Consumer harm from excessive bank fees
We advised the CFPB in an investigation involving allegations that a bank steered consumers into costly retail services without their consent and charged fees for those services. The case alleged that the bank designed its account application process to make the services seem mandatory for new customers to open accounts, obscured the related fees, and failed to notify customers of their options to opt-in or opt-out of the services. We analyzed the bank’s account-level data covering several years to identify affected accounts and fees charged to each account, and to develop analytical approaches to estimating the resulting harm to consumers, accounting for the fact that even with full information, some consumers would have opted to accept the services in question, while others would not. Separately, we supported an academic expert on behavioral economic issues.