Oliver Wyman is analyzing credit reporting submissions (See note 1) made against the Nationwide Credit Reporting Agencies (NCRAs) (See note 2) via the Consumer Financial Protection Bureau (CFPB) online portal. The CFPB created the online portal to “help consumers connect with financial companies to understand issues, fix errors, and get direct responses about problems” (See note 3).
Oliver Wyman was commissioned by Equifax, Experian, TransUnion (the “NCRAs”), and Hudson Cook LLP to conduct this analysis which aims to understand the increase in the volume of CFPB credit reporting submissions against the NCRAs from about 78,000 in 2017 to about 259,000 in 2020 (See note 4). In this document, we focus on four specific questions that help explain the current state and recent increase in submissions:
- What do submitters complain about via the CFPB portal?
- How frequently are submitters using the CFPB portal?
- What patterns emerge across CFPB portal submissions?
- What recent changes can we observe in the topics raised by submitters?
This analysis is conducted with submissions data that the NCRAs received from the CFPB portal, augmented with the NCRAs’ own internal data from processing submissions for the period of 2017 to 2020.
Key Findings Overview
Qualifications, Assumptions and Limiting Conditions
Oliver Wyman assumes no responsibility for the accuracy or completeness of the information provided by each of the individual NCRAs. The opinions expressed herein are valid only for the purpose stated herein and as of the date hereof. Information furnished by others, upon which all or portions of this report are based, is believed to be reliable but has not been verified. No warranty is given as to the accuracy of such information. Public information and industry and statistical data are from sources Oliver Wyman deems to be reliable; however, Oliver Wyman makes no representation as to the accuracy or completeness of such information and has accepted the information without further verification. No responsibility is taken for changes in market conditions or laws or regulations and no obligation is assumed to revise this report to reflect changes, events or conditions, which occur subsequent to the date hereof.
Oliver Wyman shall not have any liability to any third party in respect of this report or any actions taken or decisions made as a consequence of the results, advice, or recommendations set forth herein.
1. In this document, the word “submission” refers to a credit reporting issue raised with the three Nationwide Credit Reporting Agencies via the CFPB online portal.
2. Equifax, Experian, and TransUnion.
4. “In 2020, the CFPB received about 319,000 submissions regarding credit or consumer reporting submissions”. Of these submissions, about 259,000 referenced at least one of the three NCRAs, with the remainder either sent to other financial institutions (such as banks or lenders) or not sent due to incompleteness. Source: CFPB 2020 Consumer Response Annual Report – March 2021 (https://files.consumerfinance.gov/f/documents/cfpb_2020-consumer-response-annual-report_03-2021.pdf).