
Why don’t we act upon early indicators of change? Why do we discount “small volume as noise” when the rate of growth is undeniably significant? And why are we surprised when this rate of growth turns into a scalable problem a year or two later?
Early warning signals extracted from what our customers tell us make it possible for us to identify, understand, predict, and prevent growing customer issues.
When early warning signals could have made a difference
Just last week, federal regulators fined Bank of America $225 million for failing to control widespread fraud in the disbursement of state unemployment benefits.
Throughout 2020, Bank of America’s customers submitted complaints to the Consumer Financial Protection Bureau (CFPB) about the issues regulators raised. While the volume, at that time, was still small, the “shape of the curve” was worth noting and tracking. With proactive, ongoing systemic monitoring in place combined with “listening” to customers’ narratives, could the outcome have improved for Bank of America and its customers?

The power of triggers
What early warning signals are we seeing in today’s customers’ complaints submitted to the CFPB, and what resulting actions might we see in the next year or two?
The PositivityTech® intelligent platform’s proprietary triggers, algorithms that reveal leading indicators of environmental risks, pinpoint timely issues that may require preemptive management actions.
Currently, there are two significant — and different — issues with rising complaints from customers to the credit bureaus.
- What’s causing these issues?
- What are financial institutions doing about them?
Read on to explore these growing issues, and our findings related to them.
Growing Issue #1: “Improper Use of Your Report,” specifically “Reporting Company Used Your Report Improperly”
The PositivityTech visual below shows that complaints about this issue continue to grow exponentially, beginning in early 2022.

Growing Issue #2: “Unable to Get Your Credit Report or Credit Score,” specifically “Other Problem Getting Your Report or Credit Score”
The following PositivityTech visual shows that complaints about this issue grew significantly for more than six consecutive months.

Similar impact across the bureaus
In the past few months, TransUnion, Equifax, and Experian have experienced a similar rise in customer complaints related to these two issues.

Three states have the largest concentration of these complaints
Florida, Georgia, and Texas are seeing the greatest rise in customer complaints about these two issues.

Similar language within many of these complaints
Many submissions to the CFPB focused on the complaint, “Improper Use of Your Report,” use similar language and specifically reference the Fair Credit Reporting Act and codes specific to fair and accurate credit reporting. This may indicate that a large volume of these complaints are being submitted by credit repair companies on customers’ behalf, disputing the accuracy of credit reports.


Unusually high volume of complaints “in progress”
Companies usually respond to customer complaints in a timely manner.
- In looking at the complaint database over the last 10 years, approximately 6% of companies’ responses to consumers are “in progress.”
- In looking at the complaint database over the last year, approximately 15% of companies’ responses to consumers are “in progress.”
- In looking at the complaint database just for those complaints about “Improper Use of Your Report,” approximately 28% of companies’ responses to consumers are “in progress.”
Specifically, the number of “in progress” complaints in the last month is almost 30,000! And approximately one-third of these complaints are about “Improper Use of Your Report.”


What do PositivityTech triggers reveal about your institution?
As we all know, change happens. The important thing is knowing about change as early as possible and taking proactive action. PositivityTech’s triggers reveal changes while they’re still small and automatically send alerts to make sure they’re on your radar. That makes it possible for you to get ahead of issues, monitor and track progress, and raise awareness of potential problems before it’s too late.