with prudential regulators, the Federal 

Trade Commission, other federal agencies, and state agencies.8 In keeping with the Bureau’s 

statutory responsibilities and its commitment to accountability, this report provides information 

and analysis about complaints received by the Bureau from January 1 through December 31, 

 7 Dodd-Frank Act § 1013(b)(3)(A) (“The Director shall coordinate with the Federal Trade Commission or other 

Federal agencies to route complaints to such agencies, where appropriate.”).

8 Id. § 1013(b)(3)(D).
6 BUREAU OF CONSUMER FINANCIAL PROTECTION

2018, including information and analysis about complaint numbers, complaint types, and, 

where applicable, information about the resolution of complaints.9

 9 This report fulfills the reporting requirements of Dodd-Frank Act Section 1013(b)(3)(C), which instructs the Bureau 

to report on the complaints received by the Bureau in the prior year. “Complaints received” include those sent to 

companies for a response and those routed to other federal agencies as required by Section 1013(b)(3)(A). This report 

also fulfills the reporting requirements of Fair Credit Reporting Act Section 611(e), 15 U.S.C. § 1681i(e).
7 BUREAU OF CONSUMER FINANCIAL PROTECTION

2. Complaint Numbers

The Bureau received approximately 329,800 consumer complaints in 2018.10 The Bureau sent 

approximately 264,100 (or 80%) of these complaints to companies for review and response, 

referred 14% of complaints received to other regulatory agencies, and found 4% to be 

incomplete. At the end of 2018, 0.4% of complaints were pending with the consumer and 1% 

were pending with Bureau (see Figure 1A, Routing Outcomes).

FIGURE 1: COMPLAINT OUTCOMES IN 2018

A. Routing Outcomes B. Company Responses

More than 2,700 companies responded to complaints sent to them for review and response by 

the Bureau in 2018. Companies confirmed a commercial relationship with the named consumer 

and provided a substantive response to the consumer and the CFPB (i.e., closed with 

explanation, closed with non-monetary relief, closed with monetary relief) in approximately 

239,600 complaints (see Figure 1B, Company Responses). Companies provided an 

administrative response in approximately 6,800 complaints. At the end of 2018, approximately 

 10 This report excludes some complaints that the Bureau received, including multiple complaints submitted by a given 

consumer on the same issue (i.e., duplicates), whistleblower tips, and complaints the Bureau found were submitted 

without the consumer’s authorization. Complaint data in this report is current as of January 2, 2019. Complaint 

numbers are rounded throughout the report; therefore, numbers and percentages may not sum to sub-totals or 100%.
8 BUREAU OF CONSUMER FINANCIAL PROTECTION

13,200 complaints were being reviewed by companies, and approximately 4,500 complaints did 

not receive a timely response. Section 3, Complaint Resolution, provides more details about 

types of company responses.

Consumer Response analyzes complaint data through various lenses to understand the 

situations consumers encounter collectively in the financial marketplace, including:

 The products and services consumers submit complaints about

 Consumers’ reported attempts to resolve the issue with the company before submitting a 

complaint to the Bureau

 Consumers’ geographic region

 How different groups of consumers, such as older consumers and servicemembers,

report issues with financial products and services compared to consumers overall11

 11 Older consumers and servicemembers are both self-identified. Servicemembers refers to servicemembers, veterans, 

and military families. Older consumers refers to consumers who voluntarily reported their age as 62 or older. 
9 BUREAU OF CONSUMER FINANCIAL PROTECTION

Products and Services

As shown in Figure 2, credit or consumer reporting, debt collection, mortgage, credit card, and 

checking or savings were the most complained about consumer financial product and service 

categories in 2018. Collectively, these products comprised approximately 89% of all complaints 

the Bureau received.

FIGURE 2: COMPLAINT VOLUME BY FINANCIAL PRODUCT OR SERVICE12

 12 This figure excludes approximately 100 complaints where the consumer did not select a specific consumer financial 

product or service.

Credit or consumer reporting

Debt collection

Mortgage

Credit card

Checking or savings

Student loan

Money transfer or service, virtual currency

Vehicle loan or lease

Personal loan

Prepaid card

Payday loan

Credit repair

Title loan

126,300 (38%)

81,500 (25%)

2,600 (0.8%)

2,300 (0.7%)

1,000 (0.3%)

30,100 (9%)

28,700 (9%)

25,900 (8%)

10,400 (3%)

8,100 (2%)

8,100 (2%)

4,200 (1%)

600 (0.2%)

-19%

-48%

-19%

-20%

27%

31%

12%

33%

14%

-3%

-5%

8%

5%

2018 2017 vs. 2018
10 BUREAU OF CONSUMER FINANCIAL PROTECTION

Prior Company Contact

In April 2017, the Bureau’s complaint form began requiring consumers to indicate whether they 

tried to resolve the problem with the company before submitting a complaint to the Bureau. As 

shown in Figure 3, the majority of consumers indicated having tried already to resolve the issue 

with the named company. While the Bureau shares this information with the company to aid in 

the review of the complaint, the Bureau does not verify the information or require companies to 

confirm or deny whether the consumer attempted to resolve the problem.

FIGURE 3: PERCENTAGE OF CONSUMERS WHO REPORTED ATTEMPTING TO CONTACT COMPANY 

BEFORE SUBMITTING COMPLAINT

Attempted to resolve issue with company

Yes No

Prepaid card

Checking or savings

Mortgage

Credit card

Vehicle loan or lease

Money transfer or service, virtual currency

Student loan

Title loan

Personal loan

Credit or consumer reporting

Debt collection

Payday loan

Credit repair

94%

6%

94%

6%

93%

7%

92%

8%

92%

8%

91%

9%

90%

10%

88%

12%

87%

13%

85%

15%

82%

18%

81%

19%

78%

22%
11 BUREAU OF CONSUMER FINANCIAL PROTECTION

Geographic Region 

Consumers from all 50 states and the District of Columbia submitted complaints to the Bureau.

To understand state and regional trends, Consumer Response analyzes the geographic 

distribution of complaints after accounting for population differences. Figure 4 shows that, on a 

per capita basis, the Bureau received more complaints from consumers in Washington, D.C. 

than anywhere else in the United States, followed by consumers in Georgia, Florida, Nevada, 

and Delaware. Consumers in South Dakota submitted the fewest complaints of any state per 

capita.

FIGURE 4: U.S. COMPLAINT SUBMISSIONS PER 100K POPULATION

WY

46

WV

39

WI

55

WA

70

VT

43

VA

96

UT

72

TX

108

TN

86

SD

36

SC

116

RI

78

PA

86

OR

60

OK

53

OH

81

NY

104

NV

145

NM

56

NJ

123

NH

64

NE

40

ND

40

NC

107

MT

49

MS

81

MO

84

MN

51

MI

72

ME

50

MD

127

MA

73

LA

107

KY

49

KS

52

IN

56

IL

107

ID

48

IA

38

HI

67

GA

180

FL

158

DE

143

DC

228

CT

86

CO

82

CA

105

AZ

96

AR

66

AL

83

AK

51

35 230
12 BUREAU OF CONSUMER FINANCIAL PROTECTION

Servicemembers

Consumer Response and the Bureau’s Office of Servicemember Affairs monitor and analyze 

complaints from servicemembers, veterans, and military families (collectively referred to as 

“servicemembers” in this report). As shown in Figure 5, servicemembers submitted complaints 

about products and services at similar rates as non-servicemembers. Servicemembers’

complaints were slightly more often about debt collection, mortgages, and vehicle loans or

leases than non-servicemembers’, and were less often about credit cards and checking or

savings. Section 4 of this report (Complaint Types) analyzes some of these differences.

FIGURE 5: COMPLAINTS SUBMITTED BY SERVICEMEMBERS AND NON-SERVICEMEMBERS

Servicemember Non-Servicemember

Credit or consumer reporting

Debt collection

Mortgage

Credit card

Checking or savings

Student loan

Money transfer or service, virtual currency

Vehicle loan or lease

Personal loan

Prepaid card

Payday loan

Credit repair

Title loan

38%

38%

26%

25%

10%

9%

8%

9%

6%

8%

3%

3%

2%

2%

3%

2%

1%

1%

0.7%

0.8%

0.7%

0.7%

0.4%

0.3%

0.3%

0.2%
13 BUREAU OF CONSUMER FINANCIAL PROTECTION

Older Consumers

Consumer Response and the Bureau’s Office of Financial Protection for Older Americans 

monitor and analyze complaints from consumers who indicated they were 62 years of age or 

older at the time of submission. As shown in Figure 6, complaints submitted by older consumers 

were less often about credit or consumer reporting, debt collection, and student loans, and more 

often about mortgage, credit card, and checking or savings than complaints submitted by 

consumers under 62. Section 4 of this report (Complaint Types) analyzes some of these 

differences.

FIGURE 6: PERCENTAGE OF COMPLAINTS BY PRODUCT AND AGE GROUP

Credit or consumer reporting

Debt collection

Credit card

Mortgage

Checking or savings

Student loan

Money transfer or service, virtual currency

Vehicle loan or lease

Personal loan

Prepaid card

Payday loan

Credit repair

Title loan

21%

37%

23%

26%

15%

8%

19%

7%

9%

6%

2%

5%

4%

3%

3%

3%

2%

2%

1%

1%

0.7%

1%

0.6%

0.5%

0.3%

0.3%

62 or Older Under 62
14 BUREAU OF CONSUMER FINANCIAL PROTECTION

3. Complaint Resolution

Companies responded to 96% of the approximately 264,100 complaints that the Bureau sent to 

them for response in 2018. Companies confirmed a commercial relationship with, and provided

responses to, consumers in approximately 91% of these complaints. Table 1 shows how 

companies responded. 

Company responses include descriptions of steps that have or 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,” “In progress,” and administrative 

options. 

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 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 of non-monetary relief to consumers include: mortgage foreclosure 

alternatives that help consumers keep their home; stopping unwanted calls from debt collectors; 

correcting inaccurate data provided or reported in consumers’ credit reports; correcting account 

information; and, addressing formerly unmet customer service issues.

“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 is used if the explanation substantively meets the consumer’s desired 

resolution or explains why no further action will be taken. 

Companies provide an “Administrative Response” when further review by Consumer Response 

may be needed. This includes complaints submitted by unauthorized third parties, complaints 

that are the result of fraud, scams or business identity theft, and complaints where a company 

cannot confirm a commercial relationship with the consumer. 

Section 4 of this report (Complaint Types) provides an analysis of patterns and trends of 

company responses for each product and service.
15 BUREAU OF CONSUMER FINANCIAL PROTECTION

TABLE 1: HOW COMPANIES HAVE RESPONDED TO CONSUMER COMPLAINTS13

Closed 

with 

monetary 

relief

Closed 

with nonmonetary 

relief

Closed with 

explanation

Administr

-ative 

response

Company 

reviewing

Company 

did not 

provide a 

timely 

response

All 4% 12% 74% 3% 5% 2%

Checking or 

savings 21% 3% 66% 3% 6% 1%

Credit card 16% 11% 66% 2% 5% 1%

Credit or consumer 

reporting <1% 18% 72% 3% 6% 1%

Credit repair 11% 10% 64% 2% 4% 9%

Debt collection 1% 12% 78% 1% 3% 5%

Money transfer or 

service, virtual 

currency

7% 4% 80% 2% 4% 2%

Mortgage 3% 3% 85% 4% 4% 2%

Payday loan 3% 3% 79% 6% 3% 6%

Personal loan 6% 6% 75% 5% 4% 5%

Prepaid card 21% 3% 68% 2% 5% 1%

Student loan 2% 6% 85% 2% 3% 2%

Title loan 4% 12% 72% 3% 4% 6%

Vehicle loan or 

lease 5% 8% 79% 1% 4% 4%

 13 Percentages throughout this report may not sum to 100% due to rounding. The Bureau requests that companies 

provide a response to each complaint within 15 calendar days of the complaint being sent to the company. When a 

complaint cannot be closed by the company within 15 calendar days, the company may indicate that work to respond 

to the complaint is “In progress” and provide a final closure response within 60 calendar days of the complaint being 

sent to the company. Responses provided outside the 15- or 60-day timeframe are considered “untimely.”
16 BUREAU OF CONSUMER FINANCIAL PROTECTION

4. Complaint Types

Monitoring consumer complaints is one of Consumer Response’s primary functions. Complaints 

provide insights into problems consumers experience and can serve as an early indicator of 

issues in the financial marketplace. Complaint analyses support the Bureau’s work to supervise 

companies, enforce federal consumer financial laws, propose rules, and develop tools to 

empower consumers to make informed financial decisions.

The Bureau analyzes complaints in a number of ways to identify trends and possible consumer 

harm. For example, Consumer Response counts complaints across a number of categories, such 

as product, issue, sub-product, sub-issue, company, and company response, among others.

