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www.acainternational.org Consumer
Complaints
www.acainternational.org
March 6, 2014
cfpb
Research
© 2014 ACA International. All Rights Reserved.
TAKING A CLOSER LOOK: Analysis of the Consumer Financial Protection Bureau´s Debt Collection Complaints
1
Table of Contents:
I. Executive Summary ....................................................................................................... 2 Introduction ............................................................................................................................ 2 Key Findings........................................................................................................................... 2 Concerns with CFPB’s Complaint Database ........................................................................... 3 Recommendations to the CFPB and Others Regarding Complaints ....................................... 3
II. Overview ........................................................................................................................ 4
The purpose of the Report – Analyzing CFPB Consumer Complaint Data .............................. 4 ACA Members and Complaints............................................................................................... 4 ACA and the CFPB................................................................................................................. 4 The Recovery of Consumer Debt is Vital to Federal, State and Local Economies .................. 4
III. Data Analysis ............................................................................................................. 5
Proportion of Consumers with Collection and Average Collection Amount per Person ........... 5 Amount of Consumer Complaints Received by Month ............................................................ 5 Number of Complaints by Sub-Products ................................................................................. 6 Percentage of Complaints Coming from Third-Party and Creditors ......................................... 6 Number of Complaints by Key Issues ..................................................................................... 7 Breakdown of Issues by Sub-Group ....................................................................................... 7 Allocation of Issues by Sub-Group .......................................................................................... 8 Complaints Received in a Timely Fashion .............................................................................. 8 Outcome of the Progress Status of Companies Complaints ................................................... 9 Complaints by Submitted Channel .......................................................................................... 9 Number of Complaints by State in Comparison to the Total Debt Collected in 2010 ..............10 Top 50 Companies Receiving Complaints .............................................................................11
IV. ACA Recommendations/ Conclusion ......................................................................11
About ACA International (www.acainternational.org) With offices in Washington, D.C. and Minneapolis, ACA International is the largest trade association
representing the consumer credit and debt collection industry. Our nearly 5,000 member organizations
employ more than 300,000 men and women as third-party debt collectors, debt buyers, collection attorneys,
creditors and industry service providers. ACA has 41 state-level units representing the 50 states and one unit
representing more than 60 countries abroad. The recovery of consumer debt is very important to America´s
credit-based economy and, according to an economic impact study by Ernst & Young, third-party collection
agencies recovered $55 billion on behalf of creditor clients in 2010.
© 2014 ACA International. All Rights Reserved.
TAKING A CLOSER LOOK: Analysis of the Consumer Financial Protection Bureau´s Debt Collection Complaints
2
I. Executive Summary
Introduction
ACA International’s Research Department created the following analysis of the Consumer Financial
Protection Bureau’s (CFPB) complaint database for debt collection. We undertook this study to gain
insight into consumer complaint issues and, in particular, to learn more about the information and to
use it for the collection of debts. Our goals with this analysis are to improve communication between
debt collectors and customers, and to mitigate the number of complaints made by customers.
This report is based on a sample of 14,328 complaints received by the CFPB between July 2013 and
February 2014. In addition, this report uses data from the Quarterly Report on Household Debt and
Credit from the Federal Reserve Bank of New York to show the average balance of accounts in third-
party debt collections (Q1 2003-Q4 2013).
Since the 1980s, the use of consumer credit rose steadily reaching its peak in 2008, when the
United States economy entered into the biggest economic downturn since the Great Depression.
Consumer spending habits created massive growth in the level of delinquent/defaulted debts owed
to businesses and government. This includes both discretionary and non-discretionary spending.
America’s credit-based economy relies on the recovery of rightfully owed consumer debt. As the
nation’s economy faltered, it triggered wide-spread efforts by public and private sector creditors,
third-party debt collectors working on behalf of creditor clients, and companies that have purchased
written-off consumer debts to seek to recoup what was possible. Without these efforts, companies
can’t pay their bills and keep people employed; the price for goods and services increases; the
availability of affordable credit decreases; and governments are forced to cut services and/or raise
taxes to cover shortfalls.
A heavier reliance on credit coupled with economic turmoil has resulted in more than one billion
consumer contacts per year. Conversely, complaints by consumers contacted about a delinquent or
defaulted debt also increased. Consumers don’t want to be told they owe money and it often
produces an emotionally charged response when contacted.
