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This presentation highlights the flaws in the CFPB complaint process and why it does not meet the arbitration requirements of American consumers. It provides detailed analysis, tables, charts, and graphs extracted from the CFPB Complaint Database. The presentation can be viewed interactively on the web.
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TWENY-FIVE REASONS WHY THE cfpb complaint process Does not work! THE FOLLOWING SECTION OF THIS PRESENTATION CONTAINS TWENTY-FIVE REASONS WHY THE CFPB COMPLAINT PROCESS DOES NOT MEET THE COMPLAINT ARBITRATION REQUIREMENTS OF AMERICAN CONSUMERS. THE INFORMATION USED TO CREATE THIS SECTION, WAS EXTRACTED FROM A SNAPSHOT OF THE DECEMBER 2011 THROUGH MARCH 14, 2017 CFPB COMPLAINT DATABASE, LOCATED AT: https://www.consumerfinance.gov/data-research/consumer-complaints/cfpb-top-20.ppsx Important Note: The twenty-five “reasons” contained in the following six pages, reference detail analysis, tables, charts, and graph included in twenty-eight additional pages of this presentation. These two sections of the presentation, are best viewed interactively, on the web at: http://www.cfpbcomplaintmonitor.org/cfpb_top-20.ppsx "THE COMPANY" ALWAYS WIN!
TOP-25 REASONS WHY THE CFPB COMPLAINT PROCESS DOES NOT WORK. • “THE COMPANY” CONTROLS THE CFPB COMPLAINT ARBITRATION PROCESS, AND CAN CLOSE ANY CONSUMER COMPLAINT,” AT ANY TIME, WITHOUT THE CONCURRENCE OF THE CONSUMER OR CFPB. • “THE COMPANY” ALWAYS WIN: THE APRIL 2017 SNAP-SHOP OF THE CFPB DATABASE SHOWS THAT OF THE 743,427 CONSUMERS WHO FILED CFPB COMPLAINTS, ONLY 6.7% WERE AWARDED MONETARY RELIEF, AND THAT “THE COMPANY” WON 81% OF ALL COMPLAINTS; AND CLOSED THEM WITH GENERIC, NON-SPECIFIC EXPLANATIONS. • CONSUMER COMPLAINT NARRATIVES ARE DESIGNED TO “EMPOWER” THE CONSUMER TO PROVIDE “WHAT HAPPENED” INFORMATION THAT CAN BE USED BY CFPB AND “THE COMPANY” TO CLEARLY UNDERSTAND THE BASIS OF THEIR COMPLAINT. ALTHOUGH THE INFORMATION CONTAINED IN COMPLAINT NARRATIVES IS ALSO INCLUDED IN CONSUMER COMPLAINTS RECEIVED VIA EMAIL, FAX, PHONE, POSTAL MAIL, AND REFERRAL; CFPB CHOSE NOT TO INCLUDE THIS INFORMATION IN NON-WEB COMPLAINTS SENT TO “THE COMPANY”. • THERE IS NO SEPARATE, INTER-AGENCY TRACKING OF CONSUMER COMPLAINTS THAT WERE FILED WITH OTHER FEDERAL, STATE, OR LOCAL CONSUMER COMPLAINT AGENCIES, AND THEN REFERRED TO CFPB: • IN MANY INSTANCES, CONSUMERS WERE NOT AWARE THAT THEIR COMPLAINTS HAD BEEN REFERRED TO CFPB UNTIL THEY RECEIVED A CLOSED RESPONSE FROM “THE COMPANY”. • THERE IS NO DOCUMENTED CFPB JURISDICTIONAL REVIEWS; AND NO DISPUTE, ESCALATION, OR APPEAL PROCESSES FOR CONSUMER COMPLAINTS FILED WITH OTHER GOVERNMENT AGENCIES, AND THEN REFERRED TO CFPB). "THE COMPANY" ALWAYS WIN! 2
TOP-25 REASONS WHY THE CFPB COMPLAINT PROCESS DOES NOT WORK. (Continued): • “THE COMPANY” CAN ARBITRARILY, AND CAPRICIOUSLY, CLOSE CONSUMER COMPLAINTS WITHOUT THE CONSENT OF EITHER THE CONSUMER, OR THE CFPB. • COMPLAINTS REFERRED BY OTHER AGENCIES ARE NOT FORMALLY-REVIEWED BY CFPB, BEFORE BEING FORWARDED TO “THE COMPANY”, AS-IS; WITHOUT CFPB COMMENTS OR COMMENTARY. • “THE COMPANY” IS NOT REQUIRED TO PUBLICLY-SHARE IT’S CONSUMER COMPLAINT RESPONSES, AND CAN REQUEST THAT SELECTED COMPLAINTS NOT BE PUBLISHED IN THE CFPB DATABASE, THIS DEPRIVES OTHER CONSUMERS, AS WELL AS OTHER FEDERAL AND/OR STATE REGULATORY AGENCIES OF THIS VITALLY-IMPORTANT INFORMATION. • “THE COMPANY” ONLY RESPONDS TO ISSUES AND SUB-ISSUES; AND IS NOT REQUIRED TO RESPOND TO COMPLAINT NARRATIVES OR ANY OTHER EVIDENCE APPENDED TO CFPB COMPLAINTS. • “THE COMPANY” RESPONSES TO CONSUMER COMPLAINTS REFERRED TO CFPB BY OTHER AGENCIES, ARE NOT SHARED WITH THE REFERRING AGENCIES, OR ANY OTHER FEDERAL, STATE OR LOCAL CONSUMER-COMPLAINT/CONSUMER-PROTECTION AGENCY. • “Enforcing laws that outlaw discrimination in consumer finance” IS ONE OF THE FIVE PRIMARY ACCOUNTABILITIES OF CFPB; YET, THERE IS NO RECORD IN THE CFPB DATABASE OF ANY CFPB COMPLAINT: ALLEGING RACIAL, ETHNIC, RELIGIOUS, OR OTHER FORMS OF DISCRIMINATION; OR OTHER ARE FORMS OF UNLAWFUL PRACTICES. "THE COMPANY" ALWAYS WIN! 3
