Abstract

We show that consumers file more formal complaints after—rather than before—public enforcement actions by the Consumer Financial Protection Bureau (CFPB). Using synthetic difference-in-differences, we study the filing response to Wells Fargo’s September 2016 enforcement disclosure action. We estimate that monthly complaints rose by 70.6% of Wells Fargo’s pre-disclosure average over the following three months. The increase initially spanned products but persisted in the category most closely tied to the conduct described in the action. In that category, the complaint increase is accompanied by a 35.0-percentage-point deterioration in Wells Fargo’s relative timely-response performance. We extend our analysis to the first eligible CFPB action at each of 19 financial institutions using a category-matched staggered difference-in-differences design. We estimate a 40.8% increase in named-product complaints during the four weeks relative to the same categories at never-treated institutions. Together, the results show that public enforcement actions change which customer problems enter regulator-managed processes as formal complaints and that, at Wells Fargo, the disclosure action coincides with weaker monitored response performance.

Monthly Wells Fargo complaints and the SDiD comparison path

Two line charts compare Wells Fargo monthly complaints with synthetic difference-in-differences comparison paths. The series track each other before September 2016. Wells Fargo complaints then rise sharply for both total and bank-account complaints while the comparison paths remain stable.

Weekly timely response after complaints reach the company

Three line charts compare Wells Fargo timely-response rates with comparison institutions. Rates are similar before September 2016, then Wells Fargo rates fall sharply across all products, bank-account complaints, and account-management complaints. Comparison rates remain near 100 percent.

Complaints increase in the categories named by 18 unique CFPB actions

Event-study chart of complaints in categories named by Consumer Financial Protection Bureau actions. Estimates are near zero before the action and rise sharply in week 0. Post-action estimates remain positive, although several later confidence intervals include zero.

Citation

Osman, Syed Muhammad Ishraque, and Nicholas R. Pusateri. 2026. “To File or Not to File: Consumer Complaints After CFPB Enforcement Actions.” Working Paper. URL: https://www.nicpusateri.com/tfontf.

@article{osman2026file,
  title={To File or Not to File: Consumer Complaints After CFPB Enforcement Actions},
  author={Osman, Syed Muhammad Ishraque and Pusateri, Nicholas R.},
  journal={Working Paper},
  year={2026},
  url={https://www.nicpusateri.com/tfontf},
  }