Enforcement Gap · CFPB + 5 Agency Cross-Reference
High complaint rates. Zero enforcement actions.
These 4 institutions are in the top 10% for consumer complaints per 1,000 customers and have never received a public enforcement action from any of the 6 federal agencies ComplaintRate tracks — OCC, CFPB, Federal Reserve, FTC, DOJ, or NCUA.
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.
4
institutions in gap
0.49
highest rate /1k
0
enforcement actions
6
agencies cross-checked
| Rank | Institution | Rate /1k | Percentile | Complaints | Confidence |
|---|---|---|---|---|---|
| 1 | Optum Bank, Inc. | 0.49 | 97.5% | 780 | Directional |
| 2 | Keycorp | 0.48 | 97.3% | 7,357 | High |
| 3 | Firstbank Puerto Rico | 0.42 | 96.9% | 699 | Medium |
| 4 | Hancock Whitney Bank | 0.17 | 95.0% | 496 | Directional |
Complaint rate: CFPB Consumer Complaint Database, March 2026 snapshot, normalised against FDIC deposit-weighted estimated customer base. Enforcement: OCC, CFPB, Federal Reserve, FTC, DOJ, NCUA public enforcement databases, April 2026. Threshold: percentile_rank > 90 (top 10%) AND federal_consensus_score = 0. Data sources →
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