Financial Pain Points for Older Consumers: A Look at the CFPB Complaint Database - AARP Spotlight

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A ARP PUBLIC POLICY INSTITUTE

                                                                                      SEPTEMBER 2021

Spotlight

Financial Pain Points for
Older Consumers: A Look at
the CFPB Complaint Database
Joe Valenti
AARP Public Policy Institute

In the 10 years since the federal Consumer Financial   transfer, virtual currency, and money service
Protection Bureau (CFPB) opened its doors, it has      businesses. While most complaints are closed with
received roughly three million complaints about        an explanation by the company involved, between
financial products and services from consumers         15 percent and 22 percent of complaints made each
across the country. Filing these complaints is a way   year by people self-identifying as older adults result
for people who have been treated unfairly—or who       in some form of relief—whether monetary, such as
have not been able to get issues resolved with their   fees refunded, or nonmonetary, such as removal of
bank, credit card or mortgage company, or other        incorrect information.
financial firm about a problem—to ultimately get       This Spotlight examines complaints filed with
answers and, in some cases, relief.                    the CFPB from individuals self-reporting as older
Yet while the complaint mechanism serves as a          adults. In part, it presents general findings about
tool for the individual consumer, collectively these   complaints filed since the establishment of the
complaints become a powerful tool for research         complaint database. But, due to changes in data
and planning. Policy makers can use them to direct     collection and reporting over time, it largely focuses
supervision and enforcement of financial firms and     on the time period from January 1, 2018, through
to identify new policy challenges that need to be      June 30, 2021. Notably, data from 2017 and earlier
addressed. Meanwhile, companies and watchdogs          years are often not directly comparable with current
alike can use the public data to see whether high-     complaint database statistics.2
level commitments are being kept.                      Each complaint to the CFPB includes the type of
Among complaints published by the CFPB since           product involved in that complaint, the name of the
its inception, nearly 126,000 have come from           company involved, and the specific issue the customer
consumers who self-identified as being age 62 or       is experiencing. Products and issues are also broken
older—the CFPB’s statutory definition of older         down into smaller categories of subproducts and
adults.1 The most frequent complaints received from    subissues. In addition, since 2015, a consumer also
older adults included issues with errors on their      has had the choice to make public the substance of
credit reports, difficulties with mortgage payments,   his or her complaint by sharing the actual complaint
problems they experience when managing a               narrative with any identifying details removed—a
checking or savings account, and trouble dealing       handful of which are included in this paper.3 While
with debt collectors. Emerging trends appear in the    each complaint is important on its own, these data
data as well, including a small but growing number     points all make it possible to highlight issues of
of complaints about scams and fraud within money       particular importance to older adults.
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Complaint Database Basics: The Number                       legacy of historical discrimination and differences in
and Origin of Consumer Complaints                           the types of products seen in different communities.7
By mid-2021, the CFPB had published a total                 State-by-state breakdowns—another type of
of nearly 2.2 million consumer complaints                   geographic variation captured by the database—also
about financial products and services within its            show wide variation in the number of complaints
jurisdiction.4 New complaints per year across all           submitted by people self-identifying as older adults.
ages increased steadily from over 72,000 in 2012            In 15 states, over 1,000 of these complaints have
to over 277,000 in 2019, before jumping to nearly           been reported to the CFPB since 2018. Floridians
half a million in 2020. Complaints received from            who self-reported as age 62 or older had the highest
people self-identifying as older adults (age 62 or
                                                            total number of complaints during this time
older) totaled 16,444 in 2020, the third highest year
                                                            period—7,257 complaints between January 2018
on record after 2016 (18,366 complaints) and 2015
                                                            and June 2021—with California close behind with
(16,803 complaints). In the first six months of 2021,
                                                            7,204 complaints. North Dakotans who self-reported
more than 237,000 additional complaints overall—
                                                            as age 62 or older submitted the fewest, with only
including 8,897 complaints by older adults—put
the agency on track to potentially exceed 2020’s            40 complaints. Comparing the total number of older
complaint levels.                                           adult complaints against the population age 65 and
                                                            older gives a rough estimate of per capita complaint
The true number of complaints coming from older             levels.8 On a per capita basis, older Floridians had
adults is unclear, since respondents are not required       the fourth-highest number of complaints, behind
to give their age. In 2019, about 20 percent of all         the District of Columbia, Nevada, and Delaware.
US residents were age 62 or older.5 From 2014 to
2016, about 1 in 10 CFPB complaints was filed by
an older adult. This percentage dropped to only
                                                                 Other Consumer Complaint Databases
3.7 percent in 2020 and the first six months of
2021. This underrepresentation of older adults in             The Consumer Financial Protection Bureau (CFPB)
the CFPB database may reflect people not giving               Consumer Complaint Database is not the only
their age when filing a complaint, or it may be               complaint database managed by the federal
caused by differences in awareness of the CFPB                government that takes complaints from the general
and its complaint database, in the types of financial         public and publishes them. However, the CFPB
concerns about which people may be inclined to file           database is notable for the number of individual
a complaint, or other factors. Notably, the CFPB is           data points made publicly available. The Federal
not the only federal agency to maintain a consumer            Trade Commission’s Consumer Sentinel database
                                                              tracks complaints about practices across a wide
complaint database, but certain aspects make it
                                                              range of consumer products. The database also
unique (see sidebar, “Other Consumer Complaint                includes cases of fraud and identity theft, but only
Databases”).                                                  aggregate complaint statistics are publicly available.
In addition to the data gaps resulting from age               The Consumer Product Safety Commission (CPSC)’s
disclosure being optional for complaint filers                complaint database, http://www.saferproducts.gov,
(service-member status is as well), demographic               tracks safety-related complaints and distinguishes
data from CFPB complaints contain other gaps—in               complaints by victims age 65 or older. Like the
part, intentionally so, to protect consumer privacy.          CFPB’s database, the CPSC also publishes complaint
                                                              narratives. The National Highway Transportation
Although data on complaints by race and ethnicity
                                                              Safety Administration collects and publishes
are not available, a 2021 study by the agency found           complaints on vehicles including a narrative, but not
that, in general, more diverse counties—specifically,         the filing driver’s age.9 Airline consumer complaints
where more than 60 percent of the population was              are compiled by the US Department of Transportation
Hispanic or non-White—filed more complaints                   by airline and category,10 but customer ages and
overall, and that this trend was evident across many          narratives are not publicly available.
major financial products.6 This may reflect both the

