By Rachel Donovan, consumer-finance journalist covering prepaid cards, public benefits, and banking regulation for 12 years
Last reviewed: July 24, 2026
Treasury said in 2020 that Direct Express had maintained customer-satisfaction ratings of 94% or higher for 10 years. A later Consumer Financial Protection Bureau complaint alleged that, during March through May 2022, callers on two Direct Express service lines waited more than one hour on average, with some waits reaching two and a half hours. (fiscal.treasury.gov)
Both statements belong in the record. Neither, alone, provides a complete measure of service quality.
The Treasury figure describes a long-running satisfaction metric whose survey method was not published in the announcement. The CFPB figures appeared as allegations in litigation that the Bureau later dismissed without prejudice in April 2025.
What Direct Express is
Direct Express is a Treasury-sponsored prepaid debit-card program used to deliver Social Security, Supplemental Security Income, veterans benefits, and other qualifying federal payments electronically.
For many cardholders, the account is not a secondary spending tool. Treasury said in its January 2020 financial-agent announcement that the program served 4.5 million Americans, most without bank accounts, and that the federal payment was the sole income source for most cardholders. (fiscal.treasury.gov)
Customer service therefore performs a more consequential role than an ordinary rewards-card help desk.
A representative may be handling a stolen card, inaccessible benefit payment, disputed withdrawal, blocked account, replacement request, or transaction error involving money needed for housing, food, medicine, or transportation.
The 94% satisfaction claim
Treasury’s announcement “Treasury’s Bureau of the Fiscal Service Selects Comerica Bank to Continue Prepaid Debit Card for Unbanked,” published January 7, 2020, stated that Direct Express had maintained customer-satisfaction ratings of 94% or higher during the previous 10 years. (fiscal.treasury.gov)
The same release reported:
- 4.5 million cardholders
- A majority without bank accounts
- Federal benefits as the sole income source for most users
- More than 14 million uses of the PayPerks financial-education program (fiscal.treasury.gov)
Those are strong headline results.
The announcement did not state the survey sample size, response rate, question wording, collection method, margin of error, or whether satisfaction was measured after routine transactions, customer-service contacts, or both.
A 94% satisfaction result can coexist with serious service failures if most users never encounter a complex problem. Routine monthly deposits and purchases may work well for a large majority, while the smaller group needing fraud, dispute, or account-recovery support experiences severe friction.
That is the first analytical distinction: overall satisfaction is not the same as problem-resolution performance.
What the CFPB alleged about call wait times
On December 6, 2024, the CFPB filed a civil complaint against Comerica Bank concerning its administration of Direct Express. An amended complaint followed on March 13, 2025. The case alleged violations of the Electronic Fund Transfer Act, Regulation E, and the Consumer Financial Protection Act.
The complaint alleged that callers using two vendor-managed Direct Express service lines waited more than an hour on average during March, April, and May 2022, covering both payment-disbursement and non-disbursement periods. Some callers allegedly waited as long as two and a half hours.
The CFPB also alleged that, between April 1, 2019 and May 31, 2023:
| Service measure alleged by CFPB | Vendor 1 | Vendor 2 |
|---|---|---|
| Periods when average waits exceeded expected standard | 40% | 43% |
| Periods when abandonment exceeded expected standard | 32% | 10% |
Source: CFPB v. Comerica Bank, Complaint, filed December 6, 2024.
These figures were allegations rather than judicial findings. The CFPB dismissed the case without prejudice on April 11, 2025, and the court terminated it that day.
Dismissal without prejudice means the case ended without a final ruling on the merits and without the court determining that every allegation was true or false.
The monthly complaint numbers
The initial CFPB complaint alleged that Comerica received 274 complaints in June 2019 from cardholders unable to reach one of the service vendors. In July 2019, it allegedly received 358 similar complaints. Some consumers reportedly described waits of up to four hours.
Those numbers provide a concrete snapshot, but they lack a denominator.
The complaint did not state in that passage how many total calls the line handled during either month. If the service center received several million calls, 358 complaints would represent one rate; if it received tens of thousands, the rate would be much higher.
