Consumer Complaints as Infrastructure Failure Signals: Systemic Vulnerability Architectures and a Failure Ecosystem Framework for Consumer Finance

Consumer financial services depend on interconnected institutions, products and regulatory processes, yet complaints about failures within this infrastructure are usually analysed as individual cases or grouped using administrative categories. This study examines whether large-scale complaint data can instead reveal recurring structures of failure. Using 4.7 million complaints submitted to the U.S. Consumer Financial Protection Bureau between 2011 and 2024, we develop a Failure Ecosystem Framework that groups complaint narratives by semantic similarity and traces the institutions and products associated with each group over time. The analysis identifies 16 failure ecosystems, spanning credit reporting, identity theft, debt collection, payment disputes, mortgage servicing and digital finance. These ecosystems differ substantially: some failures concentrate among a few institutions while others are widely distributed, and in many, the same institution–product combinations recur from year to year. Greater concentration is not systematically associated with better or worse complaint outcomes, and the evidence is least conclusive for monetary compensation. Corrective outcomes vary more across failure types than with concentration, indicating that market structure alone cannot explain how consumer failures are remedied. Complaints can therefore reveal persistent structures of failure that case-by-case review does not expose, supporting system-level monitoring of vulnerabilities in consumer finance.