Citizen Contacting in Response to Crisis: Voicing Grievances to the Consumer Financial Protection Bureau

Published date01 March 2021
Date01 March 2021
Subject MatterArticles
American Politics Research
2021, Vol. 49(2) 198 –214
© The Author(s) 2020
Article reuse guidelines:
DOI: 10.1177/1532673X20962414
Citizen interaction with government agencies is ideally a reg-
ular feature of democratic government (Gormley & Balla,
2012; Soss & Keiser, 2006; Zuckerman & West, 1985).
Political participation is more than involvement in episodic
elections. Citizen contacting of government is a means by
which political and potentially insular bureaucratic institutions
learn what people want from their leadership (Bimber, 1999;
Peters, 2010; Verba et al., 1995; Rosenstone & Hansen,
1993; Verba & Nie, 1972). But from where, and from whom,
do contacts with government agencies originate? Experts
agree that insularity from public demands heightens the risk
of undemocratic governance by bureaucracy. Bureaucracy is
not generally thought to be especially responsive to the
elected executives in charge of them, much less to petitions
bubbling up from the grassroots (Kennedy, 2015). Even
when accessible voice mechanisms are established to con-
nect citizens to agencies, contact may originate only from
select populations. If an agency only responds to demands
channeled through a particular medium, but only a few citi-
zens are aware that this voice mechanism exists, service will
be directed only toward those few (Minkoff, 2016; Sharp,
1984). The demand for service may not reflect the need for
service, pointing up the difference between needs, and needs
that are voiced, potentially magnifying inequalities already
Citizen contact with public officials is known to be quite
uneven across the population (Jones et al., 1977; Sharp, 1984;
Thomas, 1982; Peterson, 1988; Zuckerman & West, 1985).
The tendency for awareness to be a greater influence on con-
tacting than need suggests that bureaucratic response may
create greater political inequalities as the affluent and well-
educated have the wherewithal to make demands, while the
poor and less informed do not (Fountain, 2001; Hastings
et al., 2014; Hero, 1986; Matthews & Hastings, 2013; Sharp,
1982, 1984). Over time, as awareness of contact processes
increases, there may be more voicing of grievance as agency
familiarity grows, but also contingent upon changing need.
As the need for assistance increases, the search for avenues
for redress is also likely to intensify, yielding a greater vol-
ume of contacts.
An important compensatory force for those with needs but
less awareness lies in the mechanism of voice by referral of
third parties. These are often consultative agents at the street-
level, implanted in other governmental organizations, in
962414APRXXX10.1177/1532673X20962414American Politics ResearchGimpel
1University of Maryland, College Park, MD, USA
Corresponding Author:
James G. Gimpel, Department of Government, University of Maryland,
3140 Tydings Hall, College Park, MD 20742, USA.
Citizen Contacting in Response to Crisis:
Voicing Grievances to the Consumer
Financial Protection Bureau
James G. Gimpel1
The Consumer Financial Protection Bureau (CFPB) came into being in response to the housing and debt crisis that accompanied
the Great Recession. Created as a means for aggrieved consumers to bring problems to the attention of federal regulators
empowered to fine banking and finance companies, the inflow of complaints began late in 2010 and has steadily risen in the
years since. This research examines the variable emergence of complaints across 5 years, asking what types of constituencies
are most likely to register grievances with the CFPB. The filing of complaints is mostly responsive to the presence of
middle and upper income populations with mortgages, though contacts are also high from African American neighborhoods.
Government contacting among lower income populations is facilitated by the presence of counseling and consultative services
at the grassroots. Notably, legal aid services often present in lower and moderate income neighborhoods are associated
with higher complaint frequency for several financial products. Through street-level consultative organizations, the gap in
government service provision separating the affluent, who complain on their own, and less privileged, who do not know
where to express their grievances, can be reduced.
Citizen contacting, regulation, Consumer Financial Protection Bureau, Great Recession
Gimpel 199
non-profits, on the staffs of elected officials, or among private
parties that find themselves in a consultative role (Jones,
1981; Scholz et al., 1991; Weissert, 1994). Staffs of state leg-
islators and members of Congress are known to receive many
complaints that they then refer on to other government agen-
cies. Consumer organizations are also known to intercede
between citizens and government and to act as a referral ser-
vice for complaints. Non-profit agencies house expertise in
the operation of government programs, and commonly
depend upon government grants for their livelihood (Lipsky
& Smith, 1989; Soss, 2002). Their understanding of policies
and programs is beneficial to individuals seeking help with
claims for government benefits, and channeling questions and
complaints to the appropriate authorities.
