CHASE MORTGAGE FRAUD AND RACIAL/ETHNIC DISCRIMINATION PRACTICES.

2004-Chase Predatory Lending, Mortgage Loan Fraud, Racial/Ethnic Discrimination

Chase Loan Oorigination and RMBS Securtiization Fraud

Overview of CFPB Consumer Complaint Process

Saving the CFPB CFPB Complaint Process

Company-Centric Design Flaws in CFPB Complaint Process

COMPANY-CENTRIC DESIGN OF THE CFPB COMPLAINT PROCESS:

"THE COMPANY" CONTROLS THE CFPB COMPLAINT ARBITRATION PROCESS, AND CFPB TAKES NO ACTIVE ROLE IN THE CONSUMER COMPLAINT RESOLUTION PROCESS! HOWEVER, CFPB ALWAYS BLINDLY ENDORSES "THE COMPANY'S" ADJUDICATION RESPONSE WITH ITS KISS OF DEATH APPROVAL AND THEN CLOSES THE COMPLAINT BY BANISHING IT TO THE CFPB COMPLAINT "BLACKHOLE," FROM WHICH IT WILL NEVER ESCAPE.

One of the Driving Forces for the Creation of CFPB was the 2004 to 2008 Subprime Lending Crimes perpetrated upon innocent African Americans, Hispanics, Latinos, and other Financially-Distressed American Citizens.

CFPB Solution to Dispute of The Company's Complaint adjudications: "LET THEM EAT CAKE!"

CFPB plays no role in the COMPLAINT ADJUDICATION PROCESS: "THE COMPANY" IS THE JUDGE, jURY, AND APPELLATE!
FINANCIAL SERVICES INSTITUTIONS, NATIONAL BANKS, and others ARE CURRENTLY LOBBYING FOR THE SHUTDOWN OF THE CFPB COMPLAINT SYSTEM, BUT THEY DO NOT REALIZE THAT "THEy" WINS MORE THAN EIGHTY PERCENT OF THE COMPLAINTS FILED BY CONSUMERS; AND THAT CFPB, RUBBER-STAMP'S "theIR" response more than ninety-three percent of the time! "THE COMPANY" CURRENTLY HOLDS ALL THE CARDS, AND ARE THE PROVERBIAL: "JUDGE, jURY, AND EXECUTIONER" OF COMPLAINTS RECEIVED VIA THE CFPB COMPLAINT PROCESS.

Current Initiatives by some large financial services companies, and national banks to weaken (or even abolish) the CFPB Consumer Complaint process, is the classic example of: "Killing the Golden Goose"; because as of April 2017, the more than seven hundred and forty-three thousand consumer complaints contained in the CFPB Complaint Database, shows that: "THE COMPANY ALWAYS WIN!" Some of the many glaring examples that corroborate this hypothesis include:

The CFPB Complaint Process includes an "INSIDIOUS ALL-SEEING, ALL-KNOWING COMPANY PORTAL" by which it connects to more than four thousand financial services companies. This omnipresent portal is not mentioned in any consumer-related documentation; even though it, along with the CFPB Complaint Database, underpins the CFPB Consumer Complaint process. The "portal" is a web-based, interactive information channel between CFPB and "The Company"; and

Although the CFPB Complaint Process documentation still includes terms such as "sending CFBP complaints to The Company" or uploading complaint data to "the Company,"; the reality is that all of the more than forty-two hundred registered companies have instantaneous access to CFPB Complaint data residing in the Company Portal, and; this "all-seeing, all-knowing portal" provides the "The Company" with instant, real-time access to all CFPB complaints filed by consumers; thus, it can re-use arbitration responses that it previously used for similar complaints, as well as "canned" responses such as: a.) we have yet responded to this issue, b.), please contact your servicer regarding this issue and c.) we do not discriminate.

