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Breach of

Trust:
CFPB’s Complaint Database Shows
Consumers Need Help After Equifax Breach

Prepared by the Offices of


Senators Elizabeth Warren, Brian Schatz
and Robert Menendez
April 2018
Inhalt

Executive Summary.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Findings. .... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

I. Consumer Complaints about Improper Use of Credit Reports.. . . . . . . . . . 3

II. Consumer Complaints about Incorrect Information


on Credit Reports. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

III. Consumer Complaints about Equifax’s Inadequate Assistance


Resolving Problems After the Breach. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

IV. Consumer Complaints about Fraud Alerts, Security Freezes,


Credit Monitoring, or Identity Theft Support Services.. . . . . . . . . . . . . . . . . . . 5

V. Other Consumer Complaints.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

VI. Conclusion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Endnotes. ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Breach of Trust: CFPB’s Complaint Database Shows Consumers Need Help After Equifax Breach

iii Prepared by the Staffs of Senators Elizabeth Warren, Brian Schatz and Robert Menendez
Breach of Trust: CFPB’s Complaint Database Shows Consumers Need Help After Equifax Breach

iv Prepared by the Staffs of Senators Elizabeth Warren, Brian Schatz and Robert Menendez
Executive Summary credit card numbers, birth dates, social security
numbers, and other personal information belonging
On September 7th, 2017, Equifax announced that it had to millions of Americans
allowed hackers to access the sensitive information of
more than 143 million Americans in one of the largest • The CFPB received more than 7,000 complaints
security breaches of consumer data in history. In the of incorrect information on a credit report, a
wake of that breach, Equifax promised to make things problem made significantly more prevalent by the
right. increased risk of identity theft in the aftermath of
the Equifax breach
Almost immediately, consumers used the Consumer
Financial Protection Bureau’s (CFPB) consumer • The CFPB received more than 3,000 complaints
complaint hotline to register problems and concerns about Equifax’s inadequate assistance in resolving
with the breach and Equifax’s response to it. This problems after the breach, highlighting Equifax’s
analysis contains the first comprehensive review of inability or unwillingness to assist consumers with
consumer complaints in the wake of the Equifax breach. their concerns
It finds that, in the six months following the breach’s • The CFPB received more than 1,500 complaints
announcement, the CFPB received more than 20,000 regarding Equifax’s credit monitoring services,
complaints from consumers about the impact of the fraud alerts, security freezes, and other identity
breach, problems with the Equifax response, or other theft protection products, demonstrating the
issues with the company – nearly double the amount of company’s inadequate consumer support services in
complaints received regarding Equifax in the six months the wake of the breach
prior to the announcement.
Consumers are facing myriad problems even six months
The number and nature of these complaints is after the breach, and continue to seek assistance from
particularly important because of public reports that the CFPB. Specific complaints reported by consumers
cast doubt upon the CFPB’s investigation of Equifax included:
and the agency’s commitment to assist consumers and
address the fallout of the breach. In early February, • A consumer who had their “opportunity for
reports indicated that the CFPB, under the new employment…denied because of [their] Equifax
leadership of Office of Management and Budget (OMB) credit report,” and despite apparently proving that
Director Mick Mulvaney, had declined to collaborate fraud had led to the false accounts being placed on
with other regulators in investigating Equifax and may their file, was unable to get help after Equifax “re
have abandoned its own investigation. While the CFPB inserted” both accounts onto their report.
has confirmed that an inquiry is still open, reports
suggest that the agency has slowed down or stalled the • A consumer who, in the wake of the breach “was
investigation into the Equifax breach and its impact on redirected to call 6 different phone numbers,” and
consumers. when they were unable to get additional assistance
from Equifax, their finances were “frozen for over a
This report concludes that, based on the thousands of month,” causing them “extreme hardship.”
complaints received by the agency, the CFPB should act
quickly and aggressively to hold Equifax accountable. • Consumers who were materially injured by
Specific findings include: Equifax’s negligent cybersecurity and reckless
response to the breach. One consumer faced
• In six months between September 7, 2017, problems with their Equifax credit report that were
when Equifax announced the breach of sensitive “damaging [their] credit rating” when they were “in
consumer information, and March 7, 2018, the process of buying a house.”
consumers have filed more than 20,000 complaints
regarding Equifax • Another consumer who, after learning that their
“information was part of the Equifax breach,”
• The CFPB received more than 7,000 complaints of was unable to get Equifax to remove fraudulent
improper use of a credit report after the breach, accounts and inquiries from their report despite
the risks of which jumped after Equifax exposed