Consumer Response analyzes these counts across time and geography, as well as by selfidentified characteristics such as servicemember status and age.14

While counting complaints provides important information to the Bureau, it has some 

limitations. The Bureau recognizes that complaint data can often be better understood in the 

context of other data, such as product or service market size and company share. But providing 

additional market context to complaint information requires the Bureau to balance a number of 

considerations. For example, a variety of measures may provide useful context, (e.g., company 

size, number of accounts, number of transactions, and company market share), but the 

availability of this market information varies by financial product and service.

Given these and other considerations, the Bureau has not yet identified an approach to 

contextualize multiple products, services, and markets without imposing a significant burden on 

companies to provide data. Nevertheless, because context is important, throughout this section 

the Bureau references publicly available data and research, where available, that provides some 

market context. The Bureau also continues to welcome specific suggestions and best practices 

about how to publish information about complaints.

In addition to counting complaints, the Bureau analyzes the narrative text consumers provide in 

their complaints, frequently augmenting traditional qualitative analysis with automated 

methods. Similarly, the Bureau analyzes the text companies provide in their responses to 

consumers and in the documents provided to support their responses. Analyzing text from 

 14 When comparing older consumers to their younger counterparts, the Bureau limits its analysis to consumers who 

provided their age when submitting a complaint. Therefore, the Bureau excludes complaints where the consumer 

opted not to disclose their age.
17 BUREAU OF CONSUMER FINANCIAL PROTECTION

consumers and companies provides a more complete understanding of issues and a clearer idea 

of how companies respond to those issues.

The following sub-sections provide information and analyses of the types of complaints 

consumers submitted to the Bureau in 2018.15 Each sub-section includes an analysis of the 

products consumers complained about, problems they experienced, and how companies 

responded.16 Where appropriate, sub-sections include a discussion of how product types and 

issues differ for specialty populations (i.e., older consumers and servicemembers).

4.1 Credit or consumer reporting

The Bureau received approximately 126,300 credit or consumer reporting complaints in 2018. 

The Bureau sent approximately 114,900 (or 91%) of these complaints to companies for review 

and response, referred 6% to other regulatory agencies, and found 3% to be incomplete. At the 

end of 2018, 0.3% of credit or consumer reporting complaints were pending with the consumer 

and 0.4% were pending with the Bureau (see Figure 7A, Routing Outcomes).

Companies responded to approximately 99% of credit or consumer reporting complaints sent to 

them for review and response. Companies closed 72% of complaints with an explanation, 18% 

with non-monetary relief, and 0.3% with monetary relief. Companies used an administrative 

response for 3% of complaints. At the end of 2018, 6% of complaints were pending review by the 

company. Companies did not provide a timely response for 1% of complaints (see Figure 7B, 

Company Responses).

 15 Complaint data in this report is current as of January 2, 2019. Complaint numbers are rounded throughout the 

report; therefore, numbers and percentages may not sum to sub-totals or 100%.

16 The Bureau’s online complaint form is dynamic and, therefore, adjusts based on consumer selections. Some issues 

are not available for certain sub-products (e.g., the issue unable to get your credit report or credit score is not 

available for complaints about other personal consumer reports). A full list of complaint form products, sub-products, 

issues, and sub-issues is available at 

https://files.consumerfinance.gov/f/documents/201704_cfpb_Consumer_Complaint_Form_Product_and_Issue_O

ptions.pdf.
18 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 7: CREDIT OR CONSUMER REPORTING COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses

The remainder of this analysis focuses only on those credit or consumer reporting complaints 

for which the company confirmed a commercial relationship with the consumer and responded 

with an explanation or relief (i.e., complaints closed with explanation, closed with non-monetary 

relief, and closed with monetary relief).

When submitting credit or consumer reporting complaints, consumers specify whether they are 

complaining about a credit report or some other personal consumer report (e.g., background

checks, employment screening).17 In 2018, consumers complained about credit reports more 

frequently than other personal consumer reports (e.g., background checks, employment 

screening) by a wide margin (see Figure 8).

 17 The Bureau publishes an annual list of consumer reporting companies. This list includes the three nationwide 

credit reporting companies as well as other companies that focus on certain market areas and consumer segments.

See Consumer Fin. Prot. Bureau, List of Consumer Reporting Companies (Jan. 2019), available at

www.consumerfinance.gov/documents/6138/cfpb_consumer-reporting-companies-list.pdf.
19 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 8: CREDIT OR CONSUMER REPORTING COMPLAINTS BY TYPE OF REPORT AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Consumers also identify the issue that best describes the problem they experienced. For credit 

or consumer reporting complaints, options include: credit monitoring or identity theft 

protection services; improper use of report; incorrect information on report; problem with a 

credit reporting company’s investigation into an existing problem; problem with fraud alerts or 

security freezes; and, unable to get credit report or credit score. In 2018, incorrect information 

on a report was the most common issue (see Figure 9).

FIGURE 9: CREDIT OR CONSUMER REPORTING COMPLAINTS BY ISSUES AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Of the approximately 61% of consumers who identified incorrect information on a report as 

their primary issue, most indicated they did not recognize an account on their report. These 

complaints often involved consumers indicating they were victims of identity theft. To support 

their claims, many consumers submitted relevant documentation, such as police reports and

identity theft reports. Consumers frequently identified a close relative (e.g., a spouse, ex-spouse, 

or other related individual) as the person they suspect of opening the accounts in question. 

Consumer reporting companies frequently indicate that they complete a dispute reinvestigation 

and some provided suggested next steps for victims of identity theft in their responses.

Credit reporting

Other personal consumer

report

102,200 (99%)

1,600 (1%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief

Incorrect information on your report

Problem with a credit reporting company's

investigation into an existing problem

Improper use of your report

Unable to get your credit report or credit score

Problem with fraud alerts or security freezes

Credit monitoring or identity theft protection

services

63,000 (61%)

23,300 (23%)

12,600 (12%)

2,000 (2%)

1,600 (2%)

1,100 (1%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
20 BUREAU OF CONSUMER FINANCIAL PROTECTION

Other consumers who complained about incorrect information on a report acknowledged the 

accounts were theirs but disputed specific details, such as the account status or other 

information (e.g., open date, outstanding balance). Consumer reporting companies generally 

responded to these complaints by forwarding the substance of the consumer’s dispute to the 

furnisher of the information for verification.

Approximately 85% of consumers indicated that they previously contacted the consumer 

reporting company before submitting a credit or consumer reporting complaint (see Section 2, 

Figure 3), and more than 20% of consumers identified problems with a company’s investigation 

into an existing issue (see Figure 9). The majority of these consumers sought an additional 

review of a prior dispute and nearly one in six received relief in response to their complaint. For 

many of these complaints, consumer reporting companies responded with a summary 

description of the dispute process and the results of their reinvestigation. Some company 

responses also provided additional advice, such as the suggestion to contact the original creditor

to request documents or dispute the information in question.

As required by the Fair Credit Reporting Act, this report includes information about complaints

submitted by consumers about nationwide consumer reporting agencies (NCRAs)18 and related 

to incomplete or inaccurate information on their credit report.19 Of the approximately 126,300 

credit or consumer reporting complaints the Bureau received in 2018, consumers submitted 

approximately 82,300 (65%) complaints about the three NCRAs: Equifax, Experian, and 

TransUnion.

Nearly 83% of complaints submitted about the NCRAs relate to one of two accuracy issues (i.e., 

incorrect information on report and problem with a company’s investigation into an existing 

issue). For these issues, the Bureau asks the NCRAs whether the consumer submitted a previous 

dispute. The NCRAs responded “yes” 70% of the time.

Tables 2, 3, and 4 provide information about the problems consumers identified when 

submitting credit or consumer reporting complaints. These tables show that consumers 

generally complained about the same types of problems, and at similar rates, across all three 

NCRAs.

 18 15 U.S.C. § 1681a(p) (“The term ‘consumer reporting agency that compiles and maintains files on consumers on a 

nationwide basis’ means a consumer reporting agency that regularly engages in the practice of assembling or 

evaluating, and maintaining, for the purpose of furnishing consumer reports to third parties bearing on a consumer’s 

credit worthiness, credit standing, or credit capacity, each of the following regarding consumers residing nationwide: 

(1) Public record information; (2) Credit account information from persons who furnish that information regularly 

and in the ordinary course of business.”)

19 Id. § 1681i(e).
21 BUREAU OF CONSUMER FINANCIAL PROTECTION

TABLE 2: COMPLAINTS SUBMITTED ABOUT NATIONWIDE CONSUMER REPORTING AGENCIES WITH A 

CLOSURE RESPONSE AND ISSUES RELATED TO ACCURACY 

Equifax Experian TransUnion

Incorrect information on your report 16,100 16,800 16,600

Problem with a company’s investigation into an 

existing issue 5,900 6,400 6,100

The majority of complaints submitted about NCRAs related to (1) accuracy issues, or (2) 

problems with the process of investigating disputes of accuracy by consumers. The breakdown 

of accuracy-related complaints is similar among the NCRAs (see Table 3).

TABLE 3: SUB-ISSUE PERCENTAGES FOR INCORRECT INFORMATION ON YOUR REPORT

Equifax Experian TransUnion

Information belongs to someone else 52% 50% 50%

Account status incorrect 17% 18% 18%

Account information incorrect 15% 16% 16%

Personal information incorrect 6% 6% 5%

Public record information inaccurate 4% 4% 5%

Old information reappears or never goes away 4% 4% 4%

Information is missing that should be on the report 2% 2% 2%

Information is incorrect 0.2% 0.1% 0.2%

Total 100% 100% 100%

The breakdown of investigation-related complaints issues is also similar among the NCRAs (see 

Table 4).
22 BUREAU OF CONSUMER FINANCIAL PROTECTION

TABLE 4: SUB-ISSUE PERCENTAGES FOR PROBLEM WITH A CREDIT REPORTING COMPANY’S 

INVESTIGATION INTO AN EXISTING ISSUE

Equifax Experian TransUnion

Their investigation did not fix an error on your report 73% 76% 72%

Investigation took more than 30 days 8% 7% 9%

Difficulty submitting a dispute or getting information 

about a dispute over the phone 8% 7% 8%

Was not notified of investigation status or results 7% 6% 6%

Problem with personal statement of dispute 4% 5% 4%

Total 100% 100% 100%

Credit or consumer reporting complaints were the most complained about product by 

servicemembers (see Section 2, Figure 5). Servicemembers rely on accurate credit reporting to 

maintain security clearances, which can be adversely impacted by a history of failing to meet 

their financial obligations, being in excessive debt, or having a high debt-to-income ratio.20 On 

average, servicemembers submitted approximately 10% of credit or consumer reporting 

complaints, with a greater percentage complaining about issues relating to active credit 

monitoring (e.g., issues with prior investigations or with credit monitoring) (see Figure 10).

 20 See Consumer Fin. Prot. Bureau, WARNO: New security clearance guidelines make it more important than ever 

for servicemembers to monitor their credit (Aug. 20, 2018), available at https://www.consumerfinance.gov/aboutus/blog/warno-new-security-clearance-guidelines-make-it-more-important-ever-servicemembers-monitor-theircredit. 
23 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 10: SERVICEMEMBER ISSUE RATE COMPARED TO PERCENTAGE OF CREDIT REPORTING 

COMPLAINTS SUBMITTED BY SERVICEMEMBERS

Complaints submitted by older consumers were less likely to be about credit or consumer 

reporting when compared to consumers under 62 years old. Approximately 21% of complaints 

submitted by older consumers were credit or consumer reporting complaints, compared to 37% 

submitted by consumers under 62 years old (see Section 2, Figure 6).

Older consumers complained about different consumer reporting issues than consumers under 

62 years old. Older consumers comprised approximately 8% of credit or consumer reporting 

complaints (see Figure 11) and tended to raise issues about monitoring their credit. For example, 

older consumers submitted over 20% of complaints about problems with fraud alerts or security 

freezes, and 15% of complaints about getting a report or score and credit monitoring services. In 

contrast, older consumers submitted approximately 6% of complaints about improper use of 

their report. This overall lower rate of complaints related to credit inquiries might be explained, 

among other things, by fewer debts held and sought by older consumers.21

Older consumers reported problems when attempting to access their free annual report online. 

Often they complained to the Bureau that NCRAs were not able to authenticate their identity

online, requiring these consumers to mail sensitive personal information to the credit reporting 

company in order to receive their report.

 21 See e.g., Consumer Fin. Prot. Bureau, Financial Well-being of Older Americans at 17, available at

https://www.consumerfinance.gov/documents/7041/bcfp_financial-well-being-older-americans_report.pdf (“many 

older adults, compared to their younger counterparts, have lower amounts of and fewer debts”). See also Federal 

Reserve Board, 2016 SCF Chartbook (Oct. 2017), at 837-939 available at 

https://www.federalreserve.gov/econres/files/BulletinCharts.pdf, and Consumer Fin. Prot. Bureau, Consumer 

Lending Trends by Age, available at https://www.consumerfinance.gov/data-research/consumer-credittrends/mortgages/lending-borrower-age/#anchor_lending-levels.