ACA International members take complaints against debt collectors very seriously and have pledged
to work with key stakeholders including the CFPB, Federal Trade Commission (FTC), Better Business
Bureau, state lawmakers, state regulators and state attorneys general to best balance consumer
protections and the ability to recovery a rightfully owed debt.
Key Findings
The CFPB makes publicly available data that includes company name, consumer ZIP code, product,
sub–product, issue, complaint submission date, and response timeliness. Comparison of key
findings from ACA’s previous report on CFPB complaints in November 2013 finds little to no changes
among general trends in February 2014.
In addition, ACA supplemented analysis of the CFPB’s data with the Quarterly Report on Household
Debt and Credit of the Federal Reserve Bank of New York to provide a snapshot of the average
balance of accounts in third-party debt collection:
The average balance of accounts in third-party debt collection increased from $1,458 in the third
quarter of 2013 to $1,520 in the fourth quarter of 2013, representing a 4.29% increase.
The highest number of identifiable complaints was for credit card and medical debts. However,
taking into account the category “others” and “not specified” together, 50.41% of the complaints
were not associated with a particular debt collection product.
© 2014 ACA International. All Rights Reserved.
TAKING A CLOSER LOOK: Analysis of the Consumer Financial Protection Bureau´s Debt Collection Complaints
3
The most reported consumer concern was being contacted about “a debt they did not believe
they owed.” In second place was “communication tactics” followed by “disclosure verification of
a debt.” However, there is no subsequent follow-up on whether these consumer concerns were
resolved after communications with creditors or debt collectors. Further, a closer look at the
“communications tactics” sub-section identifies the most frequent concern was the frequency of
calls. It should be noted that a “catch-22” under the Fair Debt Collections Practices Act (FDCPA)
is prompting an increasing number of debt collectors to not leave voicemail and instead make
more calls to consumers in the hope of reaching a live person.
Almost all the complaints received by the CFPB were responded to in a timely fashion. Based on
the data, 96% of the complaints were responded to with a timely response.
Of the 14,328 complaints analyzed, 94% were “closed,” “closed with non-monetary relief” or
“closed with explanation.”
Concerns with CFPB’s Complaint Database
There is a lack of clarity in the data as to whether complaints are against first-party creditors,
payday lenders, third-party debt collection companies or others. Aggregating these creates
uncertainty about complaints possibly reported more than once, painting an inaccurate portrait
of third-party debt collectors.
The limited amount of information provided about consumers to debt collectors in the CFPB
complaint process makes accurate identification and timely response difficult.
The CFPB’s description of a complaint, coupled with the fact that it does not investigate whether
any real wrongdoing has occurred or whether it is an inquiry/request for additional information,
enables the data to create an inaccurate perception of the extent of wrongful conduct.
Due to the 60-day lag time from company response to consumer dispute of the company
response, coupled with a lack of completeness in the database, an accurate assessment on the
number of disputes cannot be made at this time.
Recommendations to the CFPB and Others Regarding Complaints
Clearly identify first-party collections from third-party collections to ensure accuracy in complaint
reporting and avoid the potential for double counting.
Maintain context by resisting the temptation to use a broad-brush to paint debt collectors
negatively or make assumptions about the behavior of an entire industry solely on top line
volume data.
Provide more consumer detail to debt collectors who are the subject of a complaint to increase
the likelihood of more easily identifying the information needed to resolve the consumer’s
complaint.
Adopt definition of a complaint that is limited to consumer allegations of wrongful conduct and
does not include the amorphous concept of general consumer dissatisfaction outside of wrongful
conduct.
© 2014 ACA International. All Rights Reserved.
TAKING A CLOSER LOOK: Analysis of the Consumer Financial Protection Bureau´s Debt Collection Complaints
4
II. Overview
The purpose of the Report – Analyzing CFPB Consumer Complaint Data
In 2010, the U.S. Congress passed the Dodd-Frank Act that created the CFPB. Among its many
responsibilities, the CFPB supervises the third-party debt collection industry and maintains a
database of complaints against debt collectors.
In July 2013, the CFPB officially began accepting consumer complaints pertaining to debt collection
whereby consumers may register a complaint and have it reviewed/resolved through
communications with a debt collector.