TOP-25 REASONS WHY THE CFPB COMPLAINT PROCESS DOES NOT WORK. (Continued): CONSUMER COMPLAINTS FLAGGED AS DUPLICATES BY “THE COMPANY”, AND DISCARDED BY THE CFPB COMPLAINT DEPARTMENT WITHOUT FURTHER INVESTIGATION. THE ONLY DEMOGRAPHIC CATEGORIES CONTAINED IN THE CFPB DATABASE ARE: A.) OLDER AMERICANS, B.) SERVICEMEMBERS, AND C.) OLDER SERVICEMEMBERS; HOWEVER, THERE IS NO SPECIAL ‘CFPB REVIEWS’ FOR THESE THREE DEMOGRAPHIC CATEGORIES; AND “THE COMPANY” ARBITRATION PROCESSES FOR THESE DEMOGRAPHIC CATEGORIES ARE THE SAME AS OTHER CFPB COMPLAINTS. OTHER CONSUMER COMPLAINT AGENCIES WITHIN THE FEDERAL GOVERNMENT APPEAR OBLIVIOUS OF THE MAJOR FLAWS IN THE CFPB COMPLAINT PROCESS, AND CONTINUE TO “BLINDLY THROW THEIR CONSUMER COMPLAINTS OVER THE WALL TO CFPB”. CFPB DOES NOT PUBLISH ANNUAL REPORTS OF RESPONSES BY: COMPANY, PRODUCTS, ISSUES, OR ANY OTHER CATEGORY. THESE TYPE REPORTS WOULD HELP CONSUMERS, AND REGULATORY AGENCIES IDENTIFY COMPANIES WITH UNEXPLAINED YEAR-OVER-YEAR INCREASES IN CFPB COMPLAINTS. CFPB DOES NOT PUBLISH ANNUAL REPORTS OF RESPONSES BY: COMPANY, PRODUCTS, ISSUES, OR ANY OTHER CATEGORY. THESE REPORTS HELP CONSUMERS, AND REGULATORY AGENCIES IDENTIFY COMPANIES WITH UNEXPLAINED COMPLAINT INCREASES, SUCH AS THOSE THAT OCCURRED IN FOURTEEN OF THE TOP 20 COMPANIES BETWEEN 2015 AND 2016. "THE COMPANY" ALWAYS WIN! 4
TOP-25 REASONS WHY THE CFPB COMPLAINT PROCESS DOES NOT WORK. (Continued): CFPB DOES NOT PUBLISH REPORTS THAT IDENTIFY COMPANIES WHO IGNORE, AND/OR REFUSE TO RESPOND TO CFPB CONSUMER COMPLAINTS. THE CFPB COMPLAINT PROCESS INCLUDES AN INTERNAL ENFORCEMENT UNIT, BUT THE CFPB DATABASE DOES NOT IDENTIFY THE CONSUMER COMPLAINTS REFERRED TO THIS UNIT. (IN FACT, ONLY TWO (2) COMPLAINTS WERE REFERRED TO THIS INTERNAL AGENCY BY CFPB BETWEEN 2011 AND 2016. CFPB DOES NOT ANALYZE AND/OR PUBLISH MONTHLY, QUARTERLY, OR ANNUAL REPORTS CONTAINING CONSUMER COMPLAINT TRENDS, PATTERNS, AND/OR IRREGULARITIES CFPB DOES NOT PUBLISH SUMMARY REPORTS SHOWING THE FINAL RESOLUTION OF CONSUMER COMPLAINTS ALLEGING CRIMINAL ACTIVITIES, SUCH AS IDENTITY THEFT, PREDATORY LENDING, MORTGAGE LOAN FRAUD, OR EMBEZZLEMENT. CFPB DOES NOT PUBLISH ANNUAL REPORTS SHOWING THE FINAL RESOLUTION OF CONSUMER COMPLAINTS SUBMITTED BY RACIAL, ETHNIC, AND GENDER CATEGORIES. CFBP DOES NOT PUBLISH ANNUAL TREND ANALYSIS REPORTS DELINEATING CFPB COMPLAINTS ORIGINATING IN PREDOMINATELY-MINORIY COMMUNITIES. THESE COMPLAINTS ARE FOR PRODUCTS SUCH AS DEBT COLLECTION, MONEY TRANSFER, PAYDAY LOAN, AND PREPAID CARD. "THE COMPANY" ALWAYS WIN! 5
TOP-25 REASONS WHY THE CFPB COMPLAINT PROCESS DOES NOT WORK. (Continued): THE “COMPANY PORTAL” USED TO INTERNECT CFPB WITH THE COMPANY PROVIDES THE COMPANY WITH REALTIME, INTERACTIVE ACCESS TO CFPB COMPLAINT DATA, INCLUDING ALL COMPLAINTS PREVIOUSLY FILED BY THE CONSUMER; BUT THE CONSUMER IS NEVER INFORMED OF ITS EXISTANCE, AND ARE NOT TOLD WHAT PORTIONS OF HIS, OR HER, COMPLAINT DATA CAN BE ACCESSED BY “THE COMPANY”. THE CONSUMER COMPLAINT DATABASE CONTAINS 10,022 CONSUMER NARRATIVES, ALL OF WHICH WERE DISPUTED BY CONSUMERS, AND ALL BUT 22 OF THESE NARRATIVES WERE IN RESPONSES TO COMPLAINTS, CLOSED BY “THE COMPANY”, WITH A “CLOSE WITH EXPLANATION RESPONSE; THIS INDICATES THAT THERE WAS NEAR UNANIMOUS DISPUTE OF “THE COMPANY” RESPONSES TO THESE COMPLAINTS. THE CFPB WEBSITE TOUTED THE SPECTACULAR SUCCESSES OF THE CFPB COMPLAINT PROCESS, BUT PROVIDED NO MECHINISM FOR MEASURING THE CONSUMER’S SATISFACTION (OR LACK THEREOF) OF THE COMPLAINT PROCESS. XXV. THE CFPB WEBSITE PRESENTS THE ILLUSION THAT THE CFPB COMPLAINT PROCESS IS PROTECTS CONSUMERS FROM UNSCRUPULOUS, UNETHICAL FINANCIAL SERVICES COMPANIES; HOWEVER, EVEN THOUGH, AS OF ARPIL 2017, AGAINST MORE THAN FORTY-TWO HUNDRED COMPLANIES, THE CFPB WEBSITE DID NOT HAD A SINGLE NEGATIVE REPORT ON ANY COMPANY. "THE COMPANY" ALWAYS WIN! 6