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There are several ways that people can file a                       other commercial purposes, as well as companies
complaint with the CFPB. In recent years, over                      that offer credit repair services.
90 percent of complaints from older adults came                     Meanwhile, credit or prepaid card complaints have
either through the CFPB’s website or by phone,                      grown as a share of older adult complaints in recent
which is consistent with how people overall submit
                                                                    years, forming the second largest category for 2020
complaints. The CFPB received a smaller share of
                                                                    (at 23 percent) and the third largest category in the
complaints by mail, through a referral from another
                                                                    first six months of 2021 (19 percent). Complaints
government agency, or by fax.
                                                                    about debt collection have declined somewhat in
Credit Reporting, Mortgage, and Credit                              recent years as a relative share of all complaints,
Card Products Receive the Most Older                                from 17 percent in 2018 to 12 percent in 2020 and
Adult Complaints                                                    early 2021. Complaints about banking products
The top five products for which the CFPB received                   such as checking or savings accounts have ranged
complaints have been largely consistent over time                   from 9 percent to 13 percent between 2018 and
(figure 1). About 90 percent of complaints deal                     early 2021, placing them in fifth place for the first
with five types of products: checking or savings                    three years and narrowly overtaking debt collection
accounts, credit or prepaid cards, credit reporting,                for fourth place in the first half of 2021. A smaller
debt collection, and mortgages. Since 2018, the                     share of complaints deal with other product areas
largest share of older adult complaints have                        such as money transfers, payday and title loans,
concerned credit reporting, with about one-quarter                  student loans, and vehicle loans. In addition to the
of all complaints in this category, which includes a                distribution of complaints, the overall volume of
wide range of personal consumer reports that may                    complaints from filers who self-reported as being
be used for banking, employment, insurance, or                      older adults over time is also important.