These companies are solely responsible for the arbitrating and closing all consumer complaints they received via Company Portal, and;

CFPB "Rubber-Stamped" the Company responses, more than 93% of the time,

More than seventy-three percent of all consumer complaints are "Closed with Explanation," by the Company; with no "Monetary Relief" for the consumer, and;

The annual ranking of Companies based upon the number of complaints received, percentage of complaints "Closed with Explanation," and percentage of complaints "Closed with Monetary Relief', are not shared by CFPB, and;

More than ninety percent of the Company responses to consumer complaints are not publicly shared, and this allows many the Company to reject, and "Close without explanation," more than ninety percent of all CFPB consumer complaints received, without drawing the attention of other federal or state consumer protection/consumer complaint agencies, and;

There is no dispute or escalation procedure available to consumers who disagree with the response received from the Company, and;

For all intentional purposes, consumers who filed complaints with CFPB, and had their complaints rejected and closed by the Company; inadvertently-eliminates all future options of filing the same complaint with CFPB, or other federal, state, or local consumer protection/consumer complaint agencies, and;

The CFPB "Stamp of Approval" of the Company response, can be referenced by the Company, in its responses to future CFPB complaints from the same consumer (or other consumers), and, finally;

Other federal consumer complaint agencies, such as the Consumer Assistance Group (CAG) of the Office of the Comptroller of the Currency (OCC), continue to refer consumer complaints (i.e., "Blindly throw consumer complaints over-the-wall") to CFPB, even though they have been alerted again, and again, and again of dozens of architectural and process flaws in the CFPB Complaint Process.

Click HERE view more details regarding the Company-Centric CFPB Complaint Process.

The CFPB's: "The Company is Always Right Approach", to resolving consumer complaints, is an overt, blatant contradiction to CFPB fiduciary responsibility as defined in the Dodd-Frank Wall Street Reform, and Consumer Protection Act of 2010. This Act empowered CFPB with the responsibility to ensure that financial-related consumer complaints, filed by American consumers, were arbitrated on a fair and impartial basis.

"THE COMPANY ALWAYS WINS!"
THE CFPB COMPLAINT DATABASE SHOWS THAT The ratio of Consumer Complaints "Closed with Explanation" versus Consumer Complaints "Closed with Monetary Relief" is more than 10:1 for all COMPLAINTS; AND AS HIGH AS 30:1 FOR MORTGAGE-RELATED COMPLAINTS.
During the period in question from between January 2012 and April 2017, the CFPB Complaint Database shows that:

553,374 (74.44%) of the 743.427 consumer complaints were "Closed with Explanation" by the Company, and;
49,609 (6.67%) of the 743,427 consumer complaints were "Closed with Monetary Relief" by the Company.

As incredible as the above "Closed with Explanation" responses from Companies are; the "Closed with Explanation" responses for Mortgage complaints are even higher:

157,316 (89.42%) of the 175,934 consumer mortgage complaints were "Closed with Explanation" by the Company, and;
4,952 (2.81%) of the 175,934 consumer mortgage complaints were "Closed with Monetary Relief" by the Company.
This is a 31:1 ratio of Closed with Explanation versus Closed with Monetary Relief responses from the Company. (Click HERE for additional Top-10 mortgage complaint statistics.)

Additionally, between January 2012 and April 2017, consumer disputed 145,150 (19.5%) of the 743,427 responses received from the Company; and apparently, none of these complaints resulted in further actions upon the consumers' behalf by CFPB. (It is important to note; that the CFPB Freedom of Information Act (FOIA) Office disclosed that CFPB referred 21,198 consumer complaints to other agencies during the period in question; however, because these referrals were not tracked in the CFPB Database, it is unclear if these referrals were based upon consumer complaints or CFPB actions. (A summary of these CFPB Referrals can be viewed HERE.)

Other Major Problems Found in Flawed-CFPB Complaint Process
Some of the most glaring problems we found within the CFPB Complaint Process include:

