Abstract

In this paper we show that consumers file more formal complaints after—rather than before—public enforcement actions by the Consumer Financial Protection Bureau (CFPB). We study the filing response to Wells Fargo’s September 2016 enforcement disclosure in detail. A synthetic difference-in-differences design estimates a large increase in complaints against Wells Fargo during the following three months, equal to 70.6% of its pre-disclosure monthly average. The increase initially spans products but persists most clearly in the category that most closely matches the conduct described in the enforcement action. Comparing equal 12-week periods before and after the disclosure, a triple-difference design estimates a 35.0-percentage-point decline in timely response for Wells Fargo bank-account complaints relative to its other products and comparison institutions. We extend the broader analysis to the first eligible CFPB action at each of 19 financial institutions using a category-matched staggered difference-in-differences design, which estimates a 43.1% increase in named-product complaints during the action week and the following three weeks relative to the same product categories at 58 never-treated institutions. Together, the results show that public enforcement changes formal complaint flow entering regulator-managed processes and, at Wells Fargo, coincides with deterioration in 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},
  }