FIGURE 1
Older Adult Complaints to the CFPB by Product Type (Top Five Products and All Others),
2018–2021*

    Credit reporting, credit repair services, or other personal consumer reports
    Mortgage
    Credit card or prepaid card
    Checking or savings account
    Debt collection
    All others

   2018                25%                         22%                   17%              9%         17%        10%

   2019                 26%                        20%                   18%                13%       13%       10%

   2020                25%                       18%                     23%                   12%     12%      10%

  2021*                25%                        21%                     19%               13%       12%       11%

  Source: AARP Public Policy Institute tabulations of CFPB Consumer Complaint Database.
  * 2021 data reflect January 1 through June 30. Totals may not equal 100 percent due to rounding.

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The number of complaints in most product areas                   such as payday and auto title loans—but people
has increased over time (figure 2). Complaints in                who use these products do still file numerous and
just the first six months of 2021 also grew, in some             significant complaints. Meanwhile, consumers do
categories exceeding complaints for the entire                   not have a choice about whether they interact with
year of 2018. This suggests that for some products,              certain financial products or services, such as credit
total complaint volume for 2021 may well exceed                  reporting and debt collection, but are nevertheless
2020 levels. There were some exceptions to these
                                                                 affected by them. For example, information on a
increases: payday, title, student, or personal loan
                                                                 credit report could affect not just lending decisions
complaints all declined slightly in 2020. Some of
these declines might reflect changes in financial                but also getting a job, renting an apartment, or
behavior during the pandemic, including the                      obtaining a cell phone without a deposit.
payment pause on student loans owned by the
                                                                 Top 10 Issues for Older Adults Remain
federal government—the vast majority of all loans
in this market.                                                  Largely Consistent from Year to Year
                                                                 Going beyond the product level, the issues raised
It is important to note that complaint levels do
                                                                 in complaints from individuals self-identifying
not simply reflect consumers’ satisfaction or
dissatisfaction with a particular product, and                   as older adults provide an even clearer picture of
official complaints may reflect only a fraction of               particular concerns. Since 2018, nearly two-thirds of
the challenges older adults face with that product.              complaints each year have dealt with just 10 issues.
Products that are broadly used, such as basic                    While the relative volume of each type of complaint
checking and savings accounts, will potentially have             has changed somewhat, many of these issues in
a larger number of complaints than products used                 the top 10 are highly consistent from year to year
by a much smaller percentage of older adults—                    (figure 3).

FIGURE 2
Older Adult (Age 62+) Complaints to the CFPB by Product Type, 2018–2021*

    2018
    2019
    2020
    2021*

  4,500
  4,000
  3,500
  3,000
  2,500
  2,000
  1,500
  1,000
    500
      0
              Credit     Mortgage Credit card  Debt     Checking          Money           Vehicle     Payday      Student
            reporting,            or prepaid collection or savings       transfer,        loan or   loan, title     loan
           credit repair             card                account          virtual          lease     loan, or
           services, or                                                  currency,                   personal
          other personal                                                 or money                      loan
            consumer                                                      service
             reports

  Source: AARP Public Policy Institute tabulations of CFPB Consumer Complaint Database.
  * 2021 data reflect January 1 through June 30.

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FIGURE 3
Top 10 Financial Issues Identified by Older Adults (Age 62+) in the CFPB Complaint Database, 2020

                     Credit reporting: Incorrect information on your report                                      2,284

                                Mortgage: Trouble during payment process                                 1,491

                        Checking or savings account: Managing an account                               1,336

          Credit card or prepaid card: Problem with a purchase shown on
                                                          your statement                               1,331

              Credit reporting: Problem with a credit reporting company’s
                                                                                                 981
                                     investigation into an existing problem

                       Debt collection: Attempts to collect debt not owed                        954

                                     Mortgage: Struggling to pay mortgage                  633

    Mortgage: Applying for a mortgage or refinancing an existing mortgage                 540

                              Credit card or prepaid card: Fees or interest          399

           Credit card or prepaid card: Other features, terms, or problems            393

  Source: AARP Public Policy Institute tabulations of CFPB Consumer Complaint Database.