Companies are allowed to arbitrarily close complaints even though consumers have formally disputed the Company Response. In most instances, the consumer's disputes include additional documentation that further authenticates and/or strengthen their original complaint. Between 2011 and March 26, 2017, consumers disputed more than one hundred and forty-five thousand Company responses, and there are no records in the CFPB Complaint Database that any of these disputes were ever reviewed by CFPB Reviewers, before being discarded. (Click HERE to see a list of all consumer complaint disputes by Company, by year.)
The Company is allowed to specify whether, or not; its response to a consumer can be shared publicly; and if they choose to not share this information, consumers have no awareness of similar complaints filed by other consumers.(More than ninety-three percent of all Company responses, were not shared publicly. See table below entitled: "Company Responses Sent to CFPB and Consumers, but not Shared Publicly", to see annual percentages of Company responses not shared publicly. (When Companies do not share their responses to consumer complaints publicly, it is virtually-impossible for consumer protection agencies to track and analyze patterns of potentially-fraudulent and/or criminal behavior by Companies.)
Complaints referred by other consumer complaint agencies, do not receive any special treatment, even though they have already been reviewed before being referred to CFPB; additionally, it does not appear that the Company is made aware of the fact that these complaints were review by another agency before being referred to CFPB. Finally, when the Company closes the complaint, the response by the Company, is not forwarded to the referring consumer complaint agency, and if another consumer files an identical complaint, there is no ability of the referring agency to inform this consumer of the results of the prior complaint(s).
The CFPB Consumer Complaint Database includes ninety-five issues, which can be used by consumers to file complaints with more than forty-one hundred companies; however, all of these issues appear to be given the same CFPB ranking and/or priority. As this implies, all of these ninety-five issues are treated equally, in the CFPB complaint process; for example, it appears that a five-hundred dollar pay-day loan complaint is treated the same as a five-hundred thousand dollar home mortgage loan complaint. (Click HERE to see a list of all CFPB complaint issues.).

Complaints alleging serious, and possibly felonious, violations of federal and state laws are apparently handled the same as all other consumer complaints, and theoretically, there could be dozens, if not hundreds, of similar complaints against a Company; and CFPB would never refer any of these alleged criminal activities to its internal enforcement unit, or to other law enforcement agencies.(Click HERE to view all CFPB Consumer Complaint actions for these Identity theft, Fraud, and Embezzlement complaints.)

Click HERE to see the top-twenty reasons why the CFPB Complaint Process does not work.

When a consumer Files A COMPLAINT via the CFPB complaint process, it is frequently THE PROVERBIAL "THE KISS OF DEATH" for not only that COMPLAINT; but it virtually eliminates the probability that similar complaints from other consumers will receive a fair and objective arbitration!

Filing a consumer complaint against a Company with CFPB, (or other federal agencies that, frequently and unceremoniously, "throw consumer complaints over the wall" to CFPB), is the proverbial "Kiss of Death" to the complaint. As the following Mortgage Complaint table shows, in the vast majority of instances, the Company simply rejects the consumer complaint, and sends a "Closed with Explanation Response to CFPB; and then the Company is virtually-immune to any future CFPB-related actions from the consumer. Furthermore, the Company can explicitly-request that its response to this complaint not be shared publicly, and then used the CFPB-approved "Closed with Explanation" response, to respond to dozens, or even hundreds of identical (or similar) complaints from other consumers. The fact that the Company chose not to share these responses publicly, means that consumers, and other consumer complaint/consumer protection agencies, have no awareness of the fact that a given consumer complaint was previously-filed with the CFPB dozens, in some cases hundred, of times.

Responses to Complaints against All Mortgage Companies
Closed Response	Year Complaint Filed				Total Complaints	Percent Complaints
Closed Response	2013	2014	2015	2016	Total Complaints	Percent Complaints
Closed	1569	952	1177	882	4580	2.60%
Closed with explanation	42723	39286	37685	37622	157316	89.42%
Closed with monetary relief	1323	1050	1300	1279	4952	2.81%
Closed with non-monetary relief	3760	1633	2122	1571	9086	5.16%
Grand Total	49375	42921	42284	41354	175934	100.00%
Source: CFPB Consumer Complaint Database at:http://www.consumerfinance.gov/data-research/consumer-complaint

Although the almost ninety percent "Close with explanation" response rate for all mortgage companies is outrageous; "Close with explanation" responses from other Top-10 Mortgage Companies are as high as 98.57%. Click HERE to see more Close with explanation responses from the Top-10 Mortgage Companies..

REGARDLESS OF THE METHOD USED BY CONSUMERS TO FILE COMPLAINTS VIA "THE FLAWED-CFPB COMPLAINT PROCESS"; THE RESULTS ARE ALWAYS THE SAME, "The Company "THE COMPANY ALWAYS WIN!"