ACA International’s Research Department has analyzed a total of 14,328 debt collection complaints
released by the CFPB, dating from July 2013 to February 2014. Comparison of key findings from
ACA’s previous report on CFPB complaints in November 2013 finds little to no changes in February
2014. The purpose of this analysis is to better understand the data beyond simply reviewing the total
number of complaints.
ACA Members and Complaints
Third-party consumer debt collectors make approximately one billion contacts to consumers per year.
ACA members are aware of consumer complaints and want to work seriously with the consumers to
resolve their concerns. ACA’s Code of Ethics requires each ACA member company to identify a
specific contact designated to work with consumers to address complaints against a third-party debt
collector. ACA is committed to helping members better understand and comply with federal, state
and local laws governing the collection of consumer debt. Moreover, we provide exceptional training
to help members prevent complaints from occurring and to meaningfully resolve them if they do.
ACA members realize that consumers most often prefer to share complaints with intermediaries
such as the CFPB. However, we welcome the opportunity to work directly with consumers to resolve
complaints. Communication is the cornerstone for effective consumer debt collection and, when
given the opportunity, ACA members continue to show they can be successful in appropriately
resolving consumer complaints. According to the Better Business Bureau, in 2012, collection
agencies resolved 86% of the consumer complaints received compared to the national average of
77% for all other industries combined.
ACA and the CFPB
ACA has sought a mutually respectful and collaborative relationship with the CFPB. ACA efforts have
included, but are not limited to, the following:
Educating CFPB leaders on the complexity of the debt collection industry.
Monitoring the CFPB’s actions and responding as appropriate on behalf of ACA members.
Inviting CFPB leaders to speak at our conferences and interact with industry members.
Participating in industry relevant hearings, work groups and panels.
Preparing ACA Members for supervision, rulemaking, enforcement and complaint resolution.
© 2014 ACA International. All Rights Reserved.
TAKING A CLOSER LOOK: Analysis of the Consumer Financial Protection Bureau´s Debt Collection Complaints
5
The Recovery of Consumer Debt is Vital to Federal, State and Local Economies
America’s credit-based economy relies on the recovery of rightfully owed consumer debt. As the
nation’s economy faltered, it triggered wide-spread efforts by public and private sector creditors,
third-party debt collectors working on behalf of creditor clients, and companies that have purchased
written-off consumer debts to seek to recoup what was possible. Without these efforts, companies
can’t pay their bills and keep people employed; the price for goods and services increases; the
availability of affordable credit decreases; and governments are forced to cut services and/or raise
taxes to cover shortfalls.
ACA regularly conducts research to assess the actual impact third-party debt collection has on the
national and state economies. Our most recent data, conducted by Ernst & Young in 2011, can be
found at www.acainternational.org/impact.
III. Data Analysis This section provides an analysis of the data gleaned from the 14,328 consumer complaints
pertaining to debt collection that have been submitted to the CFPB between July 2013 and February
2014. Additionally, we have used the available data from the Quarterly Report on Household Debt
and Credit provided by the Federal Reserve Bank of New York.
Proportion of Consumers with Collection and Average Collection Amount per Person
The graph below shows the proportion of consumers with collection at a national level between 2003
and 2013, represented in the blue line and read from the left axis. The purple line is read from the
right axis and represents the Average Collection Amount per Person.
The proportion of consumers in collection has increased over the past 10 years, remaining at a
relatively constant rate of 14% over the past four years. The average collection amount per person
increased 4.29% from $ 1,458 in the third quarter of 2013 to $ 1,520 in the fourth quarter of 2013.
1,520.29
$800
$900
$1,000
$1,100
$1,200
$1,300
$1,400
$1,500
$1,600
8%
9%
10%
11%
12%
13%
14%
15%
03
:Q1
03
:Q3
04
:Q1
04
:Q3
05
:Q1
05
:Q3
06
:Q1
06
:Q3
07
:Q1
07
:Q3
08
:Q1
08
:Q3
09
:Q1
09
:Q3
10
:Q1
10
:Q3
11
:Q1
11
:Q3
12
:Q1
12
:Q3
13
:Q1
13
:Q3
Proportion of Consumers with Collection (left axis)
Average Collection Amount per Person(right axis)
Data Source: Federal Reserve Bank New York
© 2014 ACA International. All Rights Reserved.
