CFPB Publishes Report Analyzing Complaint Filing Patterns by Demographic Characteristics | Ballard Spahr srl



The CFPB has published his first in-depth report analyze complaint submission patterns throughout the credit life cycle, by demographic characteristics.

The results are based on approximately 1 million consumer complaints that were submitted to the CFPB between 2018 and 2020. To prepare the report, the CFPB matched the address information of the complaints to the census tracts. Credit lifecycle categories used for Bureau findings are loan origination, performing loan servicing (productive service), overdue and distressed service and collections (overdue service), and credit reports. .

The main conclusions are as follows:

  • Census tracts with the highest proportion of Black or African American residents submit the most complaints per resident.
  • Low-income census tracts and census tracts with a higher proportion of minority residents submit more complaints about credit reports, overdue services and identity theft.
  • For relatively high-income communities, complaints about setups and service delivery are relatively more common, and complaints about overdue credit reports and services are relatively less common.
  • Census tracts with the highest share of non-Hispanic white residents submit complaints about loan origination more than twice that of census tracts with the highest share of black or African American residents .
  • Low-income census tracts (those at or below 40% of their region’s median income) submit about 30% more complaints per capita than census tracts at about 100% of their region’s median income.

Based on these findings, the CFPB makes the following findings:

  • Consumers in low-income communities and higher shares of Black or African American residents and Hispanic or Latino residents are making complaints about past financial issues and identity theft victimization. In contrast, communities with higher incomes and a greater proportion of non-Hispanic white residents tend to lodge complaints about current issues they face with lenders and service providers.
  • The different experiences of these communities suggest that structural differences in access to credit are important in determining what types of complaints CFPB receives. Complaints about loan origination by non-Hispanic white consumers at more than twice the rate of black or African American consumers likely reflects differences in access to credit, with differences in mortgage complaints playing a role. disproportionate.
  • Past barriers limiting access to regular credit for racial minorities, the long-term impact of the 2008 mortgage crisis, and continuing inequality of access continue to shape the opportunities available to consumers.
  • Of particular concern is the growing gap between communities with higher white, non-Hispanic populations and / or higher incomes and communities with higher minority populations and / or lower incomes. This suggests that new loans, especially mortgages and mortgage refinances, may be disproportionately available to consumers in communities with higher incomes and a greater proportion of non-Hispanic white residents.


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