During much of the Twentieth Century, there was a long-accepted axiom that "The Customer Is Always Right"; and while this adage usually applied to customer complaints, and was most prevalent within segments the retail industry; many other industry segments, including the financial services and mortgage lending industries, adopted this "golden rule" as a core business principle. From the consumer's perspective, this changed within the mortgage industry during the previous decade, when this industry was inundated by hordes of new predatory subprime lending institutions. In this new hyper-competitive environment, even large financial services corporations, and National Banks were "forced to bend the rules" in order to remain competitive. The CFPB Consumer Database, used to create this "Consumers for Consumers" website, vividly illustrates that "The Customer Is Always Right" has been supplanted by a new axiom that "The Company Always Wins". From January 1, 2012, through March 26, 2017, the CFPB Complaint Database shows that 743,427 consumer complaints were submitted to the CFPB Complaint Process. The origin of these consumer complaints were:

Email:	348
Fax:	10,619
Phone:	51,038
Postal Mail:	47,329
Referral from other agencies:	130,671
Web:	503,422
Total	743,427

The six-year history of the more than forty-one hundred companies to which CFPB filed consumer complaints can be viewed: HERE, and the companies' responses to these consumer complaints viewed HERE.

The Collaboration BETWEEN CFPB, AND other federal Consumer Complaint Agencies VIA THE CFPB CONSUMER COMPLAINT PROCESS FACADE.

An analysis of the 2011 through 2017 consumer complaint contained in the CFPB Complaint Database show that some Consumer Complaint Agencies, Consumer Protection Agencies, and even Civil Rights Agencies, are not Fulfilling their Fiduciary Responsibilities to American Citizens, by Indiscriminately throwing Consumer Complaints "Over The Wall" to a Defective-CFPB Consumer Complaint Process.

In many instances, consumer complaints are "Blindly Thrown Over the Wall to CFPB"; even though the CFPB Complaint Database shows that the so-called CFPB Complaint Process allowed Companies to prevail in more than Eighty Percent of all complaints filed between 2011 and 2017.

In 2012, during its first full year of operation, CFPB received slightly over seventy-two thousand consumer complaints; and the annual number of complaints received by CFPB has steadily increased, to the point where there were more than one hundred and ninety-one thousand consumer complaints processed in 2016. As this rapidly increasing number of CFPB complaints illustrates, consumers have become increasingly dissatisfied, and more cynical of the quality and fairness of the financial products and services that they are being offered; and are registering their displeasure, by filing complaints with federal, state, and local consumer complaint agencies. However, the spectacular successes claimed by CFPB have resulted in a "LET CFPB DO IT" approach to resolving consumer complaints, and today, federal, state, and local consumer protection agencies rarely pursue complaints and/or claims against Companies, and virtually all federal consumer complaints are thrown over the wall to CFPB. Our analysis of the Top-10 Companies to which CFPB filed consumer complaints shows that:

The Top-20 Companies accounted for 94,428 of the total 130,671 referred complaints for all Companies, and;
15,935 of the responses to consumer complaints referred to these Top-20 Companies were disputed by consumers. (Paradoxically, in May 2017, CFPB admitted that these so-called consumer complaint disputes, were only used for Consumer Feedback purposes, and played no role in the consumer complaint process.)

Annual consumer complaint analysis of Top-20 Companies are shown in a series of tables below. Additionally, complaint analysis summaries of: the Top-10 Companies can be found HERE; and the Top-10 Mortgage Companies, by clicking HERE.

NO Discrimination-related Complaints are INCLUDED IN THE CFPB COMPLAINT DATABASE, AND ARE not supported BY CFPB Complaint Process!

CFPB WORK INCLUDE:

q Rooting out unfair, deceptive, or abusive acts or practices by writing rules, supervising companies, and enforcing the law.

q Enforcing laws that outlaw discrimination in consumer finance.*

q Taking consumer complaints*.

q Enhancing financial education.

q Researching the consumer experience of using financial products.

q Monitoring financial markets for new risks to consumers.

* Primary responsibilities of CFPB Complaint Process.

Although, one of the key drivers behind the Dodd-Frank Wall Street Reform and Consumer Protection Act was to provide a fair, and equal playing field upon which all consumers would have access to Fair Lending and Equal Credit Opportunities. However, something was lost between the enactment of this Act into law, because the CFPB Complaint Process, and the CFPB Complaint Database are devoid of any mention of racial, ethnicity, gender, or religious discrimination. The only demographic-type information contained in the CFPB Complaint Database is: older Americans, servicemembers, and older servicemembers; but it is unclear iF this information was included in the complaints sent to Companies. Click HERE to review the CFPB Credit Discrimination Policies. (This document can also be found online under the heading: Addressing credit discrimination at: https://www.consumerfinance.gov/about-us/blog/addressing-credit-discrimination/.)