TAKING A CLOSER LOOK: Analysis of the Consumer Financial Protection Bureau´s Debt Collection Complaints
6
Amount of Consumer Complaints Received by Month Based on the data below, consumer complaints per month are trending upward. The increase from
September 2013 of 2,010 complaints to December 2013 of 2,415 complaints represents an
increase of 20.15%. The number of complaints in January 2014 did increase to 2,886. Data for
February only reflects complaints through 17 days of the month.
Number of Complaints by Sub-Products Taking a closer look at the sub-products, the highest number of identifiable complaints was for credit
cards with 3,313, followed by medical products with 1,381 complaints. A total of 4,191 complaints
were not directly associated with a certain debt collection product (e.g., phone, health club, etc.) and
3,032 complaints were not specified.
Percentage of Complaints Coming from Third-Party and Creditors ACA reviewed the list of companies and was able to identify the number of companies that were not
third party-debt collectors, including a number of financial institutions and banks. Of the total of
14,328 complaints, approximately 2,822 or 20% were made against companies conducting first-
party collections (credit card companies, pay day lenders, or other direct creditors).
861
1466
2010 1790
2436 2415
2886
464
0
500
1000
1500
2000
2500
3000
3500
Jul-13 Aug-13 Sep-13 Oct-13 Nov-13 Dec-13 Jan-14 Feb-14
4191
3313 3032
1381
625 558 457 410 361
0
500
1000
1500
2000
2500
3000
3500
4000
4500
Other(phone,
health club,etc.)
Credit card Notspecified
Medical Mortgage Payday loan Auto Non-federalstudent loan
Federalstudent loan
20%
80%
First Party/ Others Third Party
© 2014 ACA International. All Rights Reserved.
TAKING A CLOSER LOOK: Analysis of the Consumer Financial Protection Bureau´s Debt Collection Complaints
7
Number of Complaints by Key Issues A total of 5,764 complaints pertained to “a debt the consumers believe they did not owe.”
“Communications tactics” followed at 2,911. The third most reported complaint is “disclosure
verifications” of a debt totaling 2,497. However, there is no follow-up data on how many of these
complaints were eventually proven to be accurate by the debt collectors in question.
Breakdown of Issues by Sub-Group Analysis of the key sub-groups provides a deeper look at complaints.
5764
2911 2497
1168 1083 905
0
1000
2000
3000
4000
5000
6000
7000
Cont'd attemptscollect debt not
owed
Communicationtactics
Disclosureverification of debt
Improper contactor sharing of info
False statementsor representation
Taking/threateningan illegal action
264
353
1572
3575
0 500 1000 1500 2000 2500 3000 3500 4000
Debt was discharged in bankruptcy
Debt resulted from identity theft
Debt was paid
Debt is not mine
Cont'd attempts collect debt not owed
121
196
242
482
1870
0 500 1000 1500 2000
Called outside of 8am-9pm
Used obscene/profane/abusivelanguage
Called after sent written cease ofcomm
Threatened to take legal action
Frequent or repeated calls
Communications tactics
148
573
1776
0 500 1000 1500 2000
Not disclosed as an attempt to collect
Right to dispute notice not received
Not given enough info to verify debt
Disclosure verification of debt
32
259
321
556
0 100 200 300 400 500 600
Contacted me instead of my attorney
Contacted employer after asked notto
Contacted me after I asked not to
Talked to a third party about my debt
Improper contact or sharing of info
24
79
120
860
0 200 400 600 800 1000
Indicated shouldn't respond to lawsuit
Indicated committed crime not paying
Impersonated an attorney or official
Attempted to collect wrong amount
False statements or representation
26
106
121
144
230
278
0 50 100 150 200 250 300
Sued where didn't live/sign for debt
Attempted to/Collected exempt funds
Seized/Attempted to seize property
Sued w/o proper notification of suit
Threatened to sue on too old debt
Threatened arrest/jail if do not pay
Taking/threatening an illegal action
© 2014 ACA International. All Rights Reserved.
TAKING A CLOSER LOOK: Analysis of the Consumer Financial Protection Bureau´s Debt Collection Complaints
8
Allocation of Issues by Sub-Group
The graph below shows the allocation of issues by sub-group, demonstrating the percentage of each
sub-group to its main issue. It is interesting to observe that 47% of the complaints belonging to
medical issues are related to debts that consumers believe they do not owe. In the same way,
medical debt has a relatively high rate of complaints related to “disclosure/verification of debt.”