0% 10% 20% 30%

Incorrect information on your report

Problem with fraud alerts or security freezes

Unable to get your credit report or credit score

Problem with a company's investigation into an existing issue

Improper use of your report

Credit monitoring or identity theft protection services

Product average for servicemembers (10%)
24 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 11: OLDER CONSUMER ISSUE RATE COMPARED TO PERCENTAGE OF CREDIT REPORTING 

COMPLAINTS SUBMITTED BY OLDER CONSUMERS

4.2 Debt collection

The Bureau received approximately 81,500 debt collection complaints in 2018. The Bureau sent 

approximately 51,700 (or 63%) of these complaints to companies for review and response, 

referred 27% to other regulatory agencies, and found 8% to be incomplete. At the end of 2018, 

1% of debt collection complaints were pending with the consumer and 2% were pending with the 

Bureau (see Figure 12A, Routing Outcomes).

Consumers can submit complaints about creditors collecting their own debts (i.e., first-party 

collectors) or companies collecting debt on behalf of others, such as creditors or businesses (i.e., 

third-party collectors).22 When the Bureau received debt collection complaints about companies

where it was not the primary federal regulator (e.g., a mobile phone or Internet service 

provider), it referred the complaints to other regulatory agencies—most often, the Federal Trade 

Commission (FTC).

Companies responded to approximately 95% of debt collection complaints sent to them for 

review and response. Companies closed 78% of complaints with an explanation, 12% with nonmonetary relief, and 1% with monetary relief. Companies used an administrative response for

1% of complaints. At the end of 2018, 3% of complaints were pending review by the company. 

Companies did not provide a timely response for 5% of complaints (see Figure 12B, Company 

Responses).

 22 See Consumer Fin. Prot. Bureau, Fair Debt Collection Practices Act (Mar. 2019) (“Debt collection is a $11.5 billion 

industry that employs nearly 118,500 people across approximately 7,700 collection agencies in the United States. ... 

According to the Bureau’s Consumer Credit Panel, about 28 percent of consumers with a credit file have a third-party 

collection trade line listed.”) (citations omitted). 

0% 10% 20% 30%

Improper use of your report

Problem with a company's investigation into an existing issue

Incorrect information on your report

Credit monitoring or identity theft protection services

Unable to get your credit report or credit score

Problem with fraud alerts or security freezes

Product average for older consumers (8%)
25 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 12: DEBT COLLECTION COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses

The remainder of this analysis focuses only on those debt collection complaints for which the 

company confirmed a commercial relationship with the consumer and responded with an 

explanation or relief (i.e., complaints closed with explanation, closed with non-monetary relief, 

and closed with monetary relief).

When submitting debt collection complaints, consumers specify the type of debt. Options 

include: auto debt, credit card debt, federal student loan debt, medical debt, mortgage debt, 

payday loan debt, private student loan debt, “other” debt (e.g., phone bill, health club 

membership, utilities), and debt that is not known.23 In 2018, “other” debt and credit card debt 

were the most complained about debt types (see Figure 13). As more than 47 million credit 

reports included at least one telecommunications item between 2013 and 2018—the vast 

majority of which were related to collections—it is not surprising that telecommunications debt 

is common within the “other” debt type.24

 23 The Bureau’s complaint form requires consumers to select the type of debt from a list of options, including I don’t 

know.

24 See Consumer Fin. Prot. Bureau, Quarterly Consumer Credit Trends: Collection of Telecommunications Debt

(Aug. 2018), available at https://www.consumerfinance.gov/documents/6716/bcfp_consumer-credittrends_collection-telecommunications-debt_082018.pdf.
26 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 13: DEBT COLLECTION COMPLAINTS BY TYPE OF DEBT AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Consumers also identify the issue that best describes the problem they experienced. For debt 

collection complaints, options include: attempts to collect debt not owed; communication 

tactics; false statements or representation; threatened to contact someone or share information 

improperly; took or threatened to take negative or legal action; and, written notification about 

debt. In 2018, the most common issue concerned attempts to collect debt not owed (see Figure 

14). 

FIGURE 14: DEBT COLLECTION COMPLAINTS BY ISSUES AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Other debt

Credit card debt

I do not know

Medical debt

Auto debt

Payday loan debt

Mortgage debt

Federal student loan debt

Private student loan debt

14,300 (30%)

10,300 (22%)

9,800 (21%)

7,500 (16%)

1,500 (3%)

1,300 (3%)

1,000 (2%)

800 (2%)

800 (2%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief

Attempts to collect debt not owed

Written notification about debt

Communication tactics

Took or threatened to take

negative or legal action

False statements or representation

Threatened to contact someone or

share information improperly

20,900 (44%)

11,500 (24%)

5,500 (12%)

4,100 (9%)

3,900 (8%)

1,200 (3%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
27 BUREAU OF CONSUMER FINANCIAL PROTECTION

Consumers who submitted complaints about attempts to collect a debt not owed referenced a

number of reasons why they thought they did not owe the debt. For example, consumers stated

the purported debt was discharged in bankruptcy, was already paid, or was the result of identity 

theft. Most often, however, consumers claimed the debt did not belong to them. These 

consumers described third-party collectors attempting to collect debts related to financial 

products (e.g., credit cards, vehicle debt, and payday loans), and consumer products and 

services (e.g., mobile services, Internet, cable, and medical). In response to these complaints, 

collectors often reported closing the account and discontinuing collection attempts, or providing

additional information to consumers about the debt purportedly owed.

Approximately 24% of debt collection complaints were about issues regarding written 

notifications about a debt. In these complaints, consumers most frequently indicated that the 

collector did not provide enough information to verify the debt. Some consumers reported

requesting more information from collectors; however, they reported not receiving details or 

documents to support the collection. Other consumers described not learning of the debt until 

they obtained their credit report. In response to these complaints, collectors often provided 

documents to support their collection efforts, or reported discontinuing collection and closing

the account. When collectors reported discontinuing collection, they often stated they would

take steps to remove negative information from a consumer’s credit report.

Consumers who submitted complaints about communication tactics most often identified issues 

related to frequent or repeated calls. These consumers typically described one of two patterns: 

collectors who made repeated calls in short periods, and collectors who made repeated calls over 

longer time periods. Consumers who complained about repeated calls in a short period

described collectors placing successive calls on the same day and, oftentimes, within minutes of 

the preceding call. Consumers who complained about repeated calls over a long period describe 

situations where collectors do not place successive calls on the same day, but rather place a 

consistent number of calls over weeks, months, or even years. In response to these complaints, 

companies reported discontinuing calling the consumer and placing the consumer on the 

company’s do not call list.

In their debt collection complaints, consumers often raised contemporaneous credit reporting 

concerns. Consumers reported that debt collectors use the threat of negative credit reporting—

and the potential for a drop in credit scores—as a way to compel payment. Collectors frequently 

responded to these complaints by stating that they have an obligation to report accurate 

information to consumer reporting companies and the information reported is accurate.
28 BUREAU OF CONSUMER FINANCIAL PROTECTION

For servicemembers, debt collection continues to be an area of concern.25 On average, 

servicemembers comprised approximately 10% of debt collection complaints (see Figure 15). 

Servicemembers comprised approximately 13% of debt collection complaints about mortgage 

and auto debt, but only approximately 9% of debt collection complaints about medical debt and 

private student loan debt. These differences may reflect differences in overall rate of ownership 

of the underlying debt, and not necessarily differences in the rates at which they complain. For 

example, veterans are entitled to health care through the Veteran’s Health Administration, 

which may explain the relatively lower rate of medical debt and resulting complaints.26

FIGURE 15: SERVICEMEMBER RATE OF DEBT TYPES COMPARED TO PERCENTAGE OF DEBT 

COLLECTION COMPLAINTS SUBMITTED BY SERVICEMEMBERS

Although servicemembers comprised 10% of debt collection complaints, they comprised

approximately 14% of debt collection complaints about collectors taking or threatening negative 

or legal action (see Figure 16).27 These complaints frequently involved attempts to take funds 

 25 See Consumer Fin. Prot. Bureau, Office of Servicemember Affairs Annual Report (Jan. 2019), available at

https://www.consumerfinance.gov/documents/7208/cfpb_osa_annual-report_2018.pdf (The Bureau’s Office of 

Servicemember Affairs noted medical debt and telecommunications debt as emerging issues and continuing trends in 

the financial marketplace for consumers.)

26 Id. The most recent annual report for the Office of Servicemember Affairs includes a discussion of the increasing 

occurrence of medical debt for servicemembers because of policy changes that result in servicemembers using civilian 

medical facilities.

27 See id. at p. 26 (“While the top debt collection issues are similar for servicemembers and non-servicemembers, 

servicemembers are more likely to complain about a debt collector taking or threatening to take legal action against 

them. The [Bureau’s Office of Servicemember Affairs] has previously documented debt collectors inappropriately 

threatening servicemembers with Uniform Code of Military Justice (UCMJ) action in previous complaint reports.”).

0% 10% 20% 30%

I do not know

Private student loan debt

Medical debt

Other debt

Credit card debt

Payday loan debt

Federal student loan debt

Auto debt

Mortgage debt

Product average for servicemembers (10%)
29 BUREAU OF CONSUMER FINANCIAL PROTECTION

that the servicemembers thought were protected from collection, such as disability payments,

and attempts to seize property.

FIGURE 16: SERVICEMEMBER ISSUE RATE COMPARED TO PERCENTAGE OF DEBT COLLECTION

COMPLAINTS SUBMITTED BY SERVICEMEMBERS

By contrast, debt collection comprised a smaller percentage of complaints for older consumers 

than for consumers under 62 years old. Approximately 23% of complaints submitted by older 

consumers were debt collection complaints, compared to 26% submitted by consumers under 62

(see Section 2, Figure 6). 

Older consumers comprised approximately 10% of debt collection complaints (see Figure 17), 

but over 22% of debt collection complaints about mortgage. This is consistent with higher 

homeownership rates among older consumers, when compared with consumers under the age 

of 62 years old.28

 28 See U.S. Census Bureau, Quarterly Residential Vacancies and Homeownership 3rd quarter 2018 (Oct. 2018), 

available at https://www.census.gov/housing/hvs/files/currenthvspress.pdf (“The third quarter 2018 

homeownership rate was highest for those householders ages 65 years and over (78.6 percent) and lowest for those 

householders under 35 years of age (36.8 percent).”).

0% 10% 20% 30%

Written notification about debt

Threatened to contact someone or share information improperly

Attempts to collect debt not owed

Communication tactics

False statements or representation

Took or threatened to take negative or legal action

Product average for servicemembers (10%)
30 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 17: OLDER CONSUMER RATE OF DEBT TYPES COMPARED TO PERCENTAGE OF DEBT 

COLLECTION COMPLAINTS SUBMITTED BY OLDER CONSUMERS

4.3 Mortgages

The Bureau received approximately 30,100 mortgage complaints in 2018. The Bureau sent 

approximately 25,500 (or 85%) of these complaints to companies for review and response, 

referred 10% to other regulatory agencies, and found 4% to be incomplete. At the end of 2018, 

0.3% of mortgage complaints were pending with the consumer and 1% were pending with the 

Bureau (see Figure 18A, Routing Outcomes).

Companies responded to approximately 98% of mortgage complaints sent to them for review 

and response. Companies closed 85% of complaints with an explanation, 3% with monetary 

relief, and 3% with non-monetary relief. Companies used an administrative response for 4% of 

complaints. At the end of 2018, 4% of complaints were pending review by the company. 

Companies did not provide a timely response for 2% of complaints (see Figure 18B, Company 

Responses).

0% 10% 20% 30%

Private student loan debt

Payday loan debt

Federal student loan debt

Auto debt

Other debt

Medical debt

Credit card debt

I do not know

Mortgage debt

Product average for older consumers (10%)
31 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 18: MORTGAGE COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses

The remainder of this analysis focuses only on those mortgage complaints for which the 

company confirmed a commercial relationship with the consumer and responded with an 

explanation or relief (i.e., complaints closed with explanation, closed with non-monetary relief, 

and closed with monetary relief).

When submitting mortgage complaints, consumers specify the type of mortgage. Options 

include: conventional home mortgage, Federal Housing Administration (FHA) mortgage, home 

equity loan or line of credit (HELOC), reverse mortgage, Veterans Administration (VA)

mortgage, and other types of mortgages. In 2018, conventional home mortgages were the most 

complained about mortgage type (see Figure 19).
32 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 19: MORTGAGE COMPLAINTS BY TYPE AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Consumers also identify the issue that best describes the problem they experienced. For 

mortgage complaints, options include: applying for a mortgage or refinancing an existing 

mortgage; closing on a mortgage; problem with a credit or consumer report; struggling to pay 

mortgage; and, trouble during payment process. In 2018, trouble during payment process was 

the most common issue (see Figure 20).

In the fourth quarter of 2018, approximately $9.5 trillion in existing mortgage debt was 

outstanding. Over the course of 2018, more than $1.7 trillion in new loans were originated and 

about 1% of outstanding balances transitioned into delinquency per quarter.29 By contrast, 

consumers who complained about struggling to pay their mortgage submitted 35% of mortgage 

complaints. This suggests that consumers are more likely to submit complaints when their loans 

enter delinquency or are at risk of entering delinquency.