“THE COMPANY” CONTROLS THE CFPB COMPLAINT ARBITRATION PROCESS, AND CAN CLOSE "ANY "CONSUMER COMPLAINTS, AT ANY TIME, WITHOUT THE CONCURRENCE OF EITHER CFPB OR THE CONSUMER.ILLUSTRATIVE EXAMPLE: CFPB ALLOWS "THE COMPANY" TO CLOSE COMPLAINTS AT ITS DISCRETION, AND WHEN IT DOES SO, IT CAN SEND THE CONSUMER A GENERIC, NON-SPECIFIC RESPONSE, THAT IS IN ACTUALITY, THE "THE KISS OF DEATH" FOR THE CONSUMER'S COMPLAINT. THIS SEEMINGLY-SIMPLE ACT OF CLOSING A CFPB COMPLAINT BY "THE COMPANY", ENDS ALL RIGHTS FOR THE CONSUMERS TO OBTAIN A FAIR, OBJECTIVE, AND IMPARTIAL ARBITRATION OF COMPLAINTS AGAINST "THE COMPANY". THE "KISS OF DEATH" ACT OF CLOSING A COMPLAINT WITH CFPB'S STAMP-OF-APPROVAL CAN BE USED BY CFPB AS THE REASON FOR NOT ACCEPTING SIMILAR COMPLAINTS FROM THE CONSUMER; AND AS THE BASIS FOR OTHER CONSUMER COMPLAINT/CONSUMER PROTECTION AGENCIES NOT TO ACCEPT JURISDICTION OF THE SAME COMPLAINT (OR SIMILAR COMPLAINTS) AGAINST "THE COMPANY". THE CFPB ‘KISS OF DEATH’ APPROVAL OF “THE COMPANY” RESPONSE: THE CFPB ‘KISS OF DEATH’ APPROVAL OF “THE COMPANY” ARBITRARY DECISIONS, MAKES IT DIFFICULT FOR THE CONSUMERS WHO HAVE FILED COMPLAINTS VIA THE CFPB COMPLAINT PROCESS, TO OBTAIN THE SERVICES OF ATTORNEYS, BECAUSE IT IS “INCORRECTLY-ASSUMED” THAT CFPB PARTICIPATED IN THE COMPLAINT ARBITRATION PROCESS; WHEN IN FACT, “THE COMPANY” CONTROLS THE COMPLETE COMPLAINT ARBITRATION PROCESS. GIVEN THIS SCENARIO, IT IS A PROBABLY THAT CONSUMERS WOULD HAVE MUCH BETTER SUCCESS, IF THEY FILED THEIR COMPLAINTS DIRECTLY WITH “THE COMPANY”, AND BY-PASSED CFPB ALL TOGETHER. Close and return "THE COMPANY" ALWAYS WIN!
II(a. THE CFPB COMPLAINT DATABASE SHOWS, THAT CONSUMERS FILING CFPB MORTGAGE COMPLAINTS ARE ONLY AWARDED MONETARY RELIEF BY "THE COMPANY" 2.6% OF THE TIME; AND “THE COMPANY” CLOSES 91% OF ALL MORTGAGE COMPLAINTS WITH MEANINGLESS, AND NON-SPECIFIC EXPLANATIONS.ILLUSTRATIVE EXAMPLE: MOST GOVERNMENT CONSUMER COMPLAINT AGENCIES; SUCH AS THE OCC CONSUMER ASSISTANCE GROUP (CAG), HAVE LEVEL-ONE AND LEVEL-TWO REVIEW PROCESS TO WHICH CONSUMER COMPLAINTS CAN BE APPEALED; HOWEVER, THE CFPB COMPLAINT PROCESS HAS NO FIRST, OR SECOND LEVEL REVIEW OR DISPUTE PROCESSES, AND ALL “THE COMPANY“ RESPONSES ARE SIMPLY "RUBBER-STAMPED-APPROVED" BY CFPB, AND VIRTUALLY ALL COSUMER COMPLAINTS ARE CLOSED BY “THE COMPANY” WITHOUT RECEIVING EVEN A PERFUNCTORY REVIEW BY CFPB. "THE COMPANY" ALWAYS WIN!
II(b. CONSUMERS FILING CFPB COMPLAINTS ARE ONLY AWARDED MONETARY RELIEF 6.7% OF THE TIME, AND “THE COMPANY” WINS 81% OF ALL COMPLAINTS; AND CAN CLOSES CONSUMER COMPLAINTS FOREVER WITH GENERIC, AND/OR NON-SPECIFIC EXPLANATIONS.ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT TWO OF THE NATION'S LARGEST HOME MORTGAGE SERVICERS: SELECT PORTFOLIO SERVICING, INC. AND OCWEN, INC.,WON 97.6% AND 92.9%, RESPECTIVELY, OF THEIR MORTGAGE-RELATED COMPLAINTS; AND CLOSED THEIR CFPB COMPLAINTS WITH THAN ONE PERCENT MONETARY RELIEF TO THEIR CONSUMERS. Close and return Close and return "THE COMPANY" ALWAYS WIN! "THE COMPANY" ALWAYS WIN! 9
III. BEGINNING IN 2015, THE CFPB COMPLAINT PROCESS ENABLED CONSUMERS SUBMITTING COMPLAINTS VIA THE WEB, TO INCLUDE COMPLAINT NARRATIVES. THESE NARRATIVES, ALLOWED THE CONSUMERS TO PROVIDE DETAIL DESCRIPTIONS OF: “WHAT HAPPENED”. CONSUMERS SUBMITTING THEIR COMPLAINT TO CFPB VIA EMAIL, FAX, PHONE, AND POSTAL MAIL; WERE REQUIRED TO EXPLAIN “WHAT HAPPENED”; BUT CFPB CHOSE NOT TO SEND THIS INFORMATION TO “THE COMPANY” OR APPEND IT TO THE CFPB DATABASE. THUS, AS THIS IMPLIES, THE COMPANY’S ADJUDICATION RESPONSES TO CFPB COMPLAINTS, WITHOUT NARRATIVES, ARE EXCLUSIVELY BASED ON THE GENERIC COMPLAINT ISSUES AND/OR SUB-ISSUES ASSIGNED TO THE COMPLAINT BY CFPB. ILLUSTRATIVE EXAMPLE: Click to see details regarding sources of complaints. "THE COMPANY" ALWAYS WIN!