Student loans have one of the highest rates of complaints related to “communications tactics” and
“false statement or representation.”
Complaints Received in a Timely Fashion
The vast majority of the complaints were responded to in a timely manner, 96% respond on time,
whereas 4% did not respond on time. This shows the commitment of the debt collection industry to
comply with the CFPB’s established timeline for responding to complaints.
25% 21%
30%
15% 21%
31%
15%
33%
23%
33%
33%
24% 47% 33%
26%
48% 16%
46%
12% 17%
11%
23%
22% 15%
18%
5%
17%
6% 10%
12%
8%
9%
8%
8%
9%
4%
15% 9% 17%
5%
8% 15%
6%
15%
7% 9% 10%
6% 2%
6% 5% 5%
22%
3%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Auto Credit card Federalstudent
loan
Medical Mortgage Non-federalstudent
loan
Other(phone,
health club,etc.)
Paydayloan
Notspecified
Taking/threatening an illegal action
Improper contact or sharing of info
False statements or representation
Disclosure/ verification of debt
Cont'd attempts collect debt not owed
Communication tactics
4%
96%
No Yes
© 2014 ACA International. All Rights Reserved.
TAKING A CLOSER LOOK: Analysis of the Consumer Financial Protection Bureau´s Debt Collection Complaints
9
Outcome of the Progress Status of Companies Complaints
In all, 93.71% of complaints were “closed,” “closed with non-monetary relief “or “closed with
explanation.” Of the 14,328 complaints, 10,209 (71%) were closed with an explanation. A total of
2,693 complaints were registered as “closed with non-monetary relief.” A total of 349 complaints
were listed as “closed with monetary relief.”
Complaints by Submitted Channel
It is essential to find out through which channels the consumer complaints were made. Without any
doubt the CFPB website, with 10,439 complaints received, represents the most popular submission
method by a significant margin. E-mail represents the platform of lowest submission with 3
complaints.
10209
2693
525 412 349 140 0
1000
2000
3000
4000
5000
6000
7000
8000
9000
10000
11000
Closed withexplanation
Closed withnon-monetary
relief
Closed In progress Closed withmonetary
relief
Untimelyresponse
10439
1797 1231
741 117 3
0
2000
4000
6000
8000
10000
12000
Web Phone Referral Postal mail Fax Email
© 2014 ACA International. All Rights Reserved.
TAKING A CLOSER LOOK: Analysis of the Consumer Financial Protection Bureau´s Debt Collection Complaints
10
Number of Complaints by State in Comparison to the Total Debt Collected in 2010 Column two shows the number of complaints for each state. Column three shows the percentage of
complaints each state represents to the total number of complaints received by the CFPB. Column
four shows the amount of total debt collected in 2010, followed in column five by percentage of the
total amount of debt collected. Column six shows the difference between the percentage of
complaints and the percentage of debt collected in 2010.
AL 160 1.1% 753.8 1.4% -0.2%
AK 24 0.2% 74.2 0.1% 0.0%
AR 92 0.7% 2274.2 4.1% -3.5%
AZ 337 2.4% 435.4 0.8% 1.6%
CA 1910 13.6% 4400.6 8.0% 5.6%
CO 242 1.7% 1160.4 2.1% -0.4%
CT 111 0.8% 258.3 0.5% 0.3%
DE 59 0.4% 387.7 0.7% -0.3%
DC 88 0.6% 1.6 0.0% 0.6%
FL 1228 8.8% 2836.3 5.2% 3.6%
GA 580 4.1% 2277.8 4.2% 0.0%
HI 49 0.3% 36.2 0.1% 0.3%
ID 62 0.4% 128.7 0.2% 0.2%
IL 425 3.0% 2658.4 4.8% -1.8%
IN 204 1.5% 787.5 1.4% 0.0%
IA 68 0.5% 491.7 0.9% -0.4%
KS 104 0.7% 748.9 1.4% -0.6%
KY 148 1.1% 668.9 1.2% -0.2%
LA 178 1.3% 641.9 1.2% 0.1%
ME 31 0.2% 93.2 0.2% 0.1%
MD 360 2.6% 711.9 1.3% 1.3%
MA 223 1.6% 1324.8 2.4% -0.8%
MI 364 2.6% 736.4 1.3% 1.3%
MN 140 1.0% 1833.8 3.3% -2.3%
MS 71 0.5% 289.1 0.5% 0.0%
MO 231 1.6% 1300.9 2.4% -0.7%
MT 39 0.3% 209.5 0.4% -0.1%
NE 37 0.3% 447.3 0.8% -0.6%
NV 181 1.3% 643.3 1.2% 0.1%
NH 40 0.3% 402.1 0.7% -0.4%