Similar to previous years, the top issue in 2020,                  the minimum payment due, not my actual
with thousands of complaints filed on it, dealt with               payment every month. The only thing I carry
credit reporting: individuals complaining about                    a balance on is my newly acquired auto loan.
incorrect information on their credit reports. These               I have a zero balance on everything else. This
complaints may have been filed against a credit                    is incomplete and incorrect information on
reporting agency or directly against a “furnisher”—                my credit report which causes my [score] to
that is, the lender or other company submitting                    be erroneously lower than it should be. I am
                                                                   recently widowed and have always had a
information to the credit bureaus. Some estimates
                                                                   [score] above X. This is causing me a great
suggest that as many as one in five credit reports                 deal of stress.”
contains an error that could be disputed.11 The
                                                                          —Complaint under “Credit reporting: Incorrect
following are two examples of credit reporting                             information on your report,” Mississippi, 2019
complaints from older adults concerning incorrect
information.                                                       “Company is wrongfully reporting that I was
                                                                   late in paying three of my son’s student loan
   “My credit score keeps going down and                           payments. I had no notice that payment was
   the reason given is that there’s a high ratio                   due for my son’s account nor did I know that
   between balances and credit limit. This                         payment had not been made. I should not
   is incorrect and incomplete information                         be reported as having been late in making
   because I pay my two credit card balances                       payments I did not know were due. When
   in full upon receipt of the monthly statement.                  the credit alert service I subscribe to notified
   What appears in my credit report is merely                      of company’s erroneous report regarding

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   my credit I immediately contacted my son                  Another top-10 complaint each year was that people
   and made sure he rectified his accounts. In               were struggling to pay their mortgage. According to
   addition, the report is misleading as it refers           the CFPB, these complaints were particularly acute
   to three separate accounts and yet lists                  at the beginning of the COVID-19 pandemic.13
   just one account number for each separate                 Notably, the CFPB’s mortgage product category
   erroneous report. This has caused substantial             covers all types of mortgages: traditional “forward”
   harm as the summary is that I have ‘too                   mortgages and other mortgage products such as
   many’ installment accounts with a delinquent              reverse mortgages and home equity loans or lines
   or derogatory payment status. Further it                  of credit. Of all mortgage complaints received
   is misleading as it does not reflect the fact             concerning these two issues, the vast majority dealt
   that I was a co-signer who was not informed               with forward mortgages, including conventional,
   a payment was due from the debtor. These                  Federal Housing Administration, and Veterans
   wrongful actions have caused me substantial               Affairs–backed loans. Approximately 9 percent to
   damages and prohibit me from refinancing                  14 percent of older adults’ mortgage complaints each
   my home. My credit would be perfect but for               year were made regarding nonforward and home
   these wrongful reports.”                                  equity mortgage products.14
         —Complaint under “Credit reporting: Incorrect
            information on your report,” Oregon, 2020        In addition to specific credit reporting and mortgage
                                                             issues, other issues remained prevalent during
The second most common issue each year was                   this time period. Attempts to collect debt that was
trouble during the payment process for mortgages.            not owed, problems with a purchase shown on
Payment process issues include applying principal            a credit card statement, fees or interest on credit
payments and taking advantage of forbearance                 cards, managing a checking or savings account,
options as well as coming out of forbearance.12 In           and problems with a credit reporting company’s
some cases, these complaints also involve payment            investigation were all among the top 10 in each year
services handling payments incorrectly:                      from 2018 through the first six months of 2021.15
   “My mortgage payments have not been                       Looking at the rankings from these years, some
   applied to my account. My husband and I                   issues have newly emerged while others have
   have never been 30 days late on mortgage                  declined in prevalence. During this time, problems
   payments. We continuously receive late                    with applying for a mortgage or refinancing an
   notices and foreclosure letters. This has been            existing mortgage both moved up in the rankings,
   going on [for some time]. The mortgage                    as did closing on a mortgage. This trend potentially
   company is stating that we are approximately              reflects the recent challenges faced by borrowers
   [$3,800.00] behind in our mortgage. I have                during the pandemic. Most notably, while still not
   called the mortgage company to let them                   among the top 10, fraud or scam complaints also
   know that we have NEVER paid our mortgage                 increased markedly in the rankings, from 29th
   late. We pay our mortgage via [a payment                  in 2018 to 12th for the first half of 2021. These
   service] and we have all of our receipts. I               accounted for a small number of complaints in
   tried to set up online payments through the               total: 169 in the first six months of 2021 and 200
   mortgage company’s website but was told                   in 2020. The vast majority of these fraud and
   by a customer service representative that                 scam complaints involved money transfer, virtual
   we must bring our account current. This is                currency, or money service businesses. This increase
   very frustrating because our account is not               mirrors a rise in older adults’ fraud complaints filed
   delinquent. The company did not apply our                 with the Federal Trade Commission.16
   payments correctly.”                                      Complaints about closing a checking or savings
         —Complaint under “Mortgage: Trouble during          account have also increased, possibly as the pandemic
                     payment process,” Virginia, 2020        and recession led to changes in financial habits.17