 29 See Federal Reserve Bank of N.Y., Quarterly Report on Household Debt and Credit (Q4 2018) (February 2019), 

available at

https://www.newyorkfed.org/medialibrary/interactives/householdcredit/data/xls/HHD_C_Report_2018Q4.xlsx.

Conventional home mortgage

Other type of mortgage

FHA mortgage

Home equity loan or line of

credit (HELOC)

VA mortgage

Reverse mortgage

13,100 (57%)

3,700 (16%)

3,200 (14%)

1,600 (7%)

1,100 (5%)

300 (1%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
33 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 20: MORTGAGE COMPLAINTS BY ISSUES AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Of the approximately 46% of consumers with complaints about trouble during the payment 

process, most consumers identified problems regarding escrow accounts, missing payments,

and fees assessed on their accounts. For example, consumers described receiving escrow 

account analyses with increased monthly payments, but these consumers were unaware of 

increases to their homeowner insurance, taxes, or both. In response to these complaints, 

mortgage servicers often provided a written explanation to the consumer that included

calculations of annual taxes and insurance. When an escrow analysis reflected a shortfall, some 

servicers stated that the Real Estate Settlement Procedures Act (RESPA) authorizes a maximum 

escrow cushion not to exceed one-sixth of the total annual projected escrow disbursements 

made during an escrow cycle over twelve months (up to two months), unless state laws allows 

for a lesser amount.30

When consumers raised issues about missing payments, the missing payments frequently 

coincided with the servicing transfer of the loan. Although some consumers described providing

bank records and other documentation to prove they remitted payment, they expressed ongoing 

concerns about negative credit reporting and late fees when the servicer did not resolve the issue 

quickly. In response to these concerns, mortgage servicers sometimes provided a payment 

history of the loan account, including payment histories from prior servicers. Some servicers 

explained there were delays in onboarding and recording payments received by the prior 

servicer. These explanations often included the steps the servicer was taking to update the 

account, including updating credit reporting and assessed late fees. 

Consumers with complaints about struggling to pay their mortgage often cited concerns 

involving loss mitigation assistance. These consumers raised a variety of issues ranging from 

 30 Reg. X § 1024.17(c)(5).

Trouble during payment process

Struggling to pay mortgage

Applying for a mortgage or

refinancing an existing mortgage

Closing on a mortgage

Problem with a credit report or

credit score

10,600 (46%)

8,200 (35%)

2,000 (9%)

1,500 (7%)

700 (3%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
34 BUREAU OF CONSUMER FINANCIAL PROTECTION

repeated requests for documentation to delays in the review of their loss mitigation application. 

Some consumers claimed that the servicer denied the loss mitigation application for incorrect 

reasons. In response to these concerns, servicers often provided explanations for their document 

requests and delays. Frequently, servicers stated they could not approve loans for loss mitigation 

assistance because of investor guidelines.

In complaints about applying for a mortgage or refinancing an existing mortgage, consumers 

often raised issues about interest rate locks. Some consumers expressed confusion about the 

rate lock process. Other consumers described delays in their loan processing, which led to the 

expiration of their rate lock. In response to these complaints, lenders frequently stated the

consumer was untimely in extending the rate lock or never had a formal rate lock agreement in 

place.

For both servicemembers and older consumers, mortgages comprised a greater percentage of 

their complaints than for other consumers. Approximately 19% of complaints submitted by 

older consumers were mortgage complaints, compared to only 7% submitted by consumers 

under 62 years old (see Section 2, Figure 6). This is consistent with higher homeownership rates

among older consumers than their younger counterparts.31 For servicemembers, the differences 

are smaller, with 10% of servicemember complaints about mortgages compared to 9% of nonservicemember complaints (see Section 2, Figure 5).

More than 86% of consumers who submit complaints about reverse mortgages identified as an

older consumer, which is consistent with eligibility requirements limiting reverse mortgages to 

homeowners who are at least 62 years old (see Figure 21).32 Less than 14% of consumers who 

submit complaints about FHA mortgages identified as an older consumer. This is also consistent 

with FHA loans being popular mortgage products among first-time homebuyers. Perhaps more 

notably, older consumers were more likely to describe issues with home equity loans and lines of 

credit.33

 31 U.S. Census Bureau, supra note 28 (Americans over the age of 65 have a homeownership rate of over 78%, 

compared to less than 37% for Americans under 35).

32 24 CFR § 206.33.

33 One potential explanation for this difference is that older consumers are more likely to have older loans. Because 

home equity loan originations have declined relative to their peak, remaining complaints about them tend to be from 

older vintage loans and are therefore more likely to come from older consumers. See Federal Reserve Bank of St. 

Louis, Real Estate Loans: Revolving Home Equity Loans, available at

https://fred.stlouisfed.org/series/RHEACBW027NBOG .
35 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 21: OLDER CONSUMER RATE OF MORTGAGE COMPLAINT TYPES COMPARED TO PERCENTAGE 

OF MORTGAGE COMPLAINTS SUBMITTED BY OLDER CONSUMERS

Approximately 84% of consumers who submit complaints about VA mortgages identified as a 

servicemember (see Figure 22).34 Complaints about VA mortgages comprised over a third of 

mortgage complaints submitted by servicemembers, suggesting that the rate at which 

servicemembers utilize the VA mortgage program is high.35

FIGURE 22: SERVICEMEMBER RATE OF MORTGAGE COMPLAINT TYPES COMPARED TO PERCENTAGE 

OF MORTGAGE COMPLAINTS SUBMITTED BY SERVICEMEMBERS

 34 VA mortgage eligibility is limited to servicemembers. As with age, servicemember status is an optional field. For 

some intake channels, this field is not available (e.g., a consumer who mails a complaint may not reference their 

servicemembers status). The 16% of VA loan complaints that come from non-servicemembers may include some 

servicemembers who simply declined to provide their servicemember status or did not have an opportunity to do so.

35 In 2018, according to VA Lender Loan Volume Reports, the VA guaranteed over 610,000 VA loans. See U.S. 

Department of Veterans Affairs, FY 2018 Lender Loan Volume, available at

https://www.benefits.va.gov/HOMELOANS/documents/docs/2018_lender_loan_volume.xlsx.

0% 20% 40% 60% 80% 100%

FHA mortgage

Other type of mortgage

VA mortgage

Conventional home mortgage

Home equity loan or line of credit (HELOC)

Reverse mortgage

Product average for older consumers (28%)

0% 20% 40% 60% 80% 100%

Other type of mortgage

FHA mortgage

Conventional home mortgage

Home equity loan or line of credit (HELOC)

Reverse mortgage

VA mortgage

Product average for servicemembers (12%)
36 BUREAU OF CONSUMER FINANCIAL PROTECTION

4.4 Credit cards

The Bureau received approximately 28,700 credit card complaints in 2018.36 The Bureau sent 

approximately 23,400 (or 82%) of these complaints to companies for review and response, 

referred 15% to other regulatory agencies, and found 3% to be incomplete. At the end of 2018, 

0.3% of credit card complaints were pending with the consumer and 1% were pending with the 

Bureau (see Figure 23A, Routing Outcomes).

Companies responded to approximately 99% of credit card complaints sent to them for review 

and response. Companies closed 66% of complaints with an explanation, 16% with monetary 

relief, and 11% with non-monetary relief. Companies used an administrative response for 2% of 

complaints. At the end of 2018, 5% of complaints were pending review by the company. 

Companies did not provide a timely response for 1% of complaints (see Figure 23B, Company 

Responses).

FIGURE 23: CREDIT CARD COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses

 36 See Federal Reserve Bank of N.Y., supra note 29 (According to Federal Reserve data, as of the fourth quarter 2018, 

nearly 480 million general-purpose credit card accounts exist). Additionally, a recent estimate from the Bureau’s 2017 

consumer credit market study suggests that nearly 170 million consumers have at least one credit card. See Consumer 

Fin. Prot. Bureau, The Consumer Credit Card Market (December 2017), available at

https://files.consumerfinance.gov/f/documents/cfpb_consumer-credit-card-market-report_2017.pdf.
37 BUREAU OF CONSUMER FINANCIAL PROTECTION

The remainder of this analysis focuses only on those credit card complaints for which the 

company confirmed a commercial relationship with the consumer and responded with an 

explanation or relief (i.e., complaints closed with explanation, closed with non-monetary relief, 

and closed with monetary relief).

When submitting credit card complaints, consumers specify whether they are complaining 

about a general-purpose credit card (or charge card) or a store credit card. In 2018, consumers 

complained about general-purpose credit cards more frequently than store credit cards (see 

Figure 24).

Combined credit card balances reached a total of $870 billion in the fourth quarter of 2018.

According to the Bureau’s most recent report on the credit card market, at the beginning of 

2017, private label (store) credit cards comprised approximately 6% of total transaction volume,

nearly 11% of outstanding balances, and more than 33% of all open accounts. Consumers 

submitted complaints about all aspects of the credit card lifecycle (i.e., opening accounts, 

transacting, and repaying); therefore, the 18% of complaints about store credit card complaints 

is in line with these market estimates.37

FIGURE 24: CREDIT CARD COMPLAINTS BY TYPE AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Consumers also identify the issue that best describes the problem they experienced. For credit 

card complaints, options include: advertising and marketing, including promotional offers; 

closing credit card account; fees or interest; getting a credit card; other features, terms, or 

problems; problem when making payments; problem with a credit report or credit score;

problem with a purchase shown on a statement; trouble using card; and, struggling to pay bill. 

In 2018, a problem with a purchase shown on a statement was the most common issue (see 

Figure 25).

 37 See id.

General-purpose credit card or charge card

Store credit card

17,800 (82%)

3,900 (18%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
38 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 25: CREDIT CARD COMPLAINTS BY ISSUES AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Of the approximately 25% of consumers who identified a problem with a purchase shown on a

statement, most discussed an ongoing dispute with their credit card company. Approximately 

92% percent of consumers claimed to have previously contacted the credit card company before 

submitting a complaint (see Section 2, Figure 3). Consumers described difficulties in disputing 

transactions they claimed they did not initiate. Consumers also described difficulties in 

disputing charges of products and services they either did not receive or that did not meet 

expectations. In response to these complaints, credit card companies often explained the 

investigative process for a dispute and explained their decision. In some instances, credit card 

companies reported resolving the dispute in favor of consumers and crediting the amount of the 

disputed transaction. 

Consumers who submitted complaints about fees or interest frequently raised concerns about 

late fees, promotional interest rates, and the computation of interest. Consumers who raised 

concerns about late fees described a number of different situations that resulted in a late fee. For 

example, some consumers described submitting payment on the day payment was due, but the 

credit card company did not credit the payment until the next day. Some consumers reported 

being unable to submit a timely payment because of problems with technology, including 

inaccessible account websites and unsuccessful automatic payments. Some consumers described 

late fees and interest charges on accounts they thought they had closed. In response to these 

complaints, credit card companies often credited the consumer some money—explaining the 

credit was a courtesy.

Problem with a purchase shown

on your statement

Fees or interest

Other features, terms, or problems

Problem when making payments

Getting a credit card

Closing your account

Advertising and marketing,

including promotional offers

Problem with a credit report or

credit score

Trouble using your card

Struggling to pay your bill

5,500 (25%)

3,000 (14%)

3,000 (14%)

2,200 (10%)

2,100 (10%)

1,800 (8%)

1,400 (6%)

1,300 (6%)

900 (4%)

600 (3%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
39 BUREAU OF CONSUMER FINANCIAL PROTECTION

Consumers who identified issues about interest calculations frequently expressed disagreement 

with the interest charged after paying a statement balance in full. These consumers were 

surprised to receive a subsequent account statement with residual interest from their purchases. 

In response, credit card companies stated that they charge interest from the date of the billing 

statement through the date consumers submit payment. Similar to late fees, some credit card 

companies reported providing a statement credit as a courtesy.

Consumers reported issues related to credit card reward programs. Some consumers claimed 

that credit card companies denied reward benefits after they met program requirements. In 

response, credit card companies sometimes asserted that these consumers had not met all of the 

requirements and detailed specific criteria to gain access to benefits. Some consumers claimed 

that credit card companies had not previously disclosed such requirements, or had done so in a 

confusing manner.

Approximately 15% of complaints submitted by older consumers were credit card complaints, 

compared to 8% submitted by consumers under 62 years old (see Section 2, Figure 6).38 Older 

consumers comprised approximately 21% of credit cards complaints and more commonly 

submitted complaints about general-purpose credit cards (see Figure 26). These differences may 

reflect differences in overall rate of ownership of these products by age.

