This content was published prior to the combination of Dentons Sirote. Learn more about Dentons Sirote. 

In April, the CFPB received a record number of complaints about lenders—42,774 to be exact. According to CFPB Director Kraninger, the Bureau received more complaints from consumers in April than in any month since the Bureau first began to take complaints in December of 2011.  Most of the complaints centered around mortgages and credit cards, as consumers are having a hard time understanding just how the federal COVID-19 pandemic intervention efforts work—or don’t work.

The CFPB was created under the Dodd-Frank Wall Street Reform and Consumer Protection Act in part to protect consumers from unfair, deceptive and abusive credit practices.  While everything about COVID-19 may be unfair, deceptive and abusive, there is little that the CFPB can do to ameliorate its direct effects. 

However, the CFPB can and will act as a watch dog over creditors, keeping an eye out for unfair, deceptive or abusive acts and practices during the pandemic.  And, complaints are the first indicator of problems.

We are fond of saying that complaints are the “canary in the coal mine.” I have written and spoken about complaints many times in recent years.  See our October 24, 2018 blog by clicking here.

Similarity of complaints is a sign that a company is more than likely doing something wrong. It makes sense that a company should track its complaints, and document in a general fashion how it responds. While this may not be required by state or federal law, this seems to be a “best practice” that will help reduce the kinds of conduct leading to the activities drawing the complaints.

Practice Pointer:  If you don’t have a Complaint Policy, you are asking for trouble.

Please Note: This is the one hundred ninth blog in a series of Back to Basics blogs, in which relevant and resourceful information can be easily accessed by clicking here.