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Meanwhile, credit card complaints about fees or                  For the remainder of complaints—roughly 15 percent
interest as well as other features, terms, or problems           to 22 percent of all complaints per year—the
moved down in the rankings, as did debt collection               customer making the complaint receives some type
complaints about threatened or actual negative                   of relief from the company. Each year, 7 percent
or legal action as well as complaints about debt                 to 9 percent of complaints result in monetary
collectors’ communication tactics. Some of these may             relief, and an additional 7 percent to 14 percent of
reflect pandemic-related relief as well as limits on debt        complaints result in nonmonetary relief, which may
collection activity in certain jurisdictions, particularly       include actions such as stopping collections calls
while courthouses remained closed.                               and correcting account information or documents.18
At the state level, the top three issues vary                    Between January 2012 and June 2021, a total of 9,742
somewhat but remain fairly consistent. In all                    older adult complaints resulted in monetary relief, and
50 states as well as the District of Columbia and                13,199 resulted in nonmonetary relief. These reflect
Puerto Rico, incorrect information on credit reports             more than 18 percent of known complaints made to
was among the top three. In 44 states, the District              the CFPB by older adults during this time period.
of Columbia, and Puerto Rico, trouble during the
mortgage payment process was also among the                      Even in cases where customers do not individually
top three. Several other issues rounded out the top              receive relief, complaints may nevertheless be
three, including managing a checking or savings                  helpful systemwide. They illustrate particular
account (19 states, the District of Columbia, and                flaws in products, or in people’s expectations about
Puerto Rico), a problem with a purchase shown on a               these products, that may improve product design
credit card statement (19 states), and debt collectors           or customer service practices. They also identify
attempting to collect a debt that was not owed                   for both federal and state regulators whether new
(16 states). In six states, the top three included a             forms of regulation or enforcement are necessary to
problem with a credit reporting company’s existing               protect consumers. And as a public resource, these
investigation. In South Dakota and Wyoming, it                   financial concerns are made available to a broad
included applying for or refinancing a mortgage,                 range of researchers and individuals seeking to
and in North Dakota, it included debt collection                 track challenges in the marketplace.
communication tactics.
                                                                 FIGURE 4
Complaint Outcomes Include Relief for
                                                                 How Complaints Filed by Older Adults in 2020
about 23,000 Older Adults                                        Were Closed by Companies
After a complaint is filed with the CFPB, it is then
sent to the financial company mentioned in that                                                  Monetary relief
complaint. The company has a chance to verify it;                                                   8.01%
for example, for a bank account complaint, the bank                                                   Nonmonetary relief
verifies that someone actually has an account at                                                           7.89%
that bank. The company must then investigate and
                                                                                                         Untimely response
provide an initial response within 15 days as well as a
                                                                      Explanation                             0.46%
final response within 60 days. The way the company                      83.64%                            In progress
ultimately closed the complaint is then made public                                                          0.01%
(figure 4). The vast majority of complaints—three-
quarters or more—are closed with an explanation.
This may reflect a misunderstanding of how a
product or service works, or what the financial
company’s policies or obligations are. In a very small             Source: AARP Public Policy Institute tabulations of CFPB
share of complaints (less than 1 percent per year), the            Consumer Complaint Database.
company fails to provide a timely response.