Breach of Trust: CFPB’s Complaint Database Shows Consumers Need Help After Equifax Breach

Prepared by the Staffs of Senators Elizabeth Warren, Brian Schatz and Robert Menendez 1
trying “multiple times,” even filing a police report In his response to Senator’s Warren’s September 2017
over the false accounts listed on their report. letter to the CFPB, former Director Richard Cordray
outlined the bureau’s authority over Equifax and
• Another consumer who complained that Equifax efforts to investigate the breach and assist consumers.
had not contacted them to provide assistance with He described the CFPB’s “authority…to review the
similar problems, specifically adding that “I have data security practices of financial institutions…
been a victim of identity theft and I have suffered to determine whether such practices violate Federal
from the credit breach.” consumer financial laws…which include prohibitions
Equifax continued to keep important information on unfair, deceptive, or abusive acts and practices.”5 He
from the public, leaving consumers to fend for added that the CFPB “is the only Federal agency that
themselves. This report provides strong evidence that has any supervisory authority over the larger consumer
the CFPB must hold the company accountable and act reporting companies.”6
decisively to protect the millions of consumers harmed
by this breach. Director Cordray also noted that the “recent breach
at Equifax poses an enormous threat to consumers,”
Introduction and given that risk, informed Senator Warren that
the bureau was “currently looking into the data breach
On September 7, 2017, Equifax announced that it had and Equifax’s response.”7 More specifically, he claimed
allowed hackers to access the sensitive information that the bureau was “working with our Federal and
of more than 143 million Americans in one of the state partners to respond to the problems at Equifax,”
largest security breaches of consumer data in history.1 including through efforts with other banking regulatory
After failing to adopt strict cybersecurity measures agencies.8 Director Cordray committed that the CFPB
to protect valuable consumer data, Equifax then would “continue to examine and investigate consumer
mishandled the aftermath of the breach, failing to reporting companies,” adding that “a breach of this
properly assist consumers, and in some cases, making magnitude calls for a coordinated response.”9
the situation even worse. The company waited 40
days to alert consumers and regulators; initially asked Despite the severe threat to consumers and the
that consumers waive their rights to file lawsuits just authority and responsibility of the CFPB to investigate
to receive free credit monitoring services; increased and respond to such threats, recent reports indicate
their profits through their partnership with LifeLock that under the control of Office of Management and
because of the ensuing rush for credit protection; and Budget Director Mick Mulvaney, the agency may have
set up frustrating and ineffective call centers and other slowed down or stalled its investigation into the Equifax
consumer support measures.2 breach. The investigation has reportedly “sputtered
since” Mr. Mulvaney took over at the CFPB, because he
Five months after the breach, reports indicated that has “not ordered subpoenas against Equifax or sought
Equifax was continuing to withhold information sworn testimony from executives,” both of which are
from the public about the extent of the breach. We “routine steps when launching a full-scale probe.”10
still do not fully understand the scope of the harm Furthermore, reports suggest that the CFPB “rebuffed
to consumers or what measures Equifax is taking to bank regulators…when they offered to help with on-
avoid such catastrophic failures of cybersecurity and site exams of credit bureaus,” despite former Director
consumer support in the future. Cordray making it clear that this cooperation was both
The Consumer Financial Protection Bureau was necessary and welcome.11
established by the Dodd-Frank Wall Street Reform and In response to our inquiry, Mr. Mulvaney stated that
Consumer Protection Act in order to enforce federal “it is a matter of public record that the Bureau is
consumer protection laws. The CFPB is responsible looking into Equifax’s data breach and response,” and
for protecting consumers from “unfair, deceptive, or that any claims that there is no such investigation “are
abusive acts and practices.”3 The CFPB also has clear incorrect.”12 But Mr. Mulvaney did not specify whether
supervisory authority over large consumer reporting the reporting about the sluggishness of his investigation
agencies, including Equifax.4 is correct. Mr. Mulvaney also did not comment on