NJ 495 3.5% 1219.9 2.2% 1.3%
NM 87 0.6% 65.6 0.1% 0.5%
NY 952 6.8% 5310.4 9.7% -2.9%
NC 311 2.2% 808.6 1.5% 0.7%
ND 13 0.1% 106.6 0.2% -0.1%
OH 478 3.4% 2597.9 4.7% -1.3%
OK 141 1.0% 777.8 1.4% -0.4%
OR 187 1.3% 486.3 0.9% 0.4%
PA 523 3.7% 2407.8 4.4% -0.7%
RI 50 0.4% 27.4 0.0% 0.3%
SC 238 1.7% 597.3 1.1% 0.6%
SD 26 0.2% 205.5 0.4% -0.2%
TN 245 1.7% 1999.9 3.6% -1.9%
TX 1349 9.6% 5329.2 9.7% -0.1%
UT 105 0.7% 381.1 0.7% 0.1%
VT 11 0.1% 28 0.1% 0.0%
VA 471 3.4% 1057.4 1.9% 1.4%
WA 310 2.2% 1311.3 2.4% -0.2%
WV 39 0.3% 355.4 0.6% -0.4%
WI 176 1.3% 647.1 1.2% 0.1%
WY 27 0.2% 146.5 0.3% -0.1%
DifferenceState Complaints % of Complaints Total Debt Collected 2010
(in million)¹
% Debt
Collected 2010²
© 2014 ACA International. All Rights Reserved.
TAKING A CLOSER LOOK: Analysis of the Consumer Financial Protection Bureau´s Debt Collection Complaints
11
Top 50 Companies Receiving Complaints
According to the data, the top 50 companies by complaint volume, as identified by the CFPB, total
7,900 complaints. Of the top 50, a total of 37 companies are identified as third-party collectors
(5,645). Thirteen companies (totaling 2,255 complaints) are considered something other than a
traditional debt collector (e.g., credit card, student loan servicers, creditors and pay day lenders).
Their inclusion creates confusion in comparing third-party debt collectors, who are subject to the
FDCPA and a myriad of state laws and regulations that creditors do not have to follow. Moreover, it
also raises concerns about duplicative listings for complaints on a debt filed with both the creditor
and the debt collector seeking to recover the debt on behalf of a client.
IV. ACA Recommendations/Conclusion ACA International undertook this study to gain insight into consumer complaint issues and, in
particular, to learn more about the information and to use it for the collection of debts. The main goal
of this analysis is to improve the communication between debt collectors and customers, to mitigate
the number of complaints made by customers.
It is important to ensure all possible options to get efficient resolutions that need to be considered
for every consumer. Informing consumers about all their options in the debt collection process and
the consequences of non-payment should be essential. Third-party debt collectors would benefit
from future study and examination of these and other issues relating to debt collection.
Understanding the data and doing a thoughtful analysis of consumer complaints can be a useful tool
in determining trends and areas for concern as well as areas for improvement by the industry. ACA
pledges to continue working with our members to improve compliance, preventing complaints and
resolving them if they occur. ACA desires to help the CFPB improve its complaint database so that
collectors, consumers, policymakers, regulators and others have an accurate snapshot.
We offer the following suggestions to the CFPB:
Clearly identify first-party collections from third-party collections in complaint reporting and avoid
the potential for double counting complaints that stem from the same underlying issue.
Maintain context by resisting the temptation to use a broad-brush to paint debt collectors and
make assumptions about the behavior of an entire industry solely on the volume of complaints.
Provide more detail to debt collectors who are the subject of a complaint to increase the
likelihood of more easily identifying the information needed to resolve the consumer’s complaint.
Adopt a definition of complaint that is limited to consumer allegations of wrongful conduct and
does not include the concept of general consumer dissatisfaction outside of wrongful conduct.
© 2014 ACA International. All Rights Reserved.