Analysis of Consumer Complaints Against 12 of the Largest Retail Banks

Filed with the U.S. Consumer Financial Protection Bureau

From March 1, 2020 to September 23, 2021


The Committee for Better Banks original study “COVID Scorecard: Spotlight on Forbearance” released in Septeember 2020 found many of the largest banks in the US failed to communicate their COVID-related forbearance policies to customers and poorly implemented relief plans under the CARES Act. While pandemic-related unemployment surged, so did requests for relief from consumers facing unprecedented economic uncertainty. As part of CBB’s Better Banks Accountability Project, this research updates our earlier report with U.S. Consumer Financial Protection Bureau (CFPB) mortgage-complaint data from March 1, 2020 to September 23, 2021.

We compiled this data by searching for mortgage related complaints on the following issues: forbearance, deferment, loan modification, refinance, and repayment plan. Then we evaluated 12 of the largest retail banks on the level of complaints filed against each of them with their relative mortgage loan volume and market share. Specifically, for each bank, we measured:

  • The number of consumer complaints submitted;
  • The total number of forbearance-related issues raised in the complaints;
  • Average number of issues per complaint;
  • Number of multi-issue complaints;
  • COVID-19 or pandemic-related complaints; and
  • Complaints citing “balloon payments” and “without my knowledge”.


Consumers continue to have problems resolving mortgage forbearance-related policies implemented by their bank. Of the 12 major retail banks that the Committee for Better Banks has tracked under its Bank Accountability Project, Wells Fargo consistently stands out for its outsized level of consumer complaints. At 585 complaints, Wells Fargo received the most complaints of which 259 raised multiple issues. It received 36.61 percent of all complaints during the data period, and the 259 multi-issue complaints it received were 47.09 percent of all complaints naming more than one issue.

Overall, Truist Bank, Fifth Third Bank and Wells Fargo each had a greater share of complaints and issues compared to their market share, while the other 9 banks generally had fewer complaints relative to their mortgage market share. But Wells Fargo has market dominance relative to its retail bank peers, resulting in its consumer complaints having four times (4.9x) the impact as Truist Bank and (13x) as Fifth Third Bank. See Chart 1.

Complaints/Market Share Ratio: Fifth Third Bank, Truist Bank, Wells Fargo and TD Bank had a greater share of consumer complaints relative to their market share. See Table 4 for details.

Consumer Issues in Complaints/Market Share Ratio: Truist Bank, Fifth Third Bank and Wells Fargo had a greater share of total issues raised by consumers in their CFPB complaints relative to their mortgage volume market share. See Table 3 for details.

Complaints with multiple issues/Market Share Ratio: Truist Bank and Wells Fargo had significantly more consumer complaints with multiple issues relative to their mortgage volume market share compared with the rest of the banks in this study. See Table 5 for details.

Average Number of Issues Raised in each CFPB Complaint: The average number of issues raised per consumer complaint for this group of 12 banks was 1.34 issues. Wells Fargo, Truist Bank and US Bank each had a higher level of issues per consumer complaint, while the other nine banks were below the average. See Table 2 for details.

Covid-19, Pandemic-related Complaints: Truist Bank, Wells Fargo, Fifth Third Bank and PNC Bank all had a greater ratio of pandemic-related complaints than their peer banks. Wells Fargo had 43 percent of all COVID-19-related complaints. See Table 6 for details.

Complaints Involving Balloon Payments: Wells Fargo topped this list with 13 out of the total 39 consumer complaints involving balloon payments. JPMorgan Chase came in second with 9 complaints. See Table 7 for details.

Complaints Involving “Without My Knowledge”: Wells Fargo received half (6 out of 12) of all consumer complaints involving this issue indicating that the bank took action on a mortgage without the consumer’s knowledge or consent. See Table 8 for details.

Chart 1: Wells Fargo’s Consumer Complaints Exceed Its Market Dominance