The CFPB continues to encourage financial institutions to work with customers regarding issues arising from the COVID-19 pandemic, and has been collecting and posting resources and guidance for consumers to protect and manage their finances during this time. In a Bureau press release, Director Kathleen Kraninger highlighted that "[a]s a backstop, the CFPB stands ready to help consumers resolve issues with their financial services providers through [the CFPB's] consumer complaint system." As the financial services industry continues to serve its customers and react to COVID-19, regulatory guidance published for consumers may be important in understanding consumer and regulatory expectations to avoid consumer complaints and regulatory inquiries.
Among other things, the CFPB is advising consumers to:
- Protect their finances – The CFPB advises consumers to reach out to lenders, servicers, and debt collectors for payment plans and other options to handle a loss of income or inability to make payments on time. The CFPB also directs consumers to various state and local resources and guidance for addressing repayment issues. The Bureau particularly warns of potential scams that may target consumers, notably older consumers, during this time. The CFPB's guidance – and the COVID-19 pandemic generally – may result in an increased need for borrower assistance and alternative payment plans. Industry participants should prepare for an increased volume of customer requests for delayed payment or payment plans and ensure that all aspects of such options, including potential drawbacks, are communicated clearly.
- File complaints – The CFPB encourages consumers to file complaints about issues with financial products or services, after attempting to contact the company directly, as a way to get responses and resolve issues. This may lead to an uptick in consumer complaints as the COVID-19 pandemic continues to disrupt the financial services industry.
- Protect their credit – The CFPB's guidance directs consumers to obtain their credit report, regularly check their credit, and dispute inaccurate information. This may lead to an increased number of credit disputes and general inquiries from consumers.
Financial services companies are adjusting to new working conditions and beginning to engage with consumers facing challenges brought on by the COVID-19 pandemic – and an influx of inquiries, disputes, and complaints may represent a far larger hurdle than encountered under normal conditions. Keeping up to date on the Bureau's guidance to consumers may help companies react quickly to consumer communication spikes and devote resources where needed.
Venable's upcoming webinar, Consumer Financial Services Legal & Regulatory Update: COVID-19, provides an opportunity to hear about these and other issues facing financial services companies.