Close and return "THE COMPANY" ALWAYS WIN!
IV(a. THERE IS NO FORMAL DISPUTE PROCESS FOR CONSUMER COMPLAINTS FILED WITH CFPB, (OR CONSUMER COMPLAINTS FILED WITH OTHER GOVERNMENT AGENCIES), AND THEN DISPUTED BY CONSUMERS.ILLUSTRATIVE EXAMPLES: • DISPUTE PROCESS: • ON APRIL 30, 2017, CFPB ANNOUNCED THAT IT WAS DISCONTINUING THE OPTION OF ALLOWING CONSUMERS TO DISPUTE CLOSED RESPONSES FROM "THE COMPANY"; AND WAS REPLACED THIS OPTION WITH AN IRRELEVANT “CONSUMER FEEDBACK CAPABILITY", THAT WOULD ENABLE CONSUMERS TO LEAVE COMMENTS REGARDING THEIR ASSESSMENT OF HOW THEIR COMPLAINT WAS HANDLED BY CFPB. BETWEEN DECEMBER 1, 2011 TO APRIL 30, 2017, 145,150 OF THE 743,427 COMPLAINTS FILED VIA THE CFPB COMPLAINT PROCESS WERE DISPUTED BY CONSUMERS WHO BELIEVED THAT THEIR DISPUTES WOULD BE REVIEWED BY CFPB AND/OR “THE COMPANY”. HOWEVER, AS INCOMPREHENSIBLE AS IT SOUNDS, NONE OF THESE DISPUTED COMPLAINTS WERE EVER RE-ARBITRATED BY THE "THE COMPANY"; AND EVEN WORSE, NONE OF THESE DISPUTED COMPLAINTS WERE REVIEWED BY CFPB. GIVEN THIS SCENARIO, CFPB MAY HAVE PURPOSELY DEPRIVED 145,150 CONSUMERS OF THEIR RIGHTS FOR A FAIR, AND OBJECTIVE ADJUDICATION OF THEIR DISPUTE BY "THE COMPANY". "THE COMPANY" ALWAYS WIN!
IV(a. THERE IS NO FORMAL DISPUTE PROCESS FOR CONSUMER COMPLAINTS FILED WITH CFPB, (OR CONSUMER COMPLAINTS FILED WITH OTHER GOVERNMENT AGENCIES), AND THEN DISPUTED BY CONSUMERS.(Continued) • CFPB COMPLAINT DISPUTE PROCESS: "THE COMPANY" ALWAYS WIN!
IV b.) THERE IS NO FORMAL REFERRAL PROCESSES FOR CONSUMER COMPLAINTS FILED WITH CFPB; OR CONSUMER COMPLAINTS FILED WITH OTHER GOVERNMENT AGENCIES, AND THEN REFERRED TO CFPB.ILLUSTRATIVE EXAMPLE: • INTER-AGENCY AND INTRA-AGENCY REFERRAL PROCESS: • INFORMATION OBTAINED FROM CFPB UNDER THE FREEDOM OF INFORMATION (FIOA), SHOWS THAT BETWEEN 2011 AND 2016, CFPB REFERRED MORE THAN TWENTY-ONE HUNDRED CONSUMER COMPLAINTS TO OTHER AGENCIES; HOWEVER, THERE IS NO SPECIFIC INFORMATION IN THE CFPB DATABASE, OR THE CFPB WEBSITE REGARDING, A.) THE METHODOLOGY USED BY CFPB TO REFER COMPLAINTS, B.) THE TYPE COMPLAINTS REFERRED, C.) THE NAME OF FEDERAL (OR STATE) AGENCY TO WHICH THESE COMPLAINTS ARE REFERRED, OR D.) THE FINAL RESOLUTION OF THESE REFERRED COMPLAINTS. • SHOCKINGLY, ONLY TWO OF THE MORE THAN TWENTY-ONE THOUSAND COMPLAINTS REFERRED TO OTHER AGENCIES, WERE REFERRED TO CFPB’S INTERNAL ENFORCEMENT AGENCY. "THE COMPANY" ALWAYS WIN!
IV b.) THERE IS NO FORMAL REFERRAL PROCESSES FOR CONSUMER COMPLAINTS FILED WITH CFPB; OR CONSUMER COMPLAINTS FILED WITH OTHER GOVERNMENT AGENCIES, AND THEN REFERRED TO CFPB.(Continued) • CFPB COMPLAINT REFERRAL PROCESS: Close and return "THE COMPANY" ALWAYS WIN!
“THE COMPANY” CAN ARBITRARILY, CLOSE CONSUMER COMPLAINTS DISPUTED BY WITHOUT THE CONSENT OF EITHER THE CONSUMER, OR THE CFPB. ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT 74.4% OF ALL CFPB COMPLAINTS WERE "CLOSED WITH EXPLANATION", AND ANOTHER 2.3% OF COMPLAINTS WERE "CLOSED” (WITH NO RESPONSE); AND THUS, BECAUSE THE CFPB COMPLAINT PROCESS DOES NOT HAVE AN ACTIONABLE DISPUTE PROCESS, THESE CONSUMER COMPLAINTS ARE EFFECTIVELY “DEAD”. EVEN THE COMPLAINTS “CLOSED WITH MONETARY RELIEF”, AND “CLOSED WITH NON-MONETARY RELIEF”, (WHICH WERE THEORETICALLY WON BY THE CONSUMER), WERE DISPUTED 3.7% AND 7.5%, RESPECTIVELY. Close and return "THE COMPANY" ALWAYS WIN!
