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Public Disclosure and Consumer Financial Protection

Journal of Financial and Quantitative Analysis 2024 59(5), 2164-2198 open access
The U.S. Consumer Financial Protection Bureau has released a database of consumer complaints about banks’ financial products to the public since 2013. We find a greater reduction in mortgage applications to banks that receive more mortgage complaints in local markets after the disclosures. The effect is stronger in areas with more sophisticated consumers and higher credit competition, and for banks receiving more severe complaints. The number of monthly mortgage complaints per bank exhibits faster mean reversion after the publication of the database. These findings suggest that the public disclosure of mortgage complaints enhances product market discipline and consumer financial protection.

Does the CARD Act affect price responsiveness? Evidence from credit card solicitations

Journal of Banking & Finance 2024 164, 107199
The CARD Act restricts consumer credit card issuers’ ability to raise interest rates. We examine whether the Act influences the degree to which an issuer adjusts offered interest rates in response to changes in interest rates offered by other lenders in credit card solicitations—the price responsiveness. Using small business card offers as a control group, we find a significant decline in the price responsiveness after the Act. The decline is concentrated among other lenders’ rate reductions rather than rate increases and is more pronounced in areas with more subprime borrowers. The results underscore an unintended consequence of regulating the consumer credit market.

Learning from peers: Evidence from disclosure of consumer complaints

Journal of Accounting and Economics 2024 77(2-3), 101620
In 2013, the U.S. Consumer Financial Protection Bureau released a database of consumer complaints filed against banks under its supervision (“CFPB banks”). We find that after the disclosure, rival banks exhibit a greater increase in mortgage approval rates in markets with more intensive mortgage complaints about CFPB banks. The effect is weaker when rivals have more expertise in the local market, are less concerned about credit risk due to mortgage sales, and locate in areas with more alternative information about the CFPB banks. The effect is concentrated in severe complaints and complaints related to loan underwriting practices. In addition to approving more loans, rivals also open more branches and are more likely to post a job opening in these markets. The findings suggest that these banks learn from the nonfinancial disclosures about operational deficiencies of peers (i.e., CFPB banks) in local markets, which alleviates their adverse selection concern about expanding.