Enforcement Gap · CFPB + 5 Agency Cross-Reference
High complaint rates. Zero enforcement actions.
These 1 institutions are in the top 10% for consumer complaints per 1,000 customers and carry no enforcement action in the federal layers we publish — OCC, CFPB, Federal Reserve, FinCEN, DOJ, FTC and HUD MRB. That is a statement about our records, not a finding that no action exists: our OCC and Federal Reserve layers are currently suspended pending an accuracy audit, and the underlying score counts some agencies only while an action is active.
What this means. A high complaint rate with zero enforcement is not proof of regulatory capture — it may reflect agency resource constraints, jurisdictional gaps, or institutions that have avoided formal action through informal supervision. What it does show is a mathematical disparity between consumer-reported harm and federal regulatory response in the public record.
1
institutions in gap
2.65
highest rate /1k
0
enforcement actions
6
agencies cross-checked
| Rank | Institution | Rate /1k | Percentile | Complaints | Confidence |
|---|---|---|---|---|---|
| 1 | American Express Company | 2.65 | 90.4% | 44,460 | High |
Complaint rate: CFPB Consumer Complaint Database, May 2026 snapshot, normalised against FDIC deposit-weighted estimated customer base. Enforcement: OCC, CFPB, Federal Reserve, FinCEN, DOJ, FTC and HUD MRB public enforcement databases, April 2026. NCUA is not counted by this score. The OCC and Federal Reserve layers are suspended pending an accuracy audit (Aug 2026). Threshold: percentile_rank > 90 (top 10%) AND federal_consensus_score = 0. Data sources →
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