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Conclusion                                                           data collection from the complaint portal, the
Ten years after its creation, the Consumer Financial                 CFPB should also explore ways to enhance public
Protection Bureau’s complaint database serves as                     complaint reporting and analysis based on age and
a powerful tool for individuals to file complaints                   other demographic factors to identify particular
about a financial product or service, to see that                    areas of concern for various communities.
their voices are heard, and in some cases to obtain                  Otherwise, concerns frequently raised by older
relief. While the true number of complaints filed by                 adults, or among people of a particular race or
older adults is unknown, it is clear that older adults               ethnicity, for example, might be overlooked.
submit complaints to the CFPB about a wide range                     Meanwhile, financial services companies should take
of financial products, with particularly frequent                    older adults’ CFPB complaints seriously and even
concerns about credit reporting, mortgages, credit                   use the information obtained from the database as
cards, bank accounts, and debt collection.                           a resource to support their business. In response to
Such information makes these complaints and the                      recurring problems that older consumers raise, they
data that result from them helpful not only to the                   should explore modifying their products, practices,
individual filer but also to stakeholders who can                    and customer engagement to meet the needs of
provide solutions. The CFPB and other stakeholders                   this growing demographic. Additionally, public and
should expand awareness of the complaint portal                      private-sector entities should also consider these
and its potential to community organizations,                        complaints when vetting potential financial services
researchers, and advocates. This would increase                      company partners. These steps would increase the
both the number of complaints received and                           complaint database’s utility in the years to come for
their value. Given the limitations of demographic                    consumers, business, and government alike.

1 12 USC §5493 (g)(1). People filing complaints with the CFPB have the option to give their age and self-identify as an older
  adult, a service member, or both; this is the only available age-based distinction in these data. In this paper, “Older Adult”
  complaints refer to any record in the complaint database where the “Tags” field contains either “Older Adult” or “Older Adult,
  Servicemember.” According to the CFPB, 26 percent of complaints in 2020 included the complainant’s age (whether over or
  under 62), of which only those 62 or older were reported publicly. Consumer Financial Protection Bureau, “2020 Consumer
  Response Annual Report,” March 2021, https://files.consumerfinance.gov/f/documents/cfpb_2020-consumer-response-
  annual-report_03-2021.pdf.
2 Reporting categories in the database changed on April 24, 2017. As a result, 2017 complaints could fall under either old
  or new categories. For example, complaints about credit cards and prepaid cards were separate categories pre‑2017,
  while they were a single category afterward, and complaints about a bank account or service pre-2017 were relabeled
  as complaints about a checking or savings account. Complaint categories for debt collection, mortgages, student
  loans, and vehicle loans or leases remained consistent. For more information, see CFPB technical release notes:
  https://cfpb.github.io/api/ccdb/release-notes.html. Additionally, complaints during the CFPB’s early years did not reflect the
  full spectrum of financial products and services that the database covers today.
3 Complaints featured in this report have been lightly edited (e.g., removing misspellings, typos, or excess spaces).
4 The number of published complaints is lower than the number of total complaints received because many complaints the CFPB
  receives are ultimately referred to other agencies if they are outside the agency’s jurisdiction, such as complaints concerning
  banks and credit unions with less than $10 billion in assets.
5 US Census Bureau Current Population Survey, https://www2.census.gov/programs-surveys/demo/tables/age-and-sex/2019/
  older-population/2019older_table1.xlsx.
6 Consumer Financial Protection Bureau, “Complaint Bulletin: County-Level Demographic Overview of Consumer Complaints,”
  April 2021, https://files.consumerfinance.gov/f/documents/cfpb_complaint-bulletin_county-level-demographic-overview-
  consumer-complaints_2021-04.pdf.
7 Joe Valenti and Danyelle Solomon, “Communities of Color Cannot Afford a Weakened CFPB,” Center for American Progress,
  2017, https://www.americanprogress.org/issues/economy/reports/2017/03/28/429270/communities-color-cannot-afford-
  weakened-cfpb/.

