Debt-Buyer Complaint Record CFPB data · enforcement history · 10-K financials
Prepared for legal reference · sourced & citable

CFPB complaint volume and enforcement record across the debt-buying ecosystem

Encore Capital Group / Midland Credit Management and Concora Credit (formerly Genesis Financial Solutions, servicer for the Indigo, Destiny, Milestone and Earniva Mastercards issued by Celtic Bank and The Bank of Missouri) — complaint counts, collection-practice issue codes, regulatory settlements, and 10-K debt-buying economics, each figure traceable to a primary source.

Complaint data source: CFPB Consumer Complaint Database public API Generated:
Encore / Midland — total complaints
All-time, all products, filed under "ENCORE CAPITAL GROUP INC."
Encore / Midland — debt collection complaints
Product = "Debt collection"
Concora Credit — total complaints
Filed under "CLGF Holdco 1, LLC"
Concora Credit — debt collection complaints
Product = "Debt collection"
Neither Celtic Bank nor The Bank of Missouri — the banks that issue Concora's Indigo, Destiny and Milestone Mastercards — return any hits as a standalone company= filter in the CFPB database. All complaint volume tied to those card programs is captured under the servicer entity "CLGF Holdco 1, LLC," not the issuing bank. See CFPB Consumer Complaint Database API.
Corporate structure

Who owns whom

Ownership chains matter for pleading and discovery — complaints and lawsuits attach to different entities within each corporate family.

Encore Capital Group Public — NASDAQ: ECPG
Encore Capital Group, Inc.
San Diego, CA · publicly traded, files Form 10-K
↓ wholly-owned subsidiaries
Midland Credit Management, Inc. (MCM)
primary servicer / collector — named in most consumer-facing complaints
Midland Funding, LLC
debt-purchasing entity — usual plaintiff in collection lawsuits
Asset Acceptance Capital Corp.
acquired 2013 — debt purchaser
Cabot Credit Management
European debt-purchasing arm

Sources: Encore Capital Group ↗, Midland Credit Management ↗, Encore Capital businesses & services ↗

Concora Credit Private — Castlelake-owned
CLGF Holdings, L.P. (Castlelake, L.P. — PE sponsor)
ultimate parent; explored ~$1B sale of Concora in 2024
CLGF Holdco 1, LLC → CLGF Holdco 2, LLC
holding entities — CFPB complaints filed under "CLGF Holdco 1, LLC"
Concora Credit, Inc.
Beaverton, OR / Akron, OH — formerly Genesis Financial Solutions (rebranded 2023); no SEC filings
↓ card programs serviced, issued by partner banks
Indigo Mastercard
issued by Celtic Bank
Destiny / Milestone Mastercard
issued by The Bank of Missouri

Sources: Concora Credit — Who We Are ↗, Rule 29.6 disclosure, SCOTUS docket 25A218 ↗, Bloomberg — Castlelake sale exploration ↗, Concora card portfolio overview ↗

Collection practices

What consumers are complaining about

Debt-collection issue codes and the sub-issues driving them — the practices and dollar-amount disputes most relevant to a collection-practices claim.

Encore / Midland 52,876 debt-collection complaints
Concora Credit 1,190 debt-collection complaints
Encore / Midland — top sub-issues
Sub-issueParent issueCount
Concora Credit — top sub-issues
Sub-issueParent issueCount

"Attempts to collect debt not owed" and its sub-issues ("Debt is not yours," "Debt was already paid," "Debt was result of identity theft") are the categories most directly probative of disputed collection amounts. Source: CFPB Consumer Complaint Database API ↗.

Regulatory & private litigation record

Enforcement actions and settlements

CFPB administrative and federal-court actions, multistate AG settlements, and private FDCPA/FCRA/TCPA class actions and lawsuits — ordered by date. Every monetary figure is quoted or paraphrased directly from the linked source; where no settlement has been reported, the docket status is stated instead of a number.

10-K disclosures

Debt-buying economics: what they pay, what they collect

Encore Capital Group is publicly traded and discloses portfolio purchase spend, gross collections, and profitability in its Form 10-K. Concora Credit does not.

Encore Capital Group — portfolio purchases vs. gross collections vs. net income

Figures in $ millions, rounded. FY2022 omitted (not gathered in source set); years shown are FY2019–FY2021 and FY2023–FY2025. Source: Encore Capital Group FY2025 10-K coverage ↗, Q4/FY2024 results ↗.

Pre-tax ROIC vs. cost-to-collect

"Cost-to-collect" = adjusted operating expense ÷ gross collections. Both metrics reported only through FY2021 in the source set gathered; FY2022–FY2025 restatements were not located and are omitted rather than estimated.

Cumulative purchase economics (through FY2025)
Cumulative portfolio purchase price, all vintages$15,940,492K
Cumulative Collections Money Multiple (total)1.9×
Cumulative Collections Money Multiple (US)2.0×
Estimated total Purchase Price Multiple (total)2.5×
Estimated total Purchase Price Multiple (US)2.6×

"Money multiple" = lifetime estimated collections ÷ purchase price — the core measure of how much Encore expects to collect for every dollar spent buying charged-off debt. Source: Encore Capital Group FY2025 10-K coverage ↗.

Direct 10-K / annual-report language
“In order to operate profitably over the long term, we must continually purchase and collect on a sufficient volume of charged-off receivables to generate revenue that exceeds our costs.”Encore Capital Group 10-K — 2021 Annual Report ↗
“We maintained our focus on returns and deployed $665 million in 2021 to purchase portfolios at an average money multiple of 2.4x.”Encore Capital Group 2021 Annual Report — PDF ↗
“Global portfolio purchases in 2024 up 26% to record $1.35 billion.” “Global collections in 2024 up 16% to $2.16 billion.”Encore Capital Group Q4/FY2024 results — press release ↗
Concora Credit has no comparable disclosure. Concora Credit, Inc. is privately held (ultimate parent CLGF Holdings, L.P. / Castlelake, L.P.) and files no Form 10-K or other periodic SEC report — so no public breakdown of what it pays for charged-off receivables, what it collects, or its resulting profit margin exists for direct comparison to Encore. Source: Rule 29.6 Corporate Disclosure Statement, SCOTUS docket 25A218 ↗.
Methodology

How this was built, and every source used

Complaint counts and breakdowns come directly from the CFPB Consumer Complaint Database's public aggregation API, queried by exact company-name string ("ENCORE CAPITAL GROUP INC." and "CLGF Holdco 1, LLC") on . Enforcement and litigation entries are drawn from CFPB, state Attorney General, and court/docket primary sources where available, supplemented by secondary legal-industry reporting only where explicitly labeled as such. 10-K financial figures are quoted or recomputed directly from Encore Capital Group's public filings and investor releases; Concora Credit has no equivalent public filings.