VI. COMPLAINTS REFERRED BY OTHER AGENCIES ARE NOT FORMALLY-REVIEWED BY CFPB, BEFORE BEING FORWARDED TO “THE COMPANY”, VIA THE COMPANY PORTAL, WITHOUT COMMENTS OR COMMENTARY.ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT THIS UNSTRUCTURED, UNREGULATED REFERRAL PROCESS IS ANALOGOUS TO "GOVERNMENT AGENCIES BLINDLY THROWING CONSUMER COMPLAINTS OVER THE WALL TO CFPB"; AND BY DEFAULT, THIS ACTION RELIEVES THE REFERRING AGENCY OF ALL RESPONSIBILITY FOR THE SPECIFIED CONSUMER COMPLAINT. THE FOLLOWING TABLE SHOWS THAT 21,367 REFERRED CFPB COMPLAINTS WERE DISPUTED BY CONSUMERS: Close and return "THE COMPANY" ALWAYS WIN!
VII. “THE COMPANY” IS NOT REQUIRED TO PUBLICLY-SHARE ITS CONSUMER COMPLAINT RESPONSES; AND THIS DEPRIVES OTHER CONSUMERS; AND OTHER FEDERAL AND/OR STATE REGULATORY AGENCIES OF THIS VITALLY-IMPORTANT INFORMATION.ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT ONE OF THE NATION'S LARGEST NATIONAL ASSOCIATION BANK: JPMORGAN CHASE BANK, N. A., PUBLICLY SHARED ONLY ONE (1) OF ITS 18,179 CFPB MORTGAGE COMPLAINT RESPONSES, IT RECEIVED BETWEEN JANUARY 2011 AND MAY 2017. Close and return "THE COMPANY" ALWAYS WIN!
VIII. “THE COMPANY” IS NOT REQUIRED TO RESPOND TO DOCUMENTATION AND/OR OTHER EVIDENCE APPEND TO CFPB COMPLAINTS. IN MOST INSTANCES, THEY SIMPLY IGNORE THE APPENDED DOCUMENTS AND RESPOND TO COMPLAINT “ISSUES” AND “SUB-ISSUE”.ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT "THE COMPANY" IS ONLY REQUIRED TO RESPOND TO THE GENERIC, NON-SPECIFIC ISSUE AND/OR SUB-ISSUE "ASSIGNED" TO THE CONSUMER COMPLAINT BY CFPB; AND ALTHOUGH, CFPB FREQUENTLY APPENDS COPIES OF SUPPORTING DOCUMENTATION BEFORE THE CONSUMER COMPLAINT IS PLACED ON THE “COMPANY PORTAL”, "THE COMPANY" IS NOT COMPELLED TO REFERENCE THIS APPENDED DOCUMENTATION IN ITS RESPONSE TO EITHER CFPB, OR THE CONSUMER. Close and return "THE COMPANY" ALWAYS WIN!
IX. “THE COMPANY” RESPONSES TO CONSUMER COMPLAINTS REFERRED TO CFPB BY OTHER COMPLAINT AGENCIES, ARE NOT SHARED WITH THE REFERRING AGENCIES, OR ANY OTHER FEDERAL OR STATE COMPLAINT AGENCY. ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT 130,671 OF THE 743,427 CONSUMER COMPLAINTS CONTAINED IN THE DATABASE ON APRIL 30, 2017, WERE REFERRED BY OTHER AGENCIES; AND THAT "THE COMPANY" RESPONSES TO 21,367 OF THESE REFERRED COMPLAINTS WERE DISPUTED BY CONSUMERS. (THIS INTER-AGENCY COMPLAINT REFERRAL PROCESS DOES NOT WORK BECAUSE CFPB DOES NOT SHARE THE CLOSED-RESPONSE RECEIVED FROM “THE COMPANY” WITH THE REFERRING COMPLAINT AGENCY.) Close and return "THE COMPANY" ALWAYS WIN!
X. “Enforcing laws that outlaw discrimination in consumer finance” IS ONE OF THE PRIMARY ACCOUNTABILITIES OF THE CFPB AGENCY; BUT THERE ARE NO COMPLAINTS ALLEGING RACIAL, ETHNIC, RELIGIOUS OR OTHER FORMS OF DISCRIMINATION ARE NOT ENUMERATED, OR INVESTIGATED BY CFPB.ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT NONE OF THE " ISSUES OR SUB-ISSUES" IN THE MORE THAN SEVEN HUNDRED AND FORTY-THREE THOUSAND CONSUMER COMPLAINTS CONTAINED IN THE CFPB COMPLAINT DATABASE; WERE SPECIFICALLY FOR RACIAL, ETHNIC, GENDER, OR RELIGIOUS DISCRIMINATION. (EXAMPLE: PAYDAY LENDING IS AN EXAMPLE OF A CFPB PRODUCT, THAT SHOULD HAVE LARGE NUMBERS OF RACIAL DISCRIMINATION CLAIMS FROM AFRICAN AMERICANS AND OTHER MINORITIES. AND, AS THE FOLLOWING TABLE SHOWS, “THE COMPANY” WINNING PERCENTAGE WAS STAGGERING 90.8% OF ALL PAY DAY LOAN COMPLAINTS FILED VIA THE CFPB): Close and return "THE COMPANY" ALWAYS WIN!
XI. CONSUMER COMPLAINTS FLAGGED AS DUPLICATES BY “THE COMPANY”, ARE INDISCRIMINATELY DISCARDED BY THE CFPB COMPLAINT DEPARTMENT WITHOUT FURTHER INVESTIGATION.ILLUSTRATIVE EXAMPLE: THERE IS NO APPEAL OF THE COMPANY’S ASSESSMENT THAT A NEWLY RECEIVED COMPLAINT IS THE SAME AS ONE PREVIOUSLY FILED BY THE SAME CONSUMER; (THIS IS THE CASE, EVEN THOUGH THE SUPPORTING COMPLAINT DOCUMENTATION, MAY CLEARLY DELINEATE THE DIFFERENCES BETWEEN THE TWO COMPLAINTS). THIS LEADS TO THE CONCLUSION THAT, “THE COMPANY" IS MORE CONCERNED WITH FINDING REASONS WHY CONSUMER COMPLAINTS “SHOULD NOT” BE ARBITRATED"; RATHER THAN ANALYZING THE NEWLY-RECEIVED CONSUMER COMPLAINTS TO DETERMINE IF "THE CONSUMER’S FIDUCIARY RIGHTS TO A FAIR, AND OBJECTIVE ARBITRATION OF THEIR COMPLAINT IS BEING FULFILLED. THE FACT THAT THIS “MISCARRIAGE OF JUSTICE” IS ALLOWED TO GO UNCHALLENGED BY THE CFPB REVIEWER, IS THE UNDERLYING PROBLEM OF THE "FLAWED" CFPB COMPLAINT PROCESS! THE CFPB’S PRIMARY RESPONSIBILITY IS TO “THE CONSUMER”, AND NOT TO “THE COMPANY”. Close and return "THE COMPANY" ALWAYS WIN!