Complaint counts also understate some service failures because a caller unable to reach the institution may never complete a separate complaint about that failure.
They can overstate broader dissatisfaction when one unusually severe outage or payment cycle generates a short-term spike.
The data supports a narrow conclusion: hundreds of people formally reported access problems during those two months. It does not establish the percentage of all Direct Express callers who were affected.
How calls were allegedly dropped
The CFPB complaint described a call-management tool referred to as Heavy Queue. It alleged that one vendor activated the system when queued calls exceeded four times the number of available representatives or when more than 600 calls were waiting with a wait time above 30 minutes.
According to the complaint, the system could disconnect callers whose selected issue did not fall within a limited group of priority topics. Before September 2019, the CFPB alleged, activation of Heavy Queue resulted in all calls being dropped.
A queue-management tool is not inherently improper. Call centers routinely route customers by topic and capacity.
The regulatory concern described in the complaint was different: some Direct Express consumers allegedly could not reach a representative to report problems that affected access to essential benefits or rights under Regulation E.
The practical effect of a dropped call is larger when reporting time matters. Certain electronic-transfer protections depend on when the financial institution receives notice from the consumer.
Customer-service availability can therefore affect legal rights, not merely convenience.
Where the wait-time headline misleads
The phrase “average wait over one hour” sounds like it describes every Direct Express call.
It does not.
The CFPB complaint tied that result to specified months in 2022 and to two vendor-managed lines. It did not establish that every cardholder calling throughout the full Comerica contract period experienced an hour-long wait.
Direct Express also provides automated balance access, websites, mobile applications, and self-service functions. A customer checking a routine balance may never enter the live-agent queue.
The more accurate interpretation is that live support allegedly failed most visibly during periods when cardholders needed human intervention.
That distinction does not reduce the seriousness of the issue. Fraud claims, blocked cards, disputed transfers, and lost-card reports are precisely the situations that automated tools often cannot finish.
The scale of disputed claims
The original CFPB complaint alleged that one form letter had been sent in response to more than 220,000 Direct Express claims since April 1, 2019. The Bureau alleged that the letter said the institution could not confirm fraud but did not clearly tell cardholders whether the claim had been approved or denied.
The same complaint alleged:
- More than 140 instances in which cardholders were not notified that approved provisional credit had become final
- More than 1,350 instances in which approval notices failed to state that provisional credit was final
Again, those were allegations in a dismissed action, not final adjudicated violations.
The volume is analytically useful because it shows that error resolution was not a marginal service function. Hundreds of thousands of claims moved through the dispute system over several years.
A card program serving millions will naturally generate a large number of inquiries and disputes. The relevant performance measures would be claim rate, resolution time, approval rate, repeat contact, complaint escalation, and compliance with required notices.
Those metrics were not published as a complete public dashboard.
The CFPB’s broader prepaid-benefit findings
The CFPB’s March 2023 report “Issue Spotlight: Public Benefits Delivery & Consumer Protection” examined public cash assistance delivered through financial products, particularly prepaid cards.
The report identified three recurring issues:
- Fees that reduce benefit amounts
- Inadequate customer service that can make funds inaccessible
- Limited consumer choice because recipients are tied to a provider selected by the government program
The CFPB wrote that one unauthorized charge can produce a cascade of problems when customer service is unavailable or does not respond promptly. It also noted that relatively few vendors participate in the government prepaid-card market.
That report was broader than Direct Express. It also discussed Temporary Assistance for Needy Families and unemployment payments.
Its conclusions fit the Direct Express structure closely. The recipient generally does not select the card issuer, and switching away can require establishing a bank account and changing the federal payment destination.
Poor service has greater consequences when consumer choice is limited.
The apparent contradiction with Treasury data
Treasury described Direct Express as maintaining 94% or higher satisfaction, while the CFPB later alleged long waits, dropped calls, inadequate dispute notices, and failures involving prepaid-account rights. (fiscal.treasury.gov)
Several explanations can coexist:
- The Treasury satisfaction data may have measured the entire cardholder base.
- CFPB allegations focused on users with problems requiring live assistance.
- Satisfaction may have been measured before the most heavily criticized period.