Breach of Trust: CFPB’s Complaint Database Shows Consumers Need Help After Equifax Breach

2 Prepared by the Staffs of Senators Elizabeth Warren, Brian Schatz and Robert Menendez
whether the CFPB had stopped examining credit consumers filed 21,921 complaints regarding Equifax.17
bureaus, or whether it had rejected offers of assistance In the six months prior to the announcement, consumer
from other bank regulators. filed only 11,973 complaints.18
Mr. Mulvaney has stated that the bureau “will be I. Consumer Complaints about Improper
focusing on quantifiable and unavoidable harm to
the consumer,” and that “quantitative analysis” would Use of Credit Reports
drive the work, stating, “there’s a lot more math in our As of March 7, 2018, the CFPB had received 7,448
future.”13 Mr. Mulvaney also told his employees that complaints over the improper use of a credit report
“we will be prioritizing[,]” – and specifically cited – the since Equifax announced the data breach in September
number of complaints received on certain issues as a 2017.19
factor that would determine investigative priorities.14
The CFPB’s consumer complaint database collects Under the Fair Credit Reporting Act (FCRA), only
complaints from consumers around the country on certain individuals may request and receive a consumer
a variety of issues, offering a quantitative look at the credit report, and they can only do so for certain
problems plaguing consumers. As Mr. Mulvaney noted, “permissible” reasons.20 If a credit reporting agency
the database should serve as a guide for the bureau. provides a consumer’s report to the wrong person or
company, or to a permissible individual without the
This report does the math. It analyzes data and proper justification, this violates the FCRA. This
individual complaints from the CFPB’s consumer category of complaints includes several sub-categories,
complaint database in order to determine the extent such as “Reporting company used your report
of the impact of the Equifax breach on consumers, the improperly” and “credit inquiries on your report that
effectiveness of the CFPB response, and whether this
you don’t recognize.”21
data justified a CFPB investigation. Staff reviewed
complaints that mention “Equifax” between September After the Equifax breach, the data of more than 145
7, 2017, the day the breach was announced, and March million Americans was at risk – for many consumers,
7, 2018. Staff also read through individual complaints that includes credit card numbers, names, birth dates,
to understand the issues facing consumers. addresses, and driver’s license numbers. When a thief
obtains a consumer’s information, they can use it to
Findings apply for a loan in the consumer’s name, apply for a
credit card, file fraudulent income tax returns, or even
The results of this staff review of CFPB complaints make purchases. If a thief uses a consumer’s PII to apply
about Equifax reveal that consumers filed 21,921 for a credit card, for example, the financial institution
complaints in the six months after Equifax announced will request the consumer’s credit report from Equifax.
the massive breach of consumer data – nearly double That’s just one example of how the Equifax breach could
the amount of complaints related to Equifax in the lead to a consumer complaint over improper use of their
six months preceding the announcement – and more credit report.
complaints arrive every day.15 And while complaints
regarding Equifax nearly doubled, consumer complaints In December, three months after the Equifax breach,
filed regarding the company’s competitors, TransUnion one consumer noted that they had “several inquir[i]es
and Experian, remained roughly the same or increased on my credit report from this company,” even though
only slightly during the same period.16 they “never authorize[d] for them to pull my credit.”22
This presented a huge problem, since the requests were
From September 7, 2017 through March 7, 2018 – the “damaging [their] credit rating” when they were “in
six months after Equifax announced the breach – the process of buying a house.”23 Another consumer
complained of a similar problem, and specifically
CFPB Complaints about Equifax Doubled after the Security Breach
added that “I have been a victim of identity theft and
Six Months I have suffered from the credit breach.”24 Despite this
after breach complaint, the consumer was frustrated that “the
Six Months credit bureau and creditor” did not contact them to
before breach
0 5000 10000 15000 20000
provide assistance.25

Breach of Trust: CFPB’s Complaint Database Shows Consumers Need Help After Equifax Breach