FIGURE 26: OLDER CONSUMER RATE OF CARD COMPLAINT TYPES COMPARED TO PERCENTAGE OF 

CREDIT CARD COMPLAINTS SUBMITTED BY OLDER CONSUMERS

Older consumers were, on average, more likely to submit complaints about problems with 

purchases on statements rather than struggling to pay a bill (see Figure 27). Specifically, 

although older consumers submitted 21% of credit card complaints, they comprised more than 

28% of credit card complaints about problems with purchases shown on a statement, which may 

reflect the targeting of older consumers in fraud and identity theft schemes that result in a 

 38 This difference is consistent with data showing that credit cards make up a proportionally larger share of debt for 

those over age 60. According to data from the Federal Reserve Bank of New York’s Consumer Credit Panel, credit card 

debt makes up 8% of debt for those age 60-79 and 10% of debt for those age 70+, compared with those age 40-49 and 

50-59 where credit cards make up 6% and 7% of outstanding debt, respectively. See Federal Reserve Bank of N.Y., 

Quarterly Report on Household Debt and Credit, 2018:Q3 (Nov. 2018), available at

https://www.newyorkfed.org/medialibrary/interactives/householdcredit/data/xls/hhd_c_report_2018q3.xlsx.

0% 10% 20% 30%

Store credit card

General-purpose credit card or

charge card

Product average for older consumers (21%)
40 BUREAU OF CONSUMER FINANCIAL PROTECTION

greater frequency of disputing charges.39 In contrast, older consumers submitted approximately 

14% of credit card complaints about struggling to pay a bill, which may reflect older consumers’ 

relative financial stability when compared with younger populations.40

FIGURE 27: OLDER CONSUMER ISSUE RATE COMPARED TO PERCENTAGE OF CREDIT CARD 

COMPLAINTS SUBMITTED BY OLDER AMERICANS

4.5 Checking or savings

The Bureau received approximately 25,900 checking or savings complaints in 2018.41 The 

Bureau sent approximately 22,000 (or 85%) of these complaints to companies for review and 

response, referred 10% to other regulatory agencies, and found 4% to be incomplete. At the end 

of 2018, 0.3% of checking or savings complaints were pending with the consumer and 1% were 

pending with the Bureau (see Figure 28A, Routing Outcomes). Of the 10% of checking or savings 

 39 See e.g., Consumer Fin. Prot. Bureau, Monthly Complaint Report Vol. 23 (May 2017) at 16, available at

https://www.consumerfinance.gov/documents/4806/201705_cfpb_Monthly_Complaint_Report.pdf (“Older 

consumers reported difficulties recovering from financial scams. ... Common consequences of scams and identity 

theft—as reported by older consumers—include having to correct credit reports, disputing charges with credit card 

companies, and attempting to have money recovered that was withdrawn from their bank accounts.”).

40 See e.g., Consumer Fin. Prot. Bureau, supra note 21. See also Federal Reserve Bank of N.Y., supra note 38 (people 

aged 60-69 comprise around 3.3% of credit card debts transitioned into serious delinquency (90+ days delinquent) in 

Q3 of 2018, compared with an average of 4.8%.)

41 Financial accounts (i.e., checking or savings accounts) are one of the most widely used products about which the 

Bureau accepts complaints. Nearly ninety percent of households have a financial account. See U.S. Census Bureau, 

Wealth, Asset Ownership, & Debt of Households Detailed Tables: 2014 (Sep. 2018), available at

https://www.census.gov/data/tables/2014/demo/wealth/wealth-asset-ownership.html.

0% 10% 20% 30%

Problem with a credit report or credit score

Struggling to pay your bill

Closing your account

Other features, terms, or problems

Problem when making payments

Advertising and marketing, including promotional

offers

Getting a credit card

Trouble using your card

Fees or interest

Problem with a purchase shown on your statement

Product average for older consumers (21%)
41 BUREAU OF CONSUMER FINANCIAL PROTECTION

complaints referred to other agencies, most were complaints submitted about credit unions and 

other depository institutions with less than $10 billion in assets.

Companies responded to approximately 99% of checking or savings complaints sent to them for 

review and response. Companies closed 66% of complaints with an explanation, 21% with 

monetary relief, and 3% with non-monetary relief. Companies used an administrative response 

for 3% of complaints. At the end of 2018, 6% of complaints were pending review by the 

company. Companies did not provide a timely response for 1% of complaints (see Figure 28B, 

Company Responses).

FIGURE 28: CHECKING OR SAVINGS COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses

The remainder of this analysis focuses only on those checking or savings complaints for which 

the company confirmed a commercial relationship with the consumer and responded with an 

explanation or relief (i.e., complaints closed with explanation, closed with non-monetary relief, 

and closed with monetary relief).

When submitting checking or savings complaints, consumers specify the type of product. 

Options include: checking account, savings account, certificate of deposit (CD), and other 

banking product or service. In 2018, checking account was the most complained about product

type (see Figure 29). Although ownership rates of checking and savings accounts are similar, it is 
42 BUREAU OF CONSUMER FINANCIAL PROTECTION

not surprising that checking accounts are the subject of more complaints as they tend to have a 

greater number of transactions—a frequent issue raised by consumers in complaints.42

FIGURE 29: CHECKING OR SAVINGS COMPLAINTS BY TYPE OF PRODUCT OR SERVICE AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Consumers also identify the issue that best describes the problem they experienced. For 

checking or savings complaints, options include: closing an account; opening an account; 

managing an account; problem caused by funds being low; problem with a lender or other 

company charging your account; and, problem with credit report or credit score. In 2018, 

managing an account was the most common issue (see Figure 30).

 42 Id. According to U.S. Census data, household rates of ownership of regular checking accounts and savings accounts 

are fairly similar, with approximately 67% of households owning a regular checking account compared with 65% for 

savings accounts.

Checking account

Other banking product or

service

Savings account

CD (Certificate of Deposit)

14,700 (74%)

3,200 (16%)

1,300 (7%)

600 (3%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
43 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 30: CHECKING OR SAVINGS COMPLAINTS BY ISSUES AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Of the approximately 63% of consumers who identified managing an account as their primary 

issue, most identified issues regarding depositing and withdrawing funds and using a debit or 

ATM card. Consumers, for example, described difficulties accessing their funds, reported 

financial institutions placing holds on deposits, and stated that the financial institution 

extended the release date of the funds without notice. In response to these complaints, financial 

institutions stated that hold notices help reduce the risk of loss to the financial institution and 

the consumer, and provided details as to why they placed a hold on a consumer’s account.

Unauthorized transactions—occurring online, at merchants, and at ATMs—are a common 

concern raised by consumers. Some consumers described learning of unauthorized transactions 

from proactive account alerts, while others described learning of the transactions after 

overdrawing their account. In response to these concerns, financial institutions detailed a range 

of technology they use to combat unauthorized activity, including two-factor authentication, 

monitoring failed attempts to access accounts, tracking devices used to access accounts, and 

issuing chip-enabled debit cards. In their responses to consumers, financial institutions often 

emphasized the importance of safeguarding account information and timely reporting 

unauthorized or suspicious account activity. In some complaints, financial institutions reported 

reversing previously denied claims and crediting the consumer’s account.

Consumers who submitted complaints about problems caused by funds being low received 

monetary relief at a greater rate than consumers who submitted complaints about other issues 

(see Figure 30). These consumers often identified issues with overdraft fees. Some consumers 

disputed overdraft fees because of the sequencing of the transactions (e.g., deposits not credited 

to the account balance), while others complained that their attempts to deposit money to bring 

their account balance positive still resulted in an overdraft fee. Some consumers expressed 

confusion as to why their account incurred an overdraft fee after they had declined overdraft 

Managing an account

Closing an account

Opening an account

Problem caused by your funds being

low

Problem with a lender or other

company charging your account

Problem with a credit report or credit

score

12,500 (63%)

2,100 (11%)

1,800 (9%)

1,700 (9%)

1,500 (8%)

100 (0.7%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
44 BUREAU OF CONSUMER FINANCIAL PROTECTION

coverage. In response to these complaints, financial institutions frequently referenced 

disclosures and policies provided to the consumer at the time of account opening. As a courtesy, 

financial institutions often credited the fee back to the consumer’s account. 

Approximately 9% of complaints submitted by older consumers were checking or savings 

complaints, compared to 6% submitted by consumers under 62 years old (see Section 2, Figure 

6). Although older consumers comprised approximately 17% of checking or savings complaints, 

they comprised more than 28% of complaints about savings accounts and other banking 

products (see Figure 31). The concentration of older consumers in complaints about CDs was 

particularly pronounced at more than 56%. These differences may reflect differences in overall 

rate of ownership of these products by age.43

FIGURE 31: OLDER CONSUMER RATE OF PRODUCT TYPES COMPARED TO PERCENTAGE OF CHECKING 

OR SAVINGS COMPLAINTS SUBMITTED BY OLDER CONSUMERS

Older consumers tended to raise issues about managing and closing accounts (see Figure 32). 

The majority of these complaints involved issues with deposits and withdrawals from accounts, 

including financial institutions not handling funds in accordance with instructions. Older 

consumers were less likely to complain about overdrafts, associated fees, and problems 

associated with opening an account.

 43 See id. Data from the Survey of Income and Program Participation, a periodic survey of wealth data collected by the 

United States Census Bureau, suggests that 14% of Americans over age 65 own a CD. By contrast, less than 3% of 

those under 35 own a CD. 

0% 10% 20% 30% 40% 50% 60%

Checking account

Savings account

Other banking product or service

CD (Certificate of Deposit)

Product average for older consumers (17%)
45 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 32: OLDER CONSUMER ISSUE RATE COMPARED TO PERCENTAGE OF CHECKING OR SAVINGS 

COMPLAINTS SUBMITTED BY OLDER CONSUMERS

4.6 Student loans

The Bureau received approximately 10,400 student loan complaints in 2018. The Bureau sent 

approximately 9,000 (or 86%) of these complaints to companies for review and response, 

referred 7% to other regulatory agencies, and found 6% to be incomplete. At the end of 2018, 

0.2% of student loan complaints were pending with the consumer and 1% were pending with the 

Bureau (see Figure 33A, Routing Outcomes).

Companies responded to approximately 98% of student loan complaints sent to them for review 

and response. Companies closed 85% of complaints with an explanation, 6% with non-monetary 

relief, and 2% with monetary relief. Companies used an administrative response for 2% of 

complaints. At the end of 2018, 3% of complaints were pending review by the company. 

Companies did not provide a timely response for 2% of complaints (see Figure 33B, Company 

Responses).

0% 10% 20% 30% 40% 50% 60%

Problem caused by your funds being low

Opening an account

Problem with a lender or other company charging your account

Managing an account

Closing an account

Product average for older consumers (17%)
46 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 33: STUDENT LOAN COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses

The remainder of this analysis focuses only on those student loan complaints for which the 

company confirmed a commercial relationship with the consumer and responded with an 

explanation or relief (i.e., complaints closed with explanation, closed with non-monetary relief, 

and closed with monetary relief).

When submitting student loan complaints, consumers specify whether they are complaining 

about a federal student loan or private student loan. In 2018, consumers complained about 

federal student loans more frequently than private student loans (see Figure 34).44

 44 Before consumers submit student loan complaints to the Bureau, the Bureau’s complaint form requires them to 

select the type of student loan. When consumers select federal student loan and an issue related to financial aid 

eligibility or related to receiving money from a federal student loan, the Bureau directs consumers to the Department 

of Education.
47 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 34: STUDENT LOAN COMPLAINTS BY TYPE OF LOAN AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Consumers also identify the issue that best describes the problem they experienced. For student 

loans, options include: dealing with a lender or servicer; getting a loan; problem with a credit or 

consumer report; and, struggling to repay a loan. In 2018, dealing with a lender or servicer was 

the most common issue (see Figure 35).

FIGURE 35: STUDENT LOAN COMPLAINTS BY ISSUES AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

The majority of student borrowers who submitted complaints (approximately 65%) complained 

about problems dealing with a lender or servicer. Most of these borrowers expressed concern 

about the information student loan servicers provided (e.g., information about account details, 

repayment plans, and loan programs).

In their complaints, borrowers often raised issues related to the affordability of their repayment 

options. 45 Federal student loan borrowers typically have several repayment options, including 

plans known as Income Driven Repayment (IDR) that limit payments to a percentage of their 

income. Under these plans, some borrowers could pay as low as $0 per month. The fact that

 45 These complaints are consistent with other research that many borrowers are having difficulty repaying their 

student loans. See Federal Reserve Bank of N.Y., supra note 29 (As of the fourth quarter 2018, more than 11% of the 

total outstanding student loan balances were 90 or more days delinquent—compared with a 3.1% combined 

delinquency rate for mortgages, credit cards, vehicle loans, student loans, home equity lines of credit and other types 

of loans).

Federal student loan

Private student loan

5,300 (64%)

3,000 (36%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief

Dealing with your lender or

servicer

Struggling to repay your loan

Problem with a credit report or

credit score

Getting a loan

5,400 (65%)

2,000 (25%)

700 (8%)

200 (2%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
48 BUREAU OF CONSUMER FINANCIAL PROTECTION

many complaints relate to payment affordability for federal student loans suggests that some

borrowers may not be in the best repayment plan for their circumstances, or that they may not 

understand their available repayment options. Additionally, borrowers with federal student 

loans described delays in processing IDR applications because servicers asked for 

documentation multiple times. These delays, according to borrowers, resulted in interest 

capitalizing on their loans. Borrowers also described paying third parties large sums—

sometimes several hundred dollars—to submit applications on their behalf.