XII. THE ONLY DEMOGRAPHIC CATEGORIES CONTAINED IN THE CFPB DATABASE ARE: A.) OLDER AMERICANS, B.) SERVICEMEMBERS, AND C.) OLDER SERVICEMEMBERS; HOWEVER, THERE IS NO ‘SPECIAL PROCESSING’ FOR THESE THREE DEMOGRAPHIC CATEGORIES. ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT PROCESS HAS NO CLEAR, AND UNAMBIGUOUS, DEFINITION FOR THE TERM "OLDER AMERICAN" CATEGORY, AND THE CFPB DATABASE SHOWS THAT "THE COMPANY" RESPONSES TO COMPLAINTS FROM SO-CALLED "OLDER AMERICANS", ARE VIRTUALLY THE SAME AS THOSE FOR OTHER CONSUMERS WITHOUT THIS DESIGNATION. IT IS CLEAR, THAT COMPLAINTS FROM THESE “PROTECTED CLASSES OF CONSUMERS” SHOULD BE TREATED DIFFERENTLY, BUT THIS DOES NOT APPEAR TO BE OCCURRING WITHIN THE CURRENT CFPB COMPLAINT PROCESS. Close and return "THE COMPANY" ALWAYS WIN!
XIII. OTHER CONSUMER COMPLAINT AGENCIES WITHIN THE FEDERAL GOVERNMENT APPEAR OBLIVIOUS TO THE GLARING, MAJOR FLAWS IN THE CFPB COMPLAINT PROCESS; AND CONTINUE TO “BLINDLY THROW CONSUMER COMPLAINTS OVER THE WALL TO CFPB”. ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT BETWEEN JANUARY 2011 AND APRIL 30, 2017, 130,671 OF THE 743,427 CFPB COMPLAINTS SENT TO "THE COMPANY" WERE REFERRED BY OTHER (UNNAMED) CONSUMER COMPLAINT/CONSUMER PROTECTION AGENCIES; HOWEVER, THE CFPB COMPLAINT DATABASE DOES NOT IDENTIFY THE FEDERAL, STATE, OR LOCAL AGENCIES FROM WHICH THESE COMPLAINTS WERE REFERRED; AND MORE IMPORTANTLY, NONE OF “THE COMPANY” RESPONSES TO THESE REFERRED COMPLAINTS WERE SENT TO THE REFERRING AGENCIES. UNFORTUNATELY, IT IS LIKELY THAT CFPB’S WILLINGNESS TO ACCEPT COMPLAINT REFERAL FROM OTHER GOVERNMENT COMPLAINT AGENCIES, RESULTS IN NON-FINANCIALLY RELATED COMPLAINT BEING “THROWN OVER THE WALL” BY OTHER AGENCIES; AND THIS “LET CFPB DO IT” MENTALITY CONTRIBUTES TO CFPB’S INABILITY TO ADEQUATELY-PERFORM ITS CORE COMPETENCIES. Close and return "THE COMPANY" ALWAYS WIN!
XIV. CFPB DOES NOT PUBLISH QUARTERLY OR ANNUAL REPORTS OF CFPB COMPLAINT RESPONSES BY: COMPANY, PRODUCTS, ISSUES, OR ANY OTHER CATEGORY. THESE TYPE REPORTS WOULD HELP CONSUMERS, AND REGULATORY AGENCIES IDENTIFY COMPANIES WITH UNEXPLAINED YEAR-OVER-YEAR INCREASES IN CFPB COMPLAINTS.ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT THE NUMBER OF CFPB CONSUMER COMPLAINTS AGAINST BANK OF AMERICA, N. A., REMAINED UNCHANGED BETWEEN 2015 AND 2016; CORRESPONDINGLY, THE NUMBER OF CFPB COMPLAINTS AGAINST WELLS FARGO BANK, N. A., INCREASED 8.3% DURING THE SAME PERIOD. THE PERCENTAGE OF CFPB COMPLAINTS “CLOSED WITH EXPLANATION” WAS ALSO DRAMATICALLY HIGHER AT WELLS FARGO, THAN IT WAS AT BANK OF AMERICA. Close and return "THE COMPANY" ALWAYS WIN!
XV. CFPB DOES NOT PUBLISH ANNUAL REPORTS OF RESPONSES BY: COMPANY, PRODUCTS, ISSUES, OR ANY OTHER CATEGORY. THESE REPORTS HELP CONSUMERS, AND REGULATORY AGENCIES IDENTIFY COMPANIES WITH UNEXPLAINED COMPLAINT INCREASES, SUCH AS THE THOSE WHICH OCCURRED IN 14 OF THE TOP 20 COMPANIES SHOWN BELOW: Close and return "THE COMPANY" ALWAYS WIN!
XVI CFPB DOES NOT PUBLISH REPORTS THAT IDENTIFY COMPANIES, WHO IGNORE, AND/OR REFUSE TO RESPOND TO CFPB CONSUMER COMPLAINTS.ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT 227 CFPB CONSUMER COMPLAINTS WERE SENT MOBILOANS, LLC., BETWEEN JANUARY 2011 AND DECEMBER 31, 2016; AND "THE COMPANY" DID NOT RESPOND IN A TIMELY MANNER TO ANY OF THESE COMPLAINTS; YET, BETWEEN JANUARY 1, 2017 AND APRIL 30, 2017, CFPB SENT 13 MORE CONSUMER COMPLAINTS TO "THE COMPANY", AND IT DID NOT RESPOND IN A TIMELY MANNER TO ANY OF THESE NEW COMPLAINTS. EVEN MORE ASTONISHING, THIRTY (30) MORE CFPB COMPLAINTS HAVE BEEN SENT TO THIS "PAYDAY LENDER" SINCE THE PROBLEM WAS BROUGHT TO THE ATTENTION OF CFPB IN MAY 2017; AND THERE IS NO RECORD THAT "THE COMPANY" HAS RESPONDED TO ANY OF THESE CONSUMER COMPLAINTS. (HOWEVER, GIVEN THE FACT THAT PAYDAY LENDING IS PRIMARILY "AN AFRICAN AMERICAN PRODUCT”; AND THERE IS NO RECORD OF CFPB EVER FILING ANY RACIAL DISCRIMINATION COMPLAINTS, IT IS UNDERSTANDABLE WHY CFPB HAS NEVER REFERRED THIS PAYDAY LENDER TO THE CIVIL RIGHTS DIVISION OF THE DOJ.) Close and return "THE COMPANY" ALWAYS WIN!
