On May 21, the Consumer Financial Protection Bureau issued a report providing an analysis of the complaints it has received since the outbreak of the coronavirus (“COVID-19”) pandemic. Unsurprisingly, the number of complaints has increased dramatically.

The report shows that the CFPB received 36,700 consumer complaints in March and 42,400 in April, the two highest volumes in the Bureau’s history. Of these complaints, 4,500 referenced terms related to the crisis, including “COVID,” “coronavirus,” “pandemic,” and “CARES Act.” As a point of comparison, the CFPB received an average of 29,000 consumer complaints per month during 2019.

Although credit reporting and debt collection remain as the areas with the highest volume overall, complaints concerning mortgages and credit cards were the most likely to mention keywords related to COVID-19. Of the mortgage-related complaints, 22% referenced the pandemic and more than half of the consumers making such complaints indicated that they were struggling to make their monthly payments. Consumers making complaints concerning credit cards mentioned “the coronavirus” 19% of the time.

Consumers who reported their age as being at least 62 years old were more likely to raise COVID-19-related concerns. Nine percent of complaints submitted by older consumers were related to the pandemic as compared to six percent of the complaints submitted by the remainder of the population.

Common concerns raised by consumers included: (a) being unable to reach their creditors’ customer service representatives; (b) continued debt collection during the emergency; (c) that pursuing alternative payment options would result in negative credit reporting; and (d) having to make large, lump-sum payments to creditors at the completion of a forbearance period.

The increase in the number of complaints to the CFPB, as well as the nature of the issues raised, highlights the challenges faced by consumers and creditors alike as we continue to deal with the effects of the pandemic. It likely foreshadows a corresponding increase in consumer litigation. We will continue to monitor and report on the trends as the situation evolves.