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8 While the age cutoff for the database is 62, per capita calculations are based on 2018 census population estimates as reported
  in Population Reference Bureau, “Which US States Have the Oldest Populations?,” March 16, 2019, https://www.prb.org/
  resources/which-us-states-are-the-oldest/.
9 National Highway Traffic Safety Administration, “NHTSA Datasets and APIs,” https://www.nhtsa.gov/nhtsa-datasets-and-apis
  (last accessed June 2021).
10 US Department of Transportation, “Aviation Consumer Protection: File a Consumer Complaint,” https://www.transportation.gov/
   airconsumer/file-consumer-complaint (last accessed June 2021).
11 Federal Trade Commission, “Report to Congress under Section 319 of the Fair and Accurate Credit Transactions Act of
   2003,” December 2012, https://www.ftc.gov/sites/default/files/documents/reports/section-319-fair-and-accurate-credit-
   transactions-act-2003-fifth-interim-federal-trade-commission/130211factareport.pdf.
12 CFPB, “2020 Consumer Response Annual Report.” The CFPB also recognized that a large number of mortgage complaints
   dealt with navigating the forbearance process during the pandemic. Consumer Financial Protection Bureau, “Complaint
   Bulletin: Mortgage Forbearance Issues Described in Consumer Complaints,” May 2021, https://files.consumerfinance.gov/f/
   documents/cfpb_mortgage-forbearance-issues_complaint-bulletin_2021-05.pdf.
13 CFPB, “2020 Consumer Response Annual Report.”
14 For example, among older adult consumers who reported in 2020 that they were struggling to pay their mortgages, 6.5 percent
   had a home equity loan or line of credit, and 3.5 percent had a reverse mortgage. Among older adult consumers who reported
   in 2020 having trouble with the payment process on their mortgage, 6.5 percent had a home equity loan or line of credit,
   and 4.4 percent had a reverse mortgage. In both cases, this was a smaller share of all older adult complaints regarding that
   particular mortgage issue than in 2018 or 2019. For complainants who did not self-identify as older adults (of which most
   are presumably younger than age 62), roughly 5 percent of 2020 mortgage complaints regarding these two specific issues
   pertained to home equity loans or lines of credit, and less than 1 percent pertained to a reverse mortgage. This is not surprising
   given that federally guaranteed reverse mortgages (known as Home Equity Conversion Mortgages, or HECMs) are available only
   to homeowners age 62 or older.
15 The debt collection issues above include being called about debts the individuals do not recognize, debts that belong to
   someone else, and collections for services or products they did not receive. Credit card statement disputes include fraud or
   identity theft as well as attempts to obtain refunds or chargebacks for canceled travel, sporting events, concerts, and so on.
   Managing a checking or savings account includes complaints about processes for deposits, withdrawals, ATM cards, funds
   availability, and bank branch closures. CFPB, “2020 Consumer Response Annual Report.”
16 AARP analysis of Federal Trade Commission Consumer Sentinel data, “Reported Frauds and Losses by Age,”
   https://public.tableau.com/app/profile/federal.trade.commission/viz/FraudReports/AgeFraud (last accessed July 2021).
17 For example, during the prior recession, people who lost jobs often closed bank accounts as a result. Across multiple cycles
   of the Federal Deposit Insurance Corporation’s survey of unbanked households, the most frequent reason those without
   a checking or savings account give for not having an account is a lack of money to put in it. Joe Valenti, “Financial Access
   Challenges for Older Adults,” AARP Public Policy Institute, September 9, 2020, https://www.aarp.org/ppi/info-2020/financial-
   access-challenges-for-older-adults.html.
18 “The Bureau defines ‘monetary relief’ as objective, measurable, and verifiable
   monetary relief to the consumer as a direct result of the steps that have or
   will be taken in response to the complaint. The Bureau defines ‘non-monetary             Spotlight 1217900, September 2021
   relief’ as other objective and verifiable relief to the consumer as a direct result
   of the steps that have or will be taken in response to the complaint. Examples           © AARP PUBLIC POLICY INSTITUTE
   of non-monetary relief to consumers include stopping unwanted calls from debt            601 E Street, NW
   collectors; correcting account information; correcting inaccurate data provided          Washington DC 20049
   or reported in consumers’ credit reports; issuing corrected documents; restoring         Follow us on Twitter @AARPpolicy
   account access; and addressing formerly unmet customer service issues. ‘Closed           On facebook.com/AARPpolicy
   with explanation’ indicates that the steps taken by the company in response to the       www.aarp.org/ppi
   complaint included an explanation that was tailored to the individual consumer’s
   complaint. For example, this category is used if the explanation substantively           For more reports from the Public Policy
   meets the consumer’s desired resolution or explains why no further action will be        Institute, visit http://www.aarp.org/ppi/.
   taken. Companies should select ‘Closed with explanation’ category when specific,
   verifiable monetary or non-monetary relief was not provided to the consumer              https://doi.org/10.26419/ppi.00147.001
   in response to issues raised in the complaint.” Consumer Financial Protection
   Bureau, “2020 Consumer Response Annual Report.”

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