Prepared by the Staffs of Senators Elizabeth Warren, Brian Schatz and Robert Menendez 3
Another complaint from December came from a their “information was part of the Equifax breach,” and
consumer who had “a very difficult year with credit despite filing a police report for thousands of dollars in
in every way you could think of,” and was frustrated false accounts listed on their credit report, still could
that Equifax “continues to place unrecognized and not get this information removed.32
inaccurate inquiries” on their credit file.26 The
consumer had contacted the credit bureaus, only to be Another consumer “tried to contact the company
“placed on uncomfortable hold on the phone” and to regarding [their] report numerous times,” after having
their information “compromised during the Equifax
have “supervisors hanging the phone up” on them.27
Yet another consumer wrote in that they had “tried breach.”33 This consumer had “multiple inquiries”
to get this resolved with Equifax customer service and “wrong information” on their report, and despite
and they have not been helpful in removing these “multiple attempts and being transferred over 4 times,”
was unable to get this information removed from their
fraudulent inquiries” from their credit report.28
credit report.34 Yet another consumer was able to get
The wealth of complaints over the improper use of Equifax to remove incorrect information from their
consumer credit reports is one indication of the impact credit report, only to have the information “reinserted
of the breach. As one consumer who spotted such without [their] knowledge.”35
an inquiry but struggled to get any assistance from
Equifax said, these issues “seem[] to be a big problem The CFPB complaints over incorrect information
that might warrant some further investigation.”29 on consumer credit reports demonstrate pervasive
problems in the aftermath of the Equifax breach.
Many of these consumers are frustrated with Equifax’s
II. Consumer Complaints about Incorrect inability or unwillingness to help. One consumer spoke
Information on Credit Reports for many Americans: “This has gotten out of hand and
has gone on too long. I need results!”36
As of March 7, 2018, the CFPB had received 7,454
complaints over incorrect information on consumer III. Consumer Complaints about Equifax’s
credit reports since Equifax announced the data breach
Inadequate Assistance Resolving
in September 2017.30
Problems After the Breach
A consumer credit report includes identifying
information for the consumer; information on As of March 7, 2018, the CFPB had received 3,312
consumer credit accounts, such as auto loans, complaints about Equifax’s inadequate or ineffective
mortgages, credit cards, and bank accounts; and a list of investigation into problems with credit reports since
credit inquiries, often requests from lenders to obtain Equifax announced the data breach in September
a copy of your credit report if you have applied for a 2017.37
loan. If a thief obtains a consumer’s information and
successfully opens a new credit card in the consumer’s After failing to notify consumers of the breach for
name, for example, that card and all the debt associated more than a month, Equifax proceeded to adopt
with it will appear on the victim’s credit report. If the shoddy, unhelpful consumer support services, often
thief applies for and successfully takes out a loan, the leaving consumers confused and worse off than before
inquiry from the lender and the loan, along with all they reached out. The company did not have an up-
debt associated with it, will appear on the victim’s credit to-date crisis management plan, and it failed to follow
report. These are all forms of incorrect information on a those provisions it did have in place.38 Victims of the
consumer credit report. breach were faced with an obstacle course riddled with
frustrations, including difficulty reaching Equifax’s
In the aftermath of the Equifax breach, thousands of call centers and accessing their security freeze PINs.39
consumers filed complaints over incorrect information Equifax directed consumers to a special website,
on their credit reports. In one such instance, a consumer EquifaxSecurity2017.com, that had major security
reported disputing incorrect items “multiple times…
vulnerabilities.40
regarding fraud[ulent] accounts and many inquiries” on
their credit report.31 This consumer had learned that

Breach of Trust: CFPB’s Complaint Database Shows Consumers Need Help After Equifax Breach