For private student loan borrowers, flexible payment options are, generally, not as readily 

available. In response to private student loan borrowers, servicers explained that private loans 

do not have the same repayment options as federal loans; servicers also stated that any change 

in the original loans terms was at the discretion of the lender. Some servicers offered borrowers 

forbearance, but reminded them that interest will continue to accrue.

Federal student loan borrowers also reported issues with the Public Service Loan Forgiveness

program.46 Many borrowers stated that they made payments on loans that they thought would 

be forgiven; however, after making payments over several years, they learned they were not 

eligible for forgiveness. In response, their servicers often stated that they were not eligible for 

forgiveness because, for example, they did not have the right type of loan, were in the wrong 

type of payment plan, or did not work at a qualifying public employer. Many borrowers who 

were earlier in the payment process, and still had some time before reaching the requisite 120 

payments, stated that their loan servicer did not calculate the number of current payments 

correctly. In response, servicers often reported researching the calculation and updating the 

payment count or explained why certain payments were ineligible.

Both private and federal student loan borrowers identified problems making payments. These 

consumers raised issues with accessing account statements, difficulties cancelling automatic 

payments, and challenges specifying the date and allocation of payments. In response to these 

complaints, servicers responded in a variety of ways. Some servicers reported reversing and 

reapplying payments in accordance with the borrower’s instructions, while others stated that the 

payment allocation was correct.

Borrowers who attended schools that closed before they could graduate expressed concern that 

they would be held liable for their loans and would be unlikely to benefit from the degree they 

had been seeking. In response to these concerns, servicers recommended that the borrower 

contact the school or student loan originator to discuss their options.

 46 The Public Service Loan Forgiveness program forgives the remainder of a borrower’s federal Direct Loan balance 

after the borrower has made 120 qualifying payments (10 years) under a qualifying payment plan while working fulltime for a qualifying public service employer. See 34 CFR § 685.219.
49 BUREAU OF CONSUMER FINANCIAL PROTECTION

4.7 Money transfers, money services, and 

virtual currencies 

The Bureau received approximately 8,100 money transfer, money service, and virtual currency

complaints in 2018. The Bureau sent approximately 5,600 (or 68%) of these complaints to 

companies for review and response, referred 23% to other regulatory agencies, and found 6% to 

be incomplete. At the end of 2018, 1% of money transfer, money service, and virtual currency 

complaints were pending with the consumer and 2% were pending with the Bureau (see Figure 

36A, Routing Outcomes).

Companies responded to approximately 98% of money transfer, money service, and virtual 

currency complaints sent to them for review and response. Companies closed 80% of complaints 

with an explanation, 7% with monetary relief, and 4% with non-monetary relief. Companies 

used an administrative response for 2% of complaints. At the end of 2018, 4% of complaints 

were pending review by the company. Companies did not provide a timely response for 2% of 

complaints (see Figure 36B, Company Responses).

FIGURE 36: MONEY TRANSFER OR SERVICE, AND VIRTUAL CURRENCY COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses

The remainder of this analysis focuses only on those money transfer or service, and virtual 

currency complaints for which the company confirmed a commercial relationship with the 
50 BUREAU OF CONSUMER FINANCIAL PROTECTION

consumer and responded with an explanation or relief (i.e., complaints closed with explanation, 

closed with non-monetary relief, and closed with monetary relief).

When submitting money transfer or service, and virtual currency complaints, consumers specify 

the type of product. Options include: check cashing service; debt settlement; domestic (US)

money transfer; foreign currency exchange; international money transfer; mobile or digital 

wallet; money order; refund anticipation check; traveler's check or cashier's check; and, virtual 

currency. In 2018, domestic (US) money transfers was the most complained about type of 

product (see Figure 37).

FIGURE 37: MONEY TRANSFER OR SERVICE, AND VIRTUAL CURRENCY COMPLAINTS BY TYPE AND 

OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Consumers also identify the issue that best describes the problem they experienced. For 

complaints about money transfers, money services, and virtual currency, options include: 

confusing or misleading advertising and marketing; confusing or missing disclosures; fraud or 

scam; incorrect exchange rate; lost or stolen check; lost or stolen money order; managing, 

opening, or closing your mobile wallet account; money was not available when promised; other 

transaction problem; other service problem; overdraft, savings, or rewards features; problem 

adding money; problem with customer service; unauthorized transactions or other transaction 

Domestic (US) money transfer

Virtual currency

Mobile or digital wallet

International money transfer

Debt settlement

Money order

Traveler's check or cashier's

check

Check cashing service

Foreign currency exchange

Refund anticipation check

1,600 (31%)

1,200 (23%)

1,100 (21%)

820 (16%)

40 (0.9%)

100 (2%)

100 (2%)

90 (2%)

80 (2%)

60 (1%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
51 BUREAU OF CONSUMER FINANCIAL PROTECTION

problem; unexpected or other fees; and, wrong amount charged or received. In 2018, fraud or 

scam was the most common issue (see Figure 38).

FIGURE 38: MONEY TRANSFER OR SERVICE, AND VIRTUAL CURRENCY COMPLAINTS BY ISSUES AND 

OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

More than one-quarter of consumers reported issues related to fraud and scams in their 

complaints about money transfers, money services, and virtual currency. In these complaints, 

consumers often described corresponding with another person for the purchase of goods or 

services. The purported seller then asked the consumers to transfer money. Once the consumer 

transmitted the money, they described losing contact with the seller and being unable to cancel 

their transaction. In response to these complaints, money service businesses explained that 

money transfers are analogous to withdrawing money out of an account—and therefore, there 

Fraud or scam

Other transaction problem

Money was not available when promised

Unauthorized transactions or other transaction

problem

Managing, opening, or closing your mobile

wallet account

Other service problem

Unexpected or other fees

Wrong amount charged or received

Problem with customer service

Confusing or missing disclosures

Confusing or misleading advertising or

marketing

Lost or stolen money order

Lost or stolen check

Problem adding money

Incorrect exchange rate

Overdraft, savings, or rewards features

1,400 (27%)

1,100 (21%)

1,100 (21%)

50 (0.9%)

40 (0.8%)

40 (0.8%)

40 (0.8%)

20 (0.5%)

300 (6%)

300 (6%)

300 (6%)

100 (3%)

100 (2%)

100 (2%)

100 (2%)

4 (0.1%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
52 BUREAU OF CONSUMER FINANCIAL PROTECTION

was no way to reverse the transaction. As a courtesy, however, some money service businesses 

reported crediting their customer’s account for a portion of their loss.

Consumers who used electronic transfer services—provided by a depository institution or by

third-party mobile applications connected to depository accounts—described similar scenarios. 

Although the responses of these companies were generally similar to money service businesses, 

these companies often described additional efforts to prevent the transfer. For example, these 

companies stated they reached out to the consumer via email and text messaging alerts that 

asked the consumer to confirm the transaction. These companies also described automated tools 

that scan transactions for potentially fraudulent or high-risk activities.

Consumers who submitted money transfer complaints also identified a variety of transaction 

problems unrelated to suspected fraud or scams, including money not being available timely, 

money not being available at all, and transactions that were unexpectedly cancelled by the 

company. In response to these complaints, companies sometimes acknowledged that they could 

not complete transactions successfully or that system issues delayed the transaction. Other 

times, companies stated that they would not complete the transaction because there was a 

problem with the recipient of the transfer (e.g., the identification did not match or the transfer 

failed).

Of the consumers who submitted complaints about virtual currency, most identified issues with 

the availability of funds held at virtual currency exchanges during periods of high price volatility 

for the most active virtual currencies. These consumers reported that they were unable to access 

their funds for days and, sometimes, weeks. According to consumers who contacted currency 

exchanges, customer service representatives did not resolve their situation or provide them with 

sufficient information to access their account. Some currency exchanges explained that 

technology and the expansion of systems and teams created a backlog of support tickets that 

resulted in longer than expected processing delays.

4.8 Vehicle loans or lease

The Bureau received approximately 8,100 vehicle loan or lease complaints in 2018.47 The 

Bureau sent approximately 5,900 (or 73%) of these complaints to companies for review and 

response, referred 22% to other regulatory agencies, and found 3% to be incomplete. At the end 

 47 See Federal Reserve Bank of N.Y., supra note 29 (According to Federal Reserve Bank of New York’s data, there 

were more than 113 million outstanding vehicle loans at the end of 2018).
53 BUREAU OF CONSUMER FINANCIAL PROTECTION

of 2018, 1% of vehicle loan or lease complaints were pending with the consumer and 2% were 

pending with the Bureau (see Figure 39A, Routing Outcomes).

Some consumers submit complaints about vehicle dealerships. The Bureau generally does not 

send vehicle loan or lease complaints to vehicle dealerships unless the dealer retains motor 

vehicle installment sales contracts (often known as “buy here, pay here” dealers).

Companies responded to approximately 96% of vehicle loan or lease complaints sent to them for 

review and response. Companies closed 79% of complaints with an explanation, 8% with nonmonetary relief, and 5% with monetary relief. Companies used an administrative response for

1% of complaints. At the end of 2018, 4% of complaints were pending review by the company. 

Companies did not provide a timely response for 4% of complaints (see Figure 39B, Company 

Responses).

FIGURE 39: VEHICLE LOAN OR LEASE COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses

The remainder of this analysis focuses only on those vehicle loan or lease complaints for which 

the company confirmed a commercial relationship with the consumer and responded with an 

explanation or relief (i.e., complaints closed with explanation, closed with non-monetary relief, 

and closed with monetary relief).
54 BUREAU OF CONSUMER FINANCIAL PROTECTION

Consumers who submit vehicle loan or lease complaints specify whether they are complaining 

about a vehicle loan or lease. In 2018, consumers complained about vehicle loans more 

frequently than vehicle leases (see Figure 40).

FIGURE 40: VEHICLE LOAN OR LEASE COMPLAINTS BY TYPE AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Consumers identify the issue that best describes the problem they experienced. For vehicle loan 

or lease complaints, options include: getting a loan or lease; managing the loan or lease; 

problems at the end of the loan or lease; problem with credit report or credit score; and, 

struggling to pay loan. In 2018, managing the loan or lease was the most common issue (see 

Figure 41).

FIGURE 41: VEHICLE LOAN OR LEASE COMPLAINTS BY ISSUES AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Consumers who complain about getting a vehicle loan or lease (approximately 11% of 

complaints) frequently described loan denials. These consumers often disputed the reasons 

lenders provided in these denials, and some stated their credit reports, which lenders relied 

upon, were inaccurate. Lenders frequently replied to these complaints by reiterating reasons for 

the initial loan denial and citing underwriting guidelines. Lenders also asserted that some 

consumers did not submit required application documents. 

Loan

Lease

4,500 (83%)

900 (17%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief

Managing the loan or lease

Struggling to pay your loan

Problems at the end of the loan or

lease

Problem with a credit report or

credit score

Getting a loan or lease

1,900 (35%)

1,000 (19%)

1,000 (19%)

900 (16%)

600 (11%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
55 BUREAU OF CONSUMER FINANCIAL PROTECTION

Other complaints about getting a loan claimed that the loan terms offered were unfair because of 

high interest rates, high payment to income ratios, or repayment totals significantly larger than 

the value of the vehicle. Companies generally responded to these complaints by providing a copy 

of the loan contract or by noting that the consumer agreed to terms outlined in the contract.

For the nearly 35% of consumers who identified issues about managing a loan or lease, 

complaints about billing and repayment were common. Frequently, consumers complained

about problems with automatic payment systems, online payment portals, or changes to

payment dates that resulted in late payments. Companies frequently responded to these 

complaints by providing details of consumers’ repayment behavior, including dates of payments, 

missed payments, customer service interactions, as well as online account usage. Some 

consumers who identified issues about managing the loan or lease complained about other types 

of payment issues, including double payments, failures to refund overpayment, and failures to 

apply payments in accordance with payment instructions. 

Some consumers detailed problems utilizing Guaranteed Auto Protection (GAP) insurance, 

warranties, service plans, and other financing add-ons. These issues frequently arise after an 

accident that results in damage to the vehicle. Consumers raised a number of different issues 

with these products, including not receiving warranty refunds, problems when GAP insurers and 

finance companies delayed payment disbursement, and problems when the loan amount was 

greater than the GAP insurance maximum allowable benefit. 

Approximately 19% of consumers identified problems that occurred at the end of their loan or 

lease. Consumers with leases complained about fees for wear and tear, excess mileage, and other

disposition fees. Consumers with loans complained about difficulty in the final payoff process. 

Sometimes, these consumers complained about outstanding balances despite their attempts to 

make a payoff at the end of the loan term. When consumers remitted a final payment on their 

vehicle loan, they sometimes reported delays in receiving their title and proof of a satisfied lien.

In response to these issues, lenders often provided some form of relief (monetary or nonmonetary) to the consumer.