XVII. THE CFPB DCOMPLAINT PROCESS INCLUDES AN INTERNAL ENFORCEMENT DEPARTMENT, BUT THE CFPB DATABASE DOES NOT IDENTIFY THE CONSUMER COMPLAINTS REFERRED TO THIS AGENCY.ILLUSTRATIVE EXAMPLE: INFORMATION OBTAINED FROM CFPB UNDER THE FREEDOM OF INFORMATION ACT (FOIA) SHOWS THAT BETWEEN 2011 AND 2016, 21,198 CONSUMER COMPLAINTS WERE REFERRED TO OTHER AGENCIES BY CFPB, BUT ONLY TWO (2) OF THESE COMPLAINTS WERE REFERRED TO THE CFPB'S INTERNAL ENFORCEMENT AGENCY. GIVEN THE LARGE NUMBER OF IDENTITY THEFT, FRAUD, AND EMBEZZLEMENT COMPLAINTS FILED BY CONSUMERS DURING THIS PERIOD, IT IS UNFATHOMABLE THAT ONLY TWO COMPLAINTS WERE REFERRED TO THIS ENFORCEMENT AGENCY, AND NONE WERE REFERRED TO THE DEPARTMENT OF JUSTICE. Continued on next page "THE COMPANY" ALWAYS WIN!
XVII. THE CFPB DCOMPLAINT PROCESS INCLUDES AN INTERNAL ENFORCEMENT DEPARTMENT, BUT THE CFPB DATABASE DOES NOT IDENTIFY THE CONSUMER COMPLAINTS REFERRED TO THIS AGENCY. (Continued) Close and return "THE COMPANY" ALWAYS WIN!
XVIII. CFPB DOES NOT ANALYZE AND/OR PUBLISH MONTHLY, QUARTERLY, OR ANNUAL REPORTS CONTAINING CONSUMER COMPLAINT TRENDS, PATTERNS, AND/OR IRREGULARITIES.ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT ANNUAL COMPLAINT ANALYSIS AND REPORTING COULD POSSIBLY DETECT PATTERNS OF ILLEGAL AND/OR UNETHICAL ACTIVITIES BY COMPANIES, SUCH AS THE DRAMATIC INCREASE IN CFPB COMPLAINTS, RECEIVED FROM ONE UNNAMED NATIONAL BANK BETWEEN 2015 AND 2016. Close and return "THE COMPANY" ALWAYS WIN!
XIX. CFPB DOES NOT PUBLISH SUMMARY REPORTS SHOWING THE FINAL RESOLUTION OF CONSUMER COMPLAINTS ALLEGING CRIMINAL ACTIVITIES, SUCH AS IDENTITY THEFT, FRAUD, AND EMBEZZLEMENT.ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT IN 2016, THERE WERE MORE THAN EIGHTY-TWO HUNDRED OF THESE TYPE COMPLAINTS FILED BY CFPB. HIGH-PROFILES "COMPANIES" SUCH AS AMERICAN EXPRESS, BANK OF AMERICA, CAPITAL ONE, CITIBANK, AND JPMORGAN CHASE AND COMPANY, ACCOUNTED FOR 2,438 OF THESE COMPLAINTS; AND 1,522 THESE COMPLAINTS WERE DISPUTED IN GOOD FAITH BY CONSUMERS. HOWEVER, CFPB NOW ADMITS THAT THERE WAS NEVER A FORMAL DISPUTE PROCESS AVAILABLE IN THE CFPB COMPLAINT PROCESS; AND THEREFORE, THE FINAL DISPOSITION OF THE CONSUMER DISPUTES IS UNKNOWN. Close and return "THE COMPANY" ALWAYS WIN!
XX. CFPB DOES NOT PUBLISH ANNUAL REPORTS SHOWING THE FINAL RESOLUTION OF CONSUMER COMPLAINTS SUBMITTED BY RACIAL, ETHNIC, AND GENDER CATEGORIES. ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE DOES NOT INCLUDE THE DEMOGRAPHICS OF THE CONSUMERS WHO FILE COMPLAINTS VIA THE CFPB COMPLAINT PROCESS; AND THUS, IT IS VIRTUALLY-IMPOSSIBLE TO DETERMINE IF CFPB IS SERVING THE NEEDS OF "ALL AMERICAN CONSUMERS" ON A FAIR AND UNBIASED BASIS. THE ABSENCE OF THIS IMPORTANT DEMOGRAPHIC INFORMATION PREVENTS CFPB FROM DETERMINING WHICH DEMOGRAPHIC SEGMENTS OF CONSUMERS ARE TAKING ADVANTAGE OF THIS GOVERNMENT-FUNDED PROCESS, AND CONVERSELY, WHICH DEMOGRAPHIC SEGMENTS ARE BEING IGNORED BY CFPB. (THE ABSENCE OF RACIAL, ETHNIC, AND GENDER DEMOGRAPHICS, IS ONE OF THE GLARING PROBLEMS IN THE CFPB COMPLAINT DATABASE, AND IN THE CFPB COMPLAINT PROCESS. IDENTIFYING AND PREVENTING DISCRIMINATION IN THE FINANCIAL SERVICES INDUSTRY IS ONE OF THE ENDURING CHALLEGES FACED BY GOVERNMENT AGENCIES SUCH AS CFPB.) The omission of discrimination data from the CFPB Complaint Process and the CFPB Complaint Database was an overt policy decision delineated in the Disclosure of Consumer Complaint Data. A copy of this policy can be found at: http://files.consumerfinance.gov/f/201303_cfpb_Final-Policy-Statement-Disclosure-of-Consumer-Complaint-Data.pdf Close and return "THE COMPANY" ALWAYS WIN!
