Debt collection complaints offer one of the clearest, real‑time windows into how collection practices impact consumers at scale.
Drawing on more than 600,000 recent complaints from the CFPB Consumer Complaint Database, a new report by The Kaplan Group pinpoints where risk is concentrated, which complaint types dominate, and how much of the observed under-performance remains after adjusting for product and issue mix.
Key Takeaways
- Roughly 49.5% of complaints are generated by the top 5 states and about 65.8% by the top 10 states.
- About 30.9% of all complaints are tied to the top 5 companies and 43.4% to the top 10 companies.
- Most debt collection complaints cluster in a handful of recurring problems, led by attempts to collect debt not owed, with around 46% of the complaints.
How Concentrated Is Complaint Activity?
We analyzed 630,012 complaints filed between 2021 and early 2026 related to debt collection for U.S. states and DC. Complaint volume is highly concentrated:
- Roughly 49.5% of complaints are in the top 5 states.
- Roughly 65.8% are in the top 10 states.
Company concentration is also high:
- Roughly 30.9% of complaints are associated with the top 5 companies.
- Roughly 43.4% are associated with the top 10 companies.
Complaint volume over time provides a demand signal for when collection pain is rising and whether changes are broad‑based or localized. The peak month is September 2025 with 26,758 complaints.
What Consumers Are Complaining About?
A relatively small set of recurring issues drive a large share of debt collection complaints.
Top issues:
- Attempts to collect debt not owed, 45.9% of all complaints
- Written notification about debt, 24.2%
- Took or threatened to take negative or legal action, 11.9%
- False statements or representation, 11.2%
- Communication tactics, 4.6%
Top sub‑products:
- Other debt, 19.1%
- Credit card debt, 18%
- Medical debt, 6.8%
- Auto debt, 3.5%
Where is Collection Risk Highest?
High‑risk states combine both volume and concentration. The Collection Risk Heat Map turns each state into a 0–100 score of how concentrated complaints are by company and issue.
The highest‑risk states on this index are led by Texas, Florida, California, Georgia, New York, Illinois, Pennsylvania, North Carolina, New Jersey, and Virginia. Those states account for roughly two‑thirds of all in‑scope complaints.
How the Risk Score Works?
The Collection Risk Heat Map is a state‑level index scored from 0 to 100 and designed for prioritization, not causal inference. The index blends three elements:
- Volume pressure: log‑scaled complaint counts so large states do not dominate purely on size.
- Company concentration risk: Herfindahl–Hirschman Index (HHI) on company shares within each state, where higher scores indicate that a smaller number of companies account for most complaints.
- Issue concentration risk: HHI on issue shares within each state, where higher scores indicate a narrower set of complaint types dominates.europa
Concentration matters because:
- A high‑volume state with low concentration can indicate diffuse, system‑wide friction.
- A high‑volume state with high concentration can indicate a narrower set of practices or players driving a disproportionate share of harm, which is often more actionable.
Methodology
This report analyzes 630,012 debt collection complaints from the CFPB Consumer Complaint Database for US states plus DC. Records were grouped by State, Company, Issue, Sub-product, and Date received to quantify where complaints concentrate, which topics dominate, and how performance differs across geographies and firms. Time dynamics were measured by aggregating Date received into calendar months and plotting monthly complaint counts to identify peaks and inflection points.
To translate raw complaint volume into a prioritization signal, we built a Collection Risk Index at the state level, scored from 0 to 100. The index is designed for triage and targeting rather than causal inference. It combines three components: Volume pressure, measured as log-scaled complaint counts so large states do not dominate purely due to population size; Company concentration, measured using the Herfindahl–Hirschman Index (HHI) on company complaint shares within each state; Issue concentration, also measured via HHI on issue shares within each state. Higher scores indicate states where complaint pressure is both high and concentrated, which is often more actionable for intervention.
To separate true under-performance from differences in complaint mix, we added a benchmarking layer. We first defined peer segments using Sub-product × Issue and calculated baseline outcome rates for each segment. For each state and for each company within high-risk states, we then computed expected outcome rates as the average of segment baselines implied by that entity’s mix, and compared them to actual observed rates. Benchmarked outcomes focused on operational fields available in the extract, primarily Timely response and Company response to consumers (including “closed with explanation”). The key benchmarking output is the gap measured in percentage points between actual minus expected, which highlights where results are meaningfully better or worse than would be predicted by mix alone.
Limitations
This analysis is descriptive: it surfaces concentrations, patterns, and under-performance signals but does not claim causality. The latest month in the data appears partial, so month‑over‑month movements at the tail should be treated as ingestion‑limited rather than interpreted as real improvement.
Closed with explanation is treated as a closure posture signal, not a quality judgment; whether this is “good” or “bad” depends on internal policy and the distribution of relief outcomes in each portfolio.