Vehicle loan and lease issues appeared to be more of a concern for servicemembers than nonservicemembers. Approximately 3% of complaints submitted by servicemembers were vehicle 

loan or lease complaints, compared to 2% submitted by non-servicemembers (see Section 2, 

Figure 5). Within these complaints, servicemembers make up a larger than average percentage 

of complaining consumers for vehicle loans (see Figure 42).
56 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 42: SERVICEMEMBER LOAN COMPLAINT TYPE RATE COMPARED TO PERCENTAGE OF VEHICLE 

LOAN OR LEASE COMPLAINTS SUBMITTED BY SERVICEMEMBERS

Servicemembers also complained about issues at different rates compared with nonservicemembers. For example, servicemembers complained about struggling to pay their loan at 

a higher rate (see Figure 43). Some of these servicemembers described problems when seeking a 

reduced payment, potentially implicating the Servicemembers Civil Relief Act (SCRA), which 

provides specific protections on pre-service debts for servicemembers who are on active duty.48

Managing a loan or lease was also a concern for servicemembers. Many of these issues involved 

problems with fees or interest rates charged by lenders. In their complaints, some 

servicemembers asserted specific protections under the SCRA or otherwise mentioned their 

active duty status. 

FIGURE 43: SERVICEMEMBER ISSUE RATE COMPARED TO PERCENTAGE OF VEHICLE LOAN OR LEASE 

COMPLAINTS SUBMITTED BY SERVICEMEMBERS

4.9 Personal loans

The Bureau received approximately 4,200 personal loan complaints in 2018. The Bureau sent 

approximately 2,700 (or 65%) of these complaints to companies for review and response, 

referred 28% to other regulatory agencies, and found 5% to be incomplete. At the end of 2018, 

 48 See 50 U.S.C. § 3937 (providing for a six percent interest rate cap on debt incurred before military service while a 

borrower is on active duty).

0% 10% 20% 30%

Lease

Loan

Product average for servicemembers (12%)

0% 10% 20% 30%

Problem with a credit report or credit score

Problems at the end of the loan or lease

Getting a loan or lease

Managing the loan or lease

Struggling to pay your loan

Product average for servicemembers (12%)
57 BUREAU OF CONSUMER FINANCIAL PROTECTION

1% of personal loan complaints were pending with the consumer and 2% were pending with the 

Bureau (see Figure 44A, Routing Outcomes).

Companies responded to approximately 95% of personal loan complaints sent to them for 

review and response. Companies closed 75% of complaints with an explanation, 6% with 

monetary relief, and 6% with non-monetary relief. Companies used an administrative response 

for 5% of complaints. At the end of 2018, 4% of complaints were pending review by the 

company. Companies did not provide a timely response for 5% of complaints (see Figure 44B, 

Company Responses).

FIGURE 44: PERSONAL LOAN COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses

The remainder of this analysis focuses only on those personal loan complaints for which the 

company confirmed a commercial relationship with the consumer and responded with an 

explanation or relief (i.e., complaints closed with explanation, closed with non-monetary relief, 

and closed with monetary relief).

When submitting personal loan complaints, consumers specify the type of product. Options 

include: installment loan, personal line of credit, or pawn loan. In 2018, installment loans were

the most complained about type of personal loan product (see Figure 45).
58 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 45: PERSONAL LOAN COMPLAINTS BY TYPE AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Consumers also identify the issue that best describes the problem they experienced. For 

personal loan complaints, options are: can't contact lender or servicer; charged unexpected fee 

or interest; credit limit changed; getting the loan; getting a line of credit; problem with a credit

report or score; problem with additional add-on product or services; problem with cash 

advance; problem with the payoff process at the end of the loan; problem when making 

payments, and struggling to pay loan. In 2018, charged unexpected fees or interest was the most 

common issue (see Figure 46).

FIGURE 46: PERSONAL LOAN COMPLAINTS BY ISSUES AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Installment loan

Personal line of credit

Pawn loan

1,600 (67%)

800 (33%)

10 (0.3%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief

Charged fees or interest you didn't expect

Problem when making payments

Struggling to pay your loan

Getting the loan

Problem with a credit report or credit score

Problem with the payoff process at the end of

the loan

Getting a line of credit

Problem with additional add-on products or

services

Problem with cash advance

Credit limit changed

Can't contact lender or servicer

Other

600 (27%)

500 (19%)

300 (14%)

300 (12%)

20 (0.8%)

20 (0.7%)

200 (9%)

200 (8%)

200 (7%)

100 (4%)

2 (0.1%)

2 (0.1%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
59 BUREAU OF CONSUMER FINANCIAL PROTECTION

Personal loan complaints involve a range of loan products that consumers use for a variety of 

purposes. Some loan products have relatively small principal amounts—often used for 

temporary expenses or budget shortfalls and generally issued by non-bank lenders. Other loan 

products involve larger principal amounts for longer terms and are generally issued by both 

bank and non-bank lenders. Consumers who use these products mention a range of uses for the

funds, such as home improvement and debt consolidation. Personal loan complaints also 

include another group of loans that involve the financing of specific goods, such as solar panels, 

furniture, or other personal property.

The number of issues consumers raised in their complaints mirrors the broad range of these

loan products. For the nearly one in five consumers who identified issues getting a loan or a line 

of credit, credit denials were a common reason that a consumer submitted a complaint. Some 

consumers expressed confusion about denial reasons provided by lenders or receiving a denial 

after responding to a preapproval advertisement. 

After receiving a personal loan, many consumers complained about unexpected fees or interest. 

These consumers expressed a variety of concerns, including higher than expected interest rates, 

and problems with deferred interest and promotional rates. Other consumers identified 

problems during the repayment process, such as the application of individual payments to 

principal versus interest, and payments to balances with differing interest rates.

4.10 Prepaid cards

The Bureau received approximately 2,600 prepaid card complaints in 2018. The Bureau sent 

approximately 1,300 (or 50%) of these complaints to companies for review and response, 

referred 41% to other regulatory agencies, and found 5% to be incomplete. At the end of 2018, 

1% of prepaid card complaints were pending with the consumer and 3% were pending with the 

Bureau (see Figure 47A, Routing Outcomes).

Companies responded to approximately 99% of prepaid card complaints sent to them for review 

and response. Companies closed 68% of complaints with an explanation, 21% with monetary 

relief, and 3% with non-monetary relief. Companies used an administrative response for 2% of 

complaints. At the end of 2018, 5% of complaints were pending review by the company. 

Companies did not provide a timely response for 1% of complaints (see Figure 47B, Company 

Responses).
60 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 47: PREPAID CARD COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses

The remainder of this analysis focuses only on those prepaid card complaints for which the 

company confirmed a commercial relationship with the consumer and responded with an 

explanation or relief (i.e., complaints closed with explanation, closed with non-monetary relief, 

and closed with monetary relief).

When submitting prepaid card complaints, consumers specify the type of product. Options 

include: general-purpose prepaid card; gift card; government benefit card; payroll card; and, 

student prepaid card. In 2018, general-purpose prepaid cards were the most complained about

prepaid product type (see Figure 48).
61 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 48: PREPAID COMPLAINTS BY TYPE OF CARD AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Consumers also identify the issue that best describes the problem they experienced. For prepaid 

card complaints, options include: advertising; problem getting a card or closing an account; 

problem with a purchase or transfer; problem with overdraft; trouble using the card; and, 

unexpected or other fees. In 2018, problem with a purchase or transfer was the most common

issue (see Figure 49).

FIGURE 49: PREPAID COMPLAINTS BY ISSUES AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

For prepaid card customers, a large portion of their complaints involved claims that transactions 

were fraudulent. Many of these complaints involved claims of identity theft or scams. 

Companies generally handled these complaints as unauthorized transactions, which included 

investigating the claims and issuing a replacement card. For a number of these complaints, the 

prepaid card provider approved consumers’ claims and returned money to their customer. This, 

in part, explains the relatively high rate of monetary relief for these complaints. 

General-purpose prepaid card

Government benefit card

Payroll card

Gift card

Student prepaid card

800 (63%)

300 (22%)

10 (0.4%)

100 (9%)

80 (6%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief

Problem with a purchase or transfer

Trouble using the card

Unexpected or other fees

Problem getting a card or closing an account

Advertising

Problem with overdraft

500 (38%)

300 (28%)

200 (17%)

200 (13%)

10 (0.8%)

40 (3%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
62 BUREAU OF CONSUMER FINANCIAL PROTECTION

A number of consumers complained about the inability to access funds—including direct 

deposits—that they loaded onto their prepaid cards. Frequently, consumers claimed to have 

suffered negative consequences because of fund availability issues. Companies pointed to 

technical issues as the source of the problems and sometimes reported providing goodwill 

credits to affected consumers. 

Some consumers, especially consumers with gift cards, complained about fees. These complaints 

frequently involved inactivity fees, card replacement fees, and other fees. Some consumers 

claimed that they were not aware of these fees at the time of purchase.

4.11 Payday loans

The Bureau received approximately 2,300 payday loan complaints in 2018. The Bureau sent 

approximately 1,500 (or 63%) of these complaints to companies for review and response, 

referred 27% to other regulatory agencies, and found 6% to be incomplete. At the end of 2018, 

1% of payday loan complaints were pending with the consumer and 2% were pending with the 

Bureau (see Figure 50A, Routing Outcome).

Companies responded to approximately 94% of payday loan complaints sent to them for review 

and response. Companies closed 79% of complaints with an explanation, 3% with monetary 

relief, and 3% with non-monetary relief. Companies used an administrative response for 6% of 

complaints. At the end of 2018, 3% of complaints were pending review by the company. 

Companies did not provide a timely response for 6% of complaints (see Figure 50B, Company 

Responses).
63 BUREAU OF CONSUMER FINANCIAL PROTECTION

FIGURE 50: PAYDAY LOAN COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses

The remainder of this analysis focuses only on those payday loan complaints for which the 

company confirmed a commercial relationship with the consumer and responded with an 

explanation or relief (i.e., complaints closed with explanation, closed with non-monetary relief, 

and closed with monetary relief).

When submitting payday loan complaints, consumers specify whether they obtained the loan 

online or at a store (in person). In 2018, consumers complained about payday loans obtained 

online more than payday loans obtained at a store (see Figure 51).

FIGURE 51: PAYDAY LOAN COMPLAINTS BY LOAN SOURCE AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Online

In person or at a store

Not stated

800 (62%)

300 (22%)

200 (16%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
64 BUREAU OF CONSUMER FINANCIAL PROTECTION

Consumers also identify the issue that best describes the problem they experienced. For payday 

loan complaints, options include: cannot contact lender or servicer; cannot stop withdrawals 

from bank account; charged unexpected fees or interest; loan payment was not credited to 

account; money was taken from bank account on the wrong day or for the wrong amount;

problem with a credit report or credit score; problem with the payoff process at the end of the 

loan; received a loan consumer did not apply for; struggling to pay loan; and, was approved for a 

loan, but didn't receive the money. In 2018, charged unexpected fees or interest was the most 

common issue (see Figure 52).

FIGURE 52: PAYDAY LOAN COMPLAINTS BY ISSUES AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

More than one-third of consumers identified issues regarding unexpected fees or interest 

charges. Frequently, these consumers claimed that they did not know or understand the interest 

rates that their payday lender charged for their loans. Some of these consumers mentioned state 

laws that they thought created a maximum interest rate. Other consumers expressed confusion 

about the repayment schedule for their loan, and had questions about how the loan would 

amortize without additional payments. 

Some consumers noted that they were having difficulty paying back loans. These consumers 

often mentioned that they took out these loans because of temporary financial difficulties. These 

consumers sometimes also mentioned getting caught in a cycle of lending, which led to using 

new payday loans to repay prior loans. Consumers who reported defaulting on their loans 

Charged fees or interest you didn't expect

Struggling to pay your loan

Problem with the payoff process at the end of

the loan

Received a loan you didn't apply for

Can't stop withdrawals from your bank account

Problem with a credit report or credit score

Can't contact lender or servicer

Money was taken from your bank account on the

wrong day or for the wrong amount

Loan payment wasn't credited to your account

Was approved for a loan, but didn't receive the

money

400 (33%)

300 (27%)

90 (7%)

80 (6%)

70 (6%)

70 (6%)

60 (5%)

50 (4%)

40 (3%)

30 (2%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
65 BUREAU OF CONSUMER FINANCIAL PROTECTION

frequently raised concerns regarding certain collection tactics, such as calls to work, calls to 

home, and threats of legal action.

4.12 Credit repair

The Bureau received approximately 1,000 credit repair complaints in 2018. The Bureau sent 

approximately 360 (or 36%) of these complaints to companies for review and response, referred 

44% to other regulatory agencies, and found 15% to be incomplete. At the end of 2018, 1% of 

credit repair complaints were pending with the consumer and 4% were pending with the Bureau 

(see Figure 53A, Routing Outcomes).

Companies responded to approximately 91% of credit repair complaints sent to them for review 

and response. Companies closed 64% of complaints with an explanation, 11% with monetary 

relief, and 10% with non-monetary relief. Companies used an administrative response for 2% of 

complaints. At the end of 2018, 4% of complaints were pending review by the company. 