XXI. CFBP DOES NOT PUBLISH ANNUAL TREND ANALYSIS REPORTS DELINEATING CFPB COMPLAINTS ORIGINATING IN PREDOMINATELY-MINORIY COMMUNITIES. THESE COMPLAINTS ARE FOR PRODUCTS SUCH AS DEBT COLLECTION, MONEY TRANSFER, PAYDAY LOAN, AND PREPAID CARD.ILLUSTRATIVE EXAMPLE: THE CFPB COMPLAINT DATABASE SHOWS THAT BETWEEN 2011 AND 2017, 154,099 CFPB CONSUMER COMPLAINTS WERE FILED FOR PRODUCTS SUCH AS DEBT COLLECTION, MONEY TRANSFER, PAYDAY LOAN, AND PREPAID CARD, AND ONLY 3,866 (2.5%) OF THESE COMPLAINTS WERE "CLOSED WITH MONETARY RELIEF" BY "THE COMPANY"; DURING THE SAME PERIOD, 197,256 PRODUCTS SUCH AS BANK ACCOUNT AND SERVICE, CONSUMER LOAN, CREDIT CARD, AND OTHER FINANCIAL SERVICE, RECEIVED 33,160 (16.8%) "CLOSED WITH MONETARY RELIEF" FROM "THE COMPANY". THE DISPARITY BETWEEN THESE TWO PRODUCT SEGMENTS INDICATES THAT THERE IS A CLEAR DISTINCTION BETWEEN HOW "THE HAVES" AND "THE HAVE-NOT" CONSUMER SEGMENTS, ARE SERVED (OR NOT SERVED) BY THE CFPB CONSUMER COMPLAINT PROCESS. Close and return "THE COMPANY" ALWAYS WIN!
THE “COMPANY PORTAL” USED TO INTERNECT CFPB WITH THE COMPANY PROVIDES THE COMPANY WITH REALTIME, INTERACTIVE ACCESS TO CFPB COMPLAINT DATA, BUT THE CONSUMER IS NEVER INFORMED OF ITS EXISTANCE, AND TOLD WHAT PORTIONS OF HIS, OR HER, COMPLAINT DATA CAN BE ACCESSED BY “COMPANY”.ILLUSTRATIVE EXAMPLE: MOST CONSUMERS ARE UNAWARE OF THE FACT THAT CFPB TAKES “NO” ACTIVE ROLE IN THE REVIEW, AND ARBITRATION OF THEIR COMPLAINT, AND MAY BE WILLING TO SHARE MORE CONFIDENTIAL ELEMENTS OF THEIR COMPLAINTS WITH CFPB, THAN THEY WOULD SHARE WITH “THE COMPANY”. THE COMPLAINT NARRATIVE IS AN EXAMPLE OF THE COMPLAINT DATA THAT THE CONSUMER MAY NOT BE WILLING TO SHARE WITH “THE COMPANY”; BECAUSE IT MAY INCLUDES SOME EVIDENCE THAT WOULD BE USED IN A COURT PROCEEDING, IF THE COMPLAINT/CLAIM IS NOT RESOLVED BY CFPB, AND MUST BE ADJUDICATED IN THE COURTS. Close and return "THE COMPANY" ALWAYS WIN!
XXIII. THE CONSUMER COMPLAINT DATABASE CONTAINS 10,022 CONSUMER NARRATIVES, ALL OF WHICH WERE DISPUTED BY CONSUMERS, AND ALL BUT 22 OF THESE NARRATIVES WERE IN RESPONSES TO COMPLAINTS, CLOSED BY “THE COMPANY”, WITH A “CLOSE WITH EXPLANATION RESPONSE; THIS INDICATES THAT THERE WAS NEAR UNANIMOUS DISPUTE OF “THE COMPANY” RESPONSES TO THESE COMPLAINTS. . ILLUSTRATIVE EXAMPLE: Close and return "THE COMPANY" ALWAYS WIN!
XXIV. THE CFPB WEBSITE TOUTED THE SPECTACULAR SUCCESSES OF THE CFPB COMPLAINT PROCESS, BUT PROVIDED NO MECHINISM FOR MEASURING THE CONSUMER’S SATISFACTION (OR LACK THEREOF) OF THE COMPLAINT PROCESS. THE FINAL ACTION IN EACH CFPB COMSUMER COMPLAINT, SHOULD BE AN OPPORTUNITY FOR THE CONSUMER TO “RATE” THE PERFORMANCE AND EFFECTIVENESS OF THE CFPB COMPLAINT PROCESS , AND THE RESULTS OF THIS RATING SYSTEM SHOULD BE ADDED TO THE HOME PAGE OF THE CFPB WEBSITE. ILLUSTRATIVE EXAMPLE: THE FOLLOWING TABLE AND CHART IS FOUND ON THE WEBSITE OF THE OFFICE OF THE COMPTROLLER OF THE CURRENCY (OCC), AND MEASURES THE EFFECTIVENESS, AND THE CONSUMER SATISFACTON RATING OF THE OCC’S CUSTOMER ASSISTANCE GROUP (CAG): Close and return "THE COMPANY" ALWAYS WIN!
XXV. THE CFPB WEBSITE PRESENTS THE ILLUSION THAT THE CFPB COMPLAINT PROCESS IS PROTECTS CONSUMERS FROM UNSCRUPULOUS, UNETHICAL FINANCIAL SERVICES COMPANIES; HOWEVER, EVEN THOUGH, AS OF ARPIL 2017, THE CFPB DATABASE CONTAINED 743,427 COMPLAINTS, AGAINST 4,168 COMPLANIES, THE CFPB WEBSITE DID NOT HAD A SINGLE NEGATIVE REPORT ON ANY COMPANY; EVEN THOUGH MORE THAN TEN THOUSAND CONSUMERS DISPUTED THE CLOSED RESPONSES FROM COMPANIES, AND “CREATED CONSUMER NARRATIVES, TO EXPRESS THEIR DISPLEASURE OF THESE CLOSED RESPONSES BY “THE COMPANY”.ILLUSTRATIVE EXAMPLE: Close and return "THE COMPANY" ALWAYS WIN!