4 Prepared by the Staffs of Senators Elizabeth Warren, Brian Schatz and Robert Menendez
With thousands of consumers filing complaints with Equifax set up enhanced alerts, security freezes, and
the CFPB over Equifax’s behavior, it appears the credit monitoring after the breach – but appears to have
company dropped the ball on the investigation and done an ineffective job at implementing these protections.
response into these questions. Nearly 3,000 complaints The company offered one year of free credit monitoring
were filed reporting the company’s inadequate through its TrustedID Premier service, and it offered
or unhelpful investigations into problems facing credit freezes, free through January 31, 2018.47
consumers in the months after the breach.
But these services came with their own set of problems
In November, after calling and expressing their for consumers. Equifax initially forced consumers to
concerns to Equifax, one consumer filed a complaint pay for a freeze, before relenting to pressure to waive the
because their “opportunity for employment ha[d] been cost in light of the breach.48 The company also initially
denied because of [their] Equifax credit report.”41 demanded that consumers relinquish their rights to sue
Despite reportedly proving that fraud had led to two the company if they enrolled in TrustedID Premier,
fraudulent collections accounts being placed on their and placed consumers into an account that would
file, the consumer was rejected for employment after automatically renew and charge customers the full
Equifax “re inserted” both fraudulent accounts onto price of the service after one year.49 Equifax changed
their credit report.42 Another consumer sent “several both of these approaches after widespread consumer
ID theft affidavits,” yet they still could not get Equifax complaints.50
to remove the fraudulent account from their credit
report.43 But the problems with Equifax’s services after the
breach didn’t stop there. In an attempt to unfreeze
In December, one consumer summed up the problems their account, one consumer “was redirected to call 6
of thousands of consumers, filing a claim that said, different phone numbers.”51 The consumer’s finances
“I have been disputing erroneous items on my credit were “frozen for over a month,” causing them “extreme
report with this credit bureau and they have not done
hardship.”52
a good job with investigating these errors…This credit
bureau is hurting my chances for applying for loans For other consumers, the products and services have
to help with debt consolidation so I can provide for been inadequate. One consumer “attempted to sign up
my children.”44 After putting consumer data at risk for the company’s TrustedID Premier service,” but was
and failing to provide adequate support, Equifax unable to do so.53 The consumer filled out the form,
has continued to injure consumers with shoddy or “did not receive a confirmation email until 3 days later,”
non-existent investigations into serious and systemic and then when they went to register, the system told
problems in the aftermath of the breach. them they “had already registered.”54 Then the “site…
IV. Consumer Complaints about Fraud froze.”55 The customer couldn’t even figure out “whether
Alerts, Security Freezes, Credit [they had] been enrolled in the monitoring service.”56
Another “victim of [the] Equifax cybersecurity incident”
Monitoring, or Identity Theft Support had been unable to sign up for TrustedID Premier,
Services despite trying “at least on 40 occasions” to do so, and
contacting Equifax repeatedly.57
As of March 7, 2018, the CFPB had received 1,711
complaints over problems with Equifax’s fraud alerts, V. Other Consumer Complaints
security freezes, credit monitoring, and identify theft
support services since Equifax announced the data As of March 7, 2018, the CFPB had received almost
breach in September 2017.45 This includes 1,089 2,000 other complaints regarding a variety of other
complaints about problems with “Fraud Alerts or issues, some related to the breach, and others not. The
Security Freezes,” and 622 complaints about problems complaints included attempts by Equifax to collect
with “Credit Monitoring or Identify Theft Protection debts not owed, problems with written notification
Services.”46 from Equifax, false statements or misrepresentation,
fraud, and scam – since Equifax announced the data
breach in September 2017.58

Breach of Trust: CFPB’s Complaint Database Shows Consumers Need Help After Equifax Breach

