Pamela Foohey Article on Complaints to the CFPB

Pamela Foohey of Indiana has written Calling on the CFPB for Help: Telling Stories and Consumer Protection, 80 Law & Contemporary Problems (Forthcoming). Here is the abstract:

Since it began operating in 2011, the Consumer Financial Protection Bureau (CFPB) has handled more than a million complaints regarding consumer financial product and services. Beginning in June 2015, the CFPB began publishing consumers’ narratives submitted with their complaints. This Article analyses a random sample of 5,000 of these narratives to assess how people engage with the complaint mechanism in light of the CFPB’s role in processing complaints. I find that people predominately use the complaint function for two distinct purposes: to express their anger and frustration about companies’ practices, or to express sadness and fear about how companies’ practices have impacted their lives. When people write with anger and frustration, they typically direct their comments to the subject company, which aligns with the CFPB’s role in processing complaints. In contrast, when people write with sadness and fear, they often plead with the CFPB for individualized help in solving their broader problems. But the CFPB is not equipped to help people on an individual basis and such is not the goal of its complaint mechanism. Identifying that some consumers seem to expect the CFPB to provide this type of assistance presents an opportunity for the CFPB to address the serious problems that these consumers are voicing and to enhance how it utilizes the complaint data to further its goal of consumer protection. However, the CFPB is but one government agency that allows people to write narratives describing their problems. This Article thus provides suggestions for how agencies generally may mine their narrative databases to help people in need and to advance their missions.

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