Companies did not provide a timely response for 9% of complaints (see Figure 53B, Company 

Responses).

FIGURE 53: CREDIT REPAIR COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses
66 BUREAU OF CONSUMER FINANCIAL PROTECTION

The remainder of this analysis focuses only on those credit repair complaints for which the 

company confirmed a commercial relationship with the consumer and responded with an 

explanation or relief (i.e., complaints closed with explanation, closed with non-monetary relief, 

and closed with monetary relief).

Consumers identify the issue that best describes the problem they experienced. For credit repair 

complaints, options include: confusing or misleading advertising or marketing; confusing or 

missing disclosures; excessive fees; fraud or scam; problem with customer service; and, 

unexpected or other fees. In 2018, fraud or scam was the most common issue (see Figure 54).

FIGURE 54: CREDIT REPAIR COMPLAINTS BY ISSUES AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

The majority of consumers who submit credit repair complaints expressed concern about the 

quality and effectiveness of the services they received. Many of the complaints involved

contracts for ongoing credit repair and consumer reporting services. Consumers stated that they 

experienced difficulty cancelling the contracts with credit repair companies. Credit repair

companies regularly reported providing refunds to consumers under these circumstances. 

4.13 Title loans

The Bureau received approximately 600 title loan complaints in 2018. The Bureau sent 

approximately 410 (or 68%) of these complaints to companies for review and response, referred 

24% to other regulatory agencies, and found 5% to be incomplete. At the end of 2018, 1% of title 

loan complaints were pending with the consumer and 2% were pending with the Bureau (see 

Figure 55A, Routing Outcomes).

Fraud or scam

Problem with customer service

Confusing or misleading advertising or

marketing

Unexpected or other fees

Confusing or missing disclosures

Excessive fees

100 (33%)

80 (24%)

50 (16%)

40 (12%)

30 (10%)

20 (5%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
67 BUREAU OF CONSUMER FINANCIAL PROTECTION

Companies responded to approximately 94% of title loan complaints sent to them for review and 

response. Companies closed 72% of complaints with an explanation, 12% with non-monetary 

relief, and 4% with monetary relief. Companies used an administrative response for 3% of 

complaints. At the end of 2018, 4% of complaints were pending review by the company. 

Companies did not provide a timely response for 6% of complaints (see Figure 55B, Company 

Responses).

FIGURE 55: TITLE LOAN COMPLAINTS BY OUTCOMES

A. Routing Outcomes B. Company Responses

The remainder of this analysis focuses only on those title loan complaints for which the 

company confirmed a commercial relationship with the consumer and responded with an 

explanation or relief (i.e., complaints closed with explanation, closed with non-monetary relief, 

and closed with monetary relief).

When submitting title loan complaints, consumers identify the issue that best describes the 

problem they experienced. For title loans, options include: cannot contact lender or servicer; 

cannot stop withdrawals from bank account; charged unexpected fees or interest; loan payment 

was not credited to account; money was taken from bank account on the wrong day or for the 

wrong amount; problem with a credit or consumer report; problem with the payoff process at 

the end of the loan; received a loan consumer did not apply for; struggling to pay loan; vehicle 

was damaged or destroyed the vehicle; vehicle was repossessed or sold the vehicle; and, was 
68 BUREAU OF CONSUMER FINANCIAL PROTECTION

approved for a loan, but did not receive money. In 2018, charged unexpected fees or interest was 

the most common issue (see Figure 56).

FIGURE 56: TITLE LOAN COMPLAINTS BY ISSUES AND OUTCOMES

Complaints closed with explanation or relief in 2018 Company responses

Nearly one-quarter of the consumers who submitted a title loan complaint identified unexpected 

fees or interest as the primary issue in their complaint. Many of these consumers stated that 

they did not understand the terms—including finance charges, additional fees, and repayment 

schedule—of their title loan. Some consumers explicitly claimed that the title loan company 

misled them about the terms. Companies frequently responded to these complaints by denying 

any wrongdoing and by stating that they provided required disclosures to consumers at the time 

of origination. 

Complaints regularly involved consumers with loans that are in a delinquent status, or at risk of 

default. For consumers with title loans, this sometimes means repossession or voluntary 

surrender of their vehicle to the lender. Consumers sometimes complain about the repossession 

process, including repossessions that they assert are not fair because of the time, place, or 

manner of the repossession. Some consumers also successfully redeem their vehicles after a 

voluntary surrender or repossession. These consumers expressed concerns about the condition 

Charged fees or interest you didn't expect

Struggling to pay your loan

Problem with the payoff process at the end of

the loan

Vehicle was repossessed or sold the vehicle

Can't contact lender or servicer

Vehicle was damaged or destroyed the vehicle

Loan payment wasn't credited to your account

Received a loan you didn't apply for

Was approved for a loan, but didn't receive

money

Money was taken from your bank account on the

wrong day or for the wrong amount

Can't stop withdrawals from your bank account

Problem with a credit report or credit score

80 (24%)

70 (22%)

60 (17%)

50 (15%)

2 (0.6%)

2 (0.6%)

20 (7%)

20 (5%)

10 (4%)

10 (2%)

10 (2%)

4 (1%)

1 square = 1% Closed with explanation Closed with monetary relief Closed with non-monetary relief
69 BUREAU OF CONSUMER FINANCIAL PROTECTION

of their vehicle following redemptions. Consumers who reported successfully repaying their 

loans raised concerns about receiving a satisfaction of lien and a timely return of their title.
70 BUREAU OF CONSUMER FINANCIAL PROTECTION

5. Conclusion

In 2018, Consumer Response continued to enhance its capabilities to analyze consumer 

complaints, company responses, and consumer feedback by developing additional internal tools 

and technologies. These help the Bureau understand trends over time, relationships between 

sets of complaints, and geographic variations. Spikes in complaints trigger near-real-time alerts, 

prompting additional analysis. 

These tools support the work of Consumer Response to assess the accuracy, completeness, and 

timeliness of company responses, and ensure that the Bureau and other regulators have useful 

information about consumer complaints concerning financial products and services. Complaints 

help the Bureau in its work to regulate consumer financial products and services under existing 

federal consumer financial laws, enforce those laws judiciously, and educate and empower 

consumers to make better-informed financial decisions to reach their own life goals.
71 BUREAU OF CONSUMER FINANCIAL PROTECTION

Appendix

TABLE 5: TOTAL COMPLAINTS BY STATE AND PRODUCT IN 2018 Checking or savings Credit card Credit or consumer reporting Credit repair Debt collection

Money transfer or service, virtual currencyMortgagePayday loanPersonal loanPrepaid cardStudent loanTitle loan

Alabama 198 259 1,755 16 1,048 53 293 43 86 35 135 9 

Alaska 24 36 119 0 111 16 38 1 5 2 18 0 

American 

Samoa 0 0 1 0 0 2 0 0 0 0 0 0 

Arizona 515 545 2,306 22 1,988 155 569 39 85 53 227 35 

Arkansas 104 127 860 6 572 34 118 9 24 20 61 4 

California 3,656 4,193 15,355 133 9,403 1,218 4,339 238 547 394 1,103 92 

Colorado 370 510 1,440 21 1,126 147 503 29 57 44 226 5 

Connecticut 378 402 816 10 645 101 418 15 31 25 135 5 

Delaware 111 168 491 3 286 22 152 15 31 12 37 0 

District of 

Columbia 163 168 548 5 352 49 122 8 12 16 97 2 
72 BUREAU OF CONSUMER FINANCIAL PROTECTION Checking or savings Credit card Credit or consumer reporting

Credit repairDebt collectionMoney transfer or service, virtual currencyMortgagePayday loanPersonal loanPrepaid cardStudent loanTitle loan

Federated 

States of 

Micronesia

11 10 28 0 34 2 4 0 1 0 0 0 

Florida 2,392 2,492 14,240 73 8,171 634 2,983 163 312 176 707 35 

Georgia 1,086 998 9,221 51 4,489 300 1,406 78 176 113 423 31 

Guam 1 4 22 0 4 4 2 0 2 0 1 0 

Hawaii 63 97 425 6 186 27 91 9 8 6 24 0 

Idaho 56 90 219 1 234 26 80 8 15 13 64 2 

Illinois 1,066 1,014 6,329 22 3,014 286 952 63 143 105 376 21 

Indiana 235 305 1,300 7 1,061 75 311 67 57 35 165 11 

Iowa 72 117 297 17 389 42 116 11 23 17 60 5 

Kansas 108 125 457 8 500 33 103 24 30 21 63 4 

Kentucky 127 165 743 7 680 52 158 21 29 31 111 5 

Louisiana 239 234 2,196 28 1,392 104 402 49 89 35 103 21 

Maine 49 99 134 4 203 15 80 6 8 12 41 0 

Marshall 

Islands 0 0 0 0 0 0 0 0 0 1 0 0 

Maryland 620 651 2,645 33 1,793 176 958 89 103 56 281 18 

Massachusetts 513 667 1,377 20 1,041 167 705 32 49 36 242 3 

Michigan 503 647 2,675 32 1,978 161 515 53 75 46 305 11 

Minnesota 278 366 814 7 647 84 286 29 47 36 176 3 

Mississippi 83 122 1,267 7 538 28 143 12 46 15 98 8 

Missouri 284 369 2,143 20 1,388 91 382 36 85 32 166 5 
73 BUREAU OF CONSUMER FINANCIAL PROTECTION Checking or savings Credit card Credit or consumer reporting

Credit repairDebt collectionMoney transfer or service, virtual currencyMortgagePayday loanPersonal loanPrepaid cardStudent loanTitle loan

Montana 38 48 137 4 159 17 49 9 8 3 22 1 

Nebraska 64 98 194 8 201 27 76 17 17 12 37 0 

Nevada 370 372 1,667 17 1,106 103 351 38 47 38 89 4 

New 

Hampshire 63 103 205 4 198 25 135 4 10 3 66 2 

New Jersey 1,003 1,098 3,940 24 2,458 267 1,422 88 102 74 285 13 

New Mexico 80 98 417 2 328 27 118 5 24 11 28 1 

New York 2,168 2,467 7,721 66 4,268 586 1,919 31 154 157 683 17 

North Carolina 603 722 5,475 27 2,416 166 827 65 107 64 258 13 

North Dakota 9 27 89 2 117 9 18 4 2 1 21 0 

Northern 

Mariana Islands 0 0 0 0 1 0 0 1 0 0 0 0 

Ohio 778 952 3,300 27 2,517 210 668 145 131 71 400 29 

Oklahoma 140 189 609 2 665 48 174 29 40 27 79 2 

Oregon 218 323 623 12 680 78 300 22 43 27 129 5 

Pennsylvania 965 993 4,115 34 2,552 226 1,056 75 130 85 517 23 

Puerto Rico 47 87 269 7 135 8 130 0 12 6 25 0 

Rhode Island 90 102 234 5 194 10 98 7 9 11 34 0 

South Carolina 215 307 2,862 9 1,444 79 405 58 115 32 163 15 

South Dakota 31 25 66 1 111 4 25 4 6 6 16 0 

Tennessee 340 355 2,470 16 1,499 97 533 59 114 40 161 11 

Texas 1,760 2,012 12,323 77 9,817 519 1,946 239 326 172 679 48 
74 BUREAU OF CONSUMER FINANCIAL PROTECTION Checking or savings Credit card Credit or consumer reporting

Credit repairDebt collectionMoney transfer or service, virtual currencyMortgagePayday loanPersonal loanPrepaid cardStudent loanTitle loan

United States 

Minor Outlying 

Islands

2 6 6 0 14 0 10 1 0 0 1 0 

U.S. Armed 

Forces –

Americas

3 0 3 0 0 0 2 0 0 1 1 0 

U.S. Armed 

Forces –

Europe

4 11 46 0 19 7 7 1 2 0 7 0 

U.S. Armed 

Forces –

Middle East

2 2 0 0 1 0 1 0 0 0 0 0 

U.S. Armed 

Forces –

Pacific

4 6 40 0 27 4 4 0 0 0 1 0 

Utah 114 157 1,038 8 577 45 154 20 25 16 50 1 

Vermont 28 41 61 0 37 7 42 3 8 4 19 0 

Virgin Islands 2 4 5 0 6 1 9 0 0 0 1 0 

Virginia 660 800 2,536 29 2,097 228 879 84 162 68 331 13 

Washington 448 570 1,496 15 1,236 200 644 45 77 45 259 7 

West Virginia 55 75 204 3 192 20 51 2 12 15 42 3 

Wisconsin 278 339 1,041 11 830 74 277 29 53 30 136 4 

Wyoming 23 31 41 1 82 9 43 3 2 7 14 0 

Unspecified 1,950 1,255 2,794 47 2,255 935 1,489 88 268 185 379 26 

Total49 25,860 28,655 126,250 1,017 81,512 8,140 30,091 2,323 4,182 2,598 10,378 573 

 49 Total column includes approximately 100 complaints where no specific consumer financial product was selected by consumers.