Prepared by the Staffs of Senators Elizabeth Warren, Brian Schatz and Robert Menendez 5
These claims include one from a consumer who process to make their voices heard, and right now, the
discovered a fraudulent inquiry on their report, and agency appears to be ignoring those voices.
despite calling several times and speaking to three
different representatives, still could not get the inquiry Congress must also act to reign in abuses in the credit
reporting industry that continue to put consumers
permanently deleted.59 According to the consumer,
at risk. Congress should pass the SECURE Act,
Equifax removed the fraudulent information, only to
introduced by Senators Warren and Schatz in
return it to the report without notifying the consumer
September 2017, which would make it easier for
via mail or e-mail.60 consumers to dispute and correct errors in their credit
reports. In the six months since the data breach, more
VI. Conclusion than 7,000 consumers filed complaints over incorrect
information on their Equifax reports. The SECURE
The bottom-line is simple: consumers are reaching out Act would help these consumers by increasing
to the CFPB to help them deal with Equifax-related accountability for credit reporting agencies who
problems at nearly twice the rate that they did before willfully or negligently fail to fix incorrect information.
the recent data breach. Tens of thousands of consumers The bill would also give consumers the right to receive
have reached out to the agency with their concerns, all documentation from credit reporting agencies, and
including claims of inept customer service, difficulty would give consumers access to an additional credit
securing loans or buying houses after identity theft, and score free of charge.
outright fraud. As part of its duty to consumers, the
CFPB must continue a full-throated investigation into Congress should also pass the Data Breach Prevention
the Equifax breach, including the company’s response and Compensation Act of 2018, introduced by Senators
and its efforts to work with consumers to mitigate the Warren and Warner in January, which would require
harm and repair any damage. the Federal Trade Commission (FTC) to promulgate
cybersecurity standards for credit reporting agencies
The CFPB also must continue working with federal and would impose strict penalties on companies like
and state agencies to address critical cybersecurity Equifax whenever they fail to adequately protect
issues in the credit reporting industry. The bureau consumer data. This breach put nearly 150 million
must use all tools at its disposal, including subpoenas, Americans at risk, and the litany of complaints in the
sworn testimony, and investigative demands, to get to CFPB’s database demonstrate that it has hampered
the bottom of the causes of the breach and the depths their ability to secure loans, buy houses, and even
of Equifax’s failures to protect consumer data and get jobs. But the breach has barely put a dent in
respond adequately to the risks facing consumers. Equifax’s sky-high profits. This bill would force credit
And the CFPB should accept help from other federal reporting agencies to adopt strict security measures
regulators who reach out to assist with any aspect of to protect consumer data by imposing large penalties
the investigation, including on-site bank examinations. on any company that allows data to be accessed by
The American people have used the CFPB’s complaint unauthorized parties.

Types of Complaints about Equifax Number of Complaints


Consumer Complaints about Improper Use of Credit Reports 7,448
Consumer Complaints about Incorrect Information on Credit Reports 7,454
Consumer Complaints about Equifax’s Inadequate Assistance Resolving Problems After the Breach 3,312
Consumer Complaints about Fraud Alerts, Security Freezes, Credit Monitoring, or Identity Theft Support Services 1,711
Other Consumer Complaints 1,996
Total Number of Complaints about Equifax 21,921

Breach of Trust: CFPB’s Complaint Database Shows Consumers Need Help After Equifax Breach