- A high percentage can mask poor outcomes for a smaller but vulnerable subgroup.
- Different vendors may have produced different experiences.
- Survey methodology and complaint evidence measure different questions.
The 94% figure asks, in effect, whether cardholders generally liked or accepted the program. The regulatory complaint asked whether the institution complied with specific duties when consumers reported errors or needed help.
One does not automatically disprove the other.
The stronger conclusion is that Direct Express may have performed reliably for routine payment delivery while providing much weaker service in complex cases.
Outsourcing did not remove bank responsibility
The amended CFPB complaint said Comerica outsourced several Direct Express functions to two vendors. Those functions allegedly included:
- Card issuance and funding
- Account statements and disclosures
- Stopping preauthorized transfers
- Telephone customer service
- Complaint management
- Error investigations
- Provisional credit
- Communicating investigation results
One vendor reportedly handled several hundred thousand accounts, while the other handled the remaining millions.
The complaint emphasized that outsourcing did not transfer the bank’s legal obligations under Regulation E and other federal law.
This is a common operational model in financial services. A bank remains legally responsible while specialist contractors run the phone system, card platform, or investigation workflow.
For cardholders, the distinction is mostly invisible. They call the Direct Express number and experience the vendor as though it were the bank and program itself.
What the dismissal means
The CFPB’s enforcement page records that the original complaint was filed on December 6, 2024, amended on March 13, 2025, and dismissed without prejudice on April 11, 2025. The court terminated the action on the dismissal date.
The dismissal means no final court judgment established Comerica’s liability on the alleged conduct.
It also does not erase the underlying operational data quoted in the filed complaint. The wait times, complaint counts, and vendor-performance percentages remain claims made by a federal regulator in court documents, but they were not tested through a completed trial or final merits ruling.
Reportage must preserve both facts.
Presenting the allegations as proven misconduct would be inaccurate. Ignoring the figures because the case was dismissed would also remove some of the most detailed public information available about Direct Express customer-service performance.
Current support during the bank transition
Treasury’s Direct Express page, updated June 22, 2026, says customer service remains available 24 hours a day, seven days a week and directs cardholders to use the number on the back of the card.
The program is transitioning to a new financial-agent structure, with different service paths based on card series. That makes issuer identification important during the migration.
Twenty-four-hour availability describes the operating schedule. It does not reveal average speed of answer, abandonment rate, first-contact resolution, or dispute turnaround.
Those service-quality measures remain separate.
What a useful Direct Express service scorecard would show
A transparent report would include:
| Measure | Why it matters |
| Median and 90th-percentile wait time | Averages can hide extreme waits |
| Call abandonment rate | Shows how many users give up |
| Involuntary disconnection rate | Separates abandonment from dropped calls |
| First-contact resolution | Measures whether one call solves the issue |
| Fraud-claim resolution time | Tracks access to disputed funds |
| Replacement-card delivery time | Measures interruption after loss |
| Complaint rate per 10,000 active cards | Adds a denominator |
| Performance by service vendor | Exposes unequal experiences |
| Payment-day versus ordinary-day results | Identifies peak-load failures |
| Accessibility and language outcomes | Measures support for vulnerable users |
Treasury’s 2020 release supplied a broad satisfaction result. The CFPB litigation supplied narrow but detailed allegations about failure periods.
Neither source provides this complete scorecard.
Data limitations
Treasury’s 94% satisfaction figure was published in January 2020 and covered an asserted 10-year history. The announcement did not disclose survey methodology. (fiscal.treasury.gov)
The CFPB call-center figures were allegations contained in a civil complaint. The case was dismissed without prejudice before a final judgment.
The June and July 2019 complaint totals do not include total call volume, so a complaint rate cannot be calculated from the published passages.
The CFPB’s 2023 Issue Spotlight discusses multiple public-benefit programs rather than Direct Express alone.
No current 2026 official report reviewed provides average Direct Express call wait time, abandonment, dispute resolution, replacement-card performance, or customer satisfaction under the incoming financial-agent structure.
Frequently asked questions
What satisfaction rating did Treasury report?
Treasury