The Consumer Financial Services Association of America (CFSA) issued a statement in which it reported that documents it received from the CFPB in response to a Freedom of Information (FOIA) request filed on December 31, 2015 “reveal for the first time more than 12,000 positive testimonials that payday loan customers submitted to the [CFPB] as part of the Bureau’s “Tell Your Story” initiative.”

According to the CFSA, during the five-year period covered by the FOIA request, 12,308 comments (or more than 98%) of the 12,546 comments submitted on short-term loans praised the industry and its products and services, or otherwise indicated positive experiences.  The CFSA reported that the FOIA documents revealed that only an extremely small number of critical payday lending comments were submitted to the CFPB – just 240 or less than 2%.  (According to the CFSA, of the 240 negative comments, 84 comments were mistakenly categorized as payday lending comments.)

The CFSA observed that this data is consistent with complaint data from the CFPB and FTC.  It stated that “[s]ince the CFPB’s complaint portal came online in 2011, complaints regarding payday loans have been miniscule – just 1.5% of all complaints.  Meanwhile, these complaints continue to decline.”  The CFSA also stated that “[i]n its summary of 2015 consumer complaints, the FTC found that just 0.003% of more than three million complaints related to payday lending.”

The CFPB issued its payday loan proposal in June 2016 and comments are due by October 7, 2016.  The CFSA asserted that, by pursuing this proposal, the CFPB is “ignoring the positive experiences shared by consumers.”