Discrimination, in particular, racial discrimination continues to be one of the greatest problems in America; yet none of the ninety-six ISSUES included within the CFPB complaint process, are for the multitude discriminatory practices that exist within today’s US financial services industry. CFPB was formed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2011; which was intended to ensure that the American consumer had a mechanism for seeking arbitration and mediation of their financially-related complaints against predatory, fraudulent, and frequently criminal practices of unfettered financial services institutions, unregulated non-banks, regulated national regional, and unregulated state and local banks. The following seven points from the CFPB-own Credit Discrimination Guidelines, makes it clear that this Act intended to provide a level financial playing field for all American consumers, regardless of race, ethnicity, gender, and religion.

Review lenders’ policies, procedures, and lending activity to detect and address potential discriminatory practices.
Bring enforcement actions to stop discriminatory practices and remedy harm to consumers.
Develop new policies, including rules about loan data collection required by Congress. These data will help ensure that lenders make credit available in a fair and non-discriminatory manner.
Partner with private industry and fair lending, civil rights, consumer, and community advocates to promote fair lending compliance and education.
Help ensure that consumers have the tools they need to make sound financial decisions and protect themselves from discriminatory practices.
Assist in reviewing consumer complaints of unlawful discrimination. We can also review complaint patterns for early warnings about troubling lending practices. This data will help us in our supervision, enforcement, rule writing, and education efforts.
Conduct research and analysis on equitable access to credit. This will include analyzing data collected under Federal regulations.
Work with the Department of Justice, Department of Housing and Urban Development, Federal Trade Commission, and other federal and state agencies to make sure that our fair lending enforcement efforts are consistent, efficient, and effective.

However, it appears that something was lost during the translation of the discriminatory credit policies listed above, and the actual implementation of the CFPB Consumer Complaint Process, because nothing in the more than seven hundred and forty-three thousand CFPB complaints included in the CFPB Database, can be specifically-associated with racial, ethnic, gender, or religious discrimination. Additionally, during the six years that CFPB has existed, none of the twenty thousand plus consumer complaints that have been referred to other federal, state and local agencies, none have been referred to the CFPB’s Office of Civil Rights, or the Civil Rights Office within the Department of Justice.

"No Discrimination-Related Issues, or Sub-Issues, are included in the Current CFPB Complaint Process!"*

It is highly probable that during the past six-plus years, tens of thousands of consumers have attempted to file discrimination-related complaints via the CFPB Complaint Process, alleging some form of racial, ethnic, gender, age or religious discrimination; however, because there are no discrimination-related "Issues or Sub-Issues" within the CFPB Complaint Process, the only way these discrimination-related claims can be sent to "the Company", is in appended text-based narratives. (Given "the Company is A Right" biases ingrained in the CFPB Complaint Process, the Company is only required to respond to the Issues and Sub-Issues of the complaint; and thus, there are no motivations for "the Company" to respond to appended consumer complaint narratives.)

* See BUREAU OF CONSUMER FINANCIAL PROTECTION (Docket No. CFPB-2012-0023) Notice of final policy statement for the justification for not including discrimination-related data in the CFPB Complaint Database.

Click HERE to see a summary of all Issues and Sub-Issues in consumer complaints from January 2011 through April 2017.

Also, click HERE to see a printable list of ninety-five Issues that are included in the CFPB Complaint Process.

Read more regarding why "The CompanyAlways Wins"!

©This website was developed as an information source for 'American Consumers', and is not affiliated with CFPB or any other government agency. The primary source of the 'public-interest information' in this website, is public domain information contained in the CFPB Consumer Complaint Database located at: http://www.consumerfinance.gov/data-research/consumer-complaints. This public domain Information is being presented AS-IS, without warranty. Protecting the privacy and confidentiality of the consumer information on this site was one of the overriding-tenants of the site developers, and no information contained on this site should be modified or altered in any way without written consent of the website owners. Please direct all questions and comments to cfpbcomplaintmonitor.org.