6 Prepared by the Staffs of Senators Elizabeth Warren, Brian Schatz and Robert Menendez
Endnotes
1 “Equifax Announces Cybersecurity Incident Involving Consumer Information,” Equifax (Sept. 7, 2017) (online at https://investor.
equifax.com/news-and-events/news/2017/09-07-2017-213000628).
2 “Bad Credit: Uncovering Equifax’s Failure to Protect Americans’ Personal Information,” Elizabeth Warren (February 2018) (available at
https://www.warren.senate.gov/files/documents/2018_2_7_%20Equifax_Report.pdf).
3 Dodd-Frank Wall Street Reform and Consumer Protection Act, 12 U.S.C. § 5511(b)(2)
4 Defining Larger Participants of the Consumer Reporting Market, 12 C.F.R. § 1090.101
5 Director Cordray’s Letter to Senator Warren (Nov. 21, 2017).
6 Id.
7 Id.
8 Id.
9 Id.
10 Patrick Rucker, “Exclusive: U.S. consumer protection official puts Equifax probe on ice – sources,” Reuters (Feb. 5, 2018) (online at
https://www.reuters.com/article/us-usa-equifax-cfpb/exclusive-u-s-consumer-protection-official-puts-equifax-probe-on-ice-sources-
idUSKBN1FP0IZ).
11 Id.
12 Acting Director Mulvaney’s Letter to Senator Warren and colleagues (Feb. 16, 2018).
13 E-mail from Acting Director Mulvaney
14 Id.
15 Complaints rose from 11,252 to 20,276. “Consumer Complaint Database,” CFPB (https://www.consumerfinance.gov/data-research/
consumer-complaints/search/?from=0&searchField=all&searchText=&size=25&sort=created_date_desc). Accessed 3/7/2018.
16 For TransUnion, complaints rose from 10,722 to 12,271. For Experian, complaints rose from 10,486 to 12,952.
“Consumer Complaint Database,” CFPB (https://www.consumerfinance.gov/data-research/consumer-complaints/
search/?from=0&searchField=all&searchText=&size=25&sort=created_date_desc). Accessed 3/7/2018.
17 “Consumer Complaint Database,” CFPB (https://www.consumerfinance.gov/data-research/consumer-complaints/
search/?from=0&searchField=all&searchText=&size=25&sort=created_date_desc). Accessed 3/27/2018.
18 “Consumer Complaint Database,” CFPB (https://www.consumerfinance.gov/data-research/consumer-complaints/
search/?from=0&searchField=all&searchText=&size=25&sort=created_date_desc). Accessed 3/27/2018.
19 “Consumer Complaint Database,” CFPB (https://www.consumerfinance.gov/data-research/consumer-complaints/
search/?from=0&searchField=all&searchText=&size=25&sort=created_date_desc). Accessed 3/7/2018.
20 15 U.S.C. § 1681(b)
21 “Consumer Complaint Database,” CFPB (https://www.consumerfinance.gov/data-research/consumer-complaints/
search/?from=0&searchField=all&searchText=&size=25&sort=created_date_desc). Accessed 3/7/2018.
22 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2754474).
23 Id.
24 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2753596).
25 Id.
26 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2752070).
27 Id.
28 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2749212).
29 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2751479).

Breach of Trust: CFPB’s Complaint Database Shows Consumers Need Help After Equifax Breach

7 Prepared by the Staffs of Senators Elizabeth Warren, Brian Schatz and Robert Menendez
30 “Consumer Complaint Database,” CFPB (https://www.consumerfinance.gov/data-research/consumer-complaints/
search/?from=0&searchField=all&searchText=&size=25&sort=created_date_desc). Accessed 3/7/2018.
31 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2778467).
32 Id.
33 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2755713).
34 Id.
35 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2755969).
36 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2755713).
37 “Consumer Complaint Database,” CFPB (https://www.consumerfinance.gov/data-research/consumer-complaints/
search/?from=0&searchField=all&searchText=&size=25&sort=created_date_desc). Accessed 3/7/2018.
38 “Bad Credit: Uncovering Equifax’s Failure to Protect Americans’ Personal Information,” Elizabeth Warren (February 2018) (available
at https://www.warren.senate.gov/files/documents/2018_2_7_%20Equifax_Report.pdf).
39 See id.
40 See id.
41 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2717978).
42 Id.
43 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2762072).
44 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2755222).
45 “Consumer Complaint Database,” CFPB (https://www.consumerfinance.gov/data-research/consumer-complaints/
search/?from=0&searchField=all&searchText=&size=25&sort=created_date_desc). Accessed 3/7/2018.
46 Id.
47 “Bad Credit: Uncovering Equifax’s Failure to Protect Americans’ Personal Information,” Elizabeth Warren (February 2018) (available
at https://www.warren.senate.gov/files/documents/2018_2_7_%20Equifax_Report.pdf).
48 See id.
49 See id.
50 See id.
51 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2735137).
52 Id.
53 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2682279).
54 Id.
55 Id.
56 Id.
57 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2693702).
58 “Consumer Complaint Database,” CFPB (https://www.consumerfinance.gov/data-research/consumer-complaints/
search/?from=0&searchField=all&searchText=&size=25&sort=created_date_desc). Accessed 3/7/2018.
59 “Consumer Complaint Database,” CFPB (online at https://www.consumerfinance.gov/data-research/consumer-complaints/search/
detail/2661998).
60 Id.

Breach of Trust: CFPB’s Complaint Database Shows Consumers Need Help After Equifax Breach

8 Prepared by the Staffs of Senators Elizabeth Warren, Brian Schatz and Robert Menendez

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