One of the signal policy outcomes emerging from the
Great Recession was the creation of the Consumer Financial
Protection Bureau (CFPB). As part of the Dodd-Frank Wall
Street Reform and Consumer Protection Act, it passed into
law in 2010 following highly partisan votes in both chambers
of Congress. The impetus for the creation of this independent
agency was to protect consumers from abusive and predatory
lending practices, not just by subprime lenders, but by main-
stream financial institutions offering standard loan products.
Momentum behind passage was greatly furthered by the
home mortgage crisis that began in 2007, and continued for
several years as foreclosure rates soared in parts of the coun-
try where housing prices had surged in the preceding years.
As a critical part of its legislative mandate, the CFPB
instituted a consumer complaint procedure as a means of
addressing problems and issues associated with a range of
financial services: mortgages, credit cards, consumer loans,
payday loans, debt collection practices, and credit reporting.
The complaints are recorded in a publicly available database
beginning in 2011. Each complaint record contains details
about its geographic origin (by zip code), and the substantive
concern of the complaint, usually identifying the firm against
whom the grievance was reported, along with information
about whether the complaint was resolved. This CFPB
resource therefore offers an excellent opportunity to advance
the research on citizen involvement with government, espe-
cially engagement with newly created regulatory agencies
about which little is known.
From where are the complaints to the CFPB emerging,
and how do these complaints vary across the nation? Are
they reflective of measures of need, or do they instead reflect
the uneven distribution of socioeconomic status? Although
there is a lack of individual-specific information about indi-
vidual complainants, available information does make it pos-
sible to examine a quite granular geography in order to draw
inferences about who requests government service. This is
among the first social science papers to merge zip code level
contacting data to zip level socioeconomic information to
study the factors associated with complaint flow across the
entire nation (but see: Ayres et al., 2013; Littwin, 2014).
Thorough examination of this information may facilitate
understanding of complaint sources that are other than need
based, as government services have often been found to be
most responsive to the organized, or described as captured by
those of higher socioeconomic status (Nivola, 1978). Here,
the locations of counseling and advice-giving intermediaries
are hypothesized to be an important font of complaints flow-
ing upward. Net of measures of need and information, the
presence of consultative and intercessory organizations such
as legal aid offices, and housing counseling grantees, may be
associated with larger local volumes of financially-related
Housing Finance, the Great Recession and the
Home ownership requires long-term debt finance for the vast
majority of Americans. Since the 1930s, home purchase in the
United States has been encouraged through a number of
important policies enacted by the federal government, many
of them operating through the mortgage finance system. Of
primary importance, mortgage financing is stimulated by loan
guarantees provided by a number of federal agencies, (e.g.,
USDA, VA, FHA, HUD). Under these arrangements, the risk
of default on a loan is transferred, in large part, or entirely, to
the U.S. government (Sellon, 1990; Weiss & Jones, 2017).
Government sponsored enterprises (GSE’s) such as Fannie
Mae (FNMA), Freddie Mac (FHLMC) and Ginnie Mae
(GNMA) offer additional stimulus by providing guarantees in
the secondary housing market for certain mortgage backed
securities. The present mortgage finance system has unques-
tionably made homeownership a reality for many who could
not otherwise afford it. Given the high cost of housing com-
pared to other consumer purchases, government programs,
taken together, have generated a much higher level of home-
ownership than the market would have provided otherwise.
New mortgage products introduced since banking deregu-
lation in the 1980s have further extended housing investment
to populations that would otherwise not be able to qualify for
mortgages.1 In the period running up to the Great Recession,
lenders and borrowers sought increasing flexibility in mort-
gage finance options, advancing sub-prime loans to those
with weak credit histories, and/or to those with little docu-
mentation (of past employment and income). These noncon-
ventional instruments included adjustable rate mortgages
with low introductory interest rates, zero downpayment
loans, interest only loans, negative amortizing loans, and
some others. Quite crucially, these lending innovations all
carry substantially more risk of default than a conventional
loan with a fixed interest rate, over a fixed term. Mortgagors
start out with low equity and very high debt, and accumulate
equity very slowly over the typical 30-year repayment term
(Ryan et al., 2011). Payments are commonly burdensome
relative to the homeowner’s monthly income (Green, 2008).
By 2006, subprime loans amounted to more than 20% of all
new mortgage originations, substantially exceeding 20% in

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