On October 25, 2016, the Consumer Financial Protection Bureau (CFPB) released its monthly complaint report.  For the month of September 2016, the products and services receiving the most complaints were debt collection, credit reporting, and mortgages.  These three topics collectively represented almost two-thirds of the complaints submitted.  Notably, debt collection complaints declined by 24 percent and credit reporting complaints declined by 5 percent compared to the August 2016 figures.  In addition, comparing data from the period July-September 2016 with data from July-September 2015, complaints related to payday loans fell 21 percent while complaints related to student loans increased by 96 percent.

The report focused on complaints about prepaid accounts, highlighting three issues in particular: unauthorized transactions; lack of access to funds; and unexpected fees.

 

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Regarding these issues, the CFPB reported the following specifics about prepaid account complaints:

  • Unauthorized transactions: Consumers complained of unauthorized transactions on their accounts and described having to contact providers repeatedly before they took action. In some cases, consumers reported having prepaid cards cancelled with no explanation.
  • Lack of Access to Funds: Consumers complained of declined transactions that providers attributed to improper product registration. To resolve this issue, companies sometimes required that consumers provide proof of purchase in the form of receipts and the original packaging of the product.
  • Unexpected Fees: Consumers also reported receiving refunds in the form of prepaid cards that they were unable to activate. Consumers reported that providers charged dormancy fees, adding to their financial hardship.

The Bureau’s focus on prepaid account complaints complements its issuance of its final prepaid accounts rule on October 5, 2016.  The final prepaid accounts rule requires that providers of prepaid products, such as prepaid cards and mobile wallets, provide consumers with certain disclosures and account protections by October 1, 2017.

Photo of David Stein David Stein

David Stein advises clients on credit reporting, financial privacy, financial technology, payments, retail financial services, and fair lending issues. He assists a broad range of financial services firms, consumer reporting agencies, financial technology companies, and their vendors with regulatory, compliance, supervision, enforcement, and…

David Stein advises clients on credit reporting, financial privacy, financial technology, payments, retail financial services, and fair lending issues. He assists a broad range of financial services firms, consumer reporting agencies, financial technology companies, and their vendors with regulatory, compliance, supervision, enforcement, and transactional matters.

Mr. Stein has significant experience advising clients on compliance with the FCRA, GLBA, ECOA, EFTA, E-Sign Act, TILA, TISA, FDCPA, Dodd-Frank Wall Street Reform and Consumer Protection Act, and FTC Act, as well as state financial privacy laws. Mr. Stein is a member of the firm’s fintech and artificial intelligence initiatives and works with clients on issues related to cutting edge technologies, such as blockchain, virtual currencies, big data and data analytics, artificial intelligence, online lending, and payments technology.

Mr. Stein previously served in senior regulatory, policy-making, and management positions at the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (FRB). He played a significant role in developing regulations and policy on credit reporting, financial privacy, retail payments systems, consumer credit, fair lending, overdraft services, debit interchange, unfair or deceptive acts or practices, and mortgage origination and servicing. Mr. Stein draws upon his government experience in representing clients before the CFPB, the FRB, and other regulatory agencies and leverages his insights into the regulatory process to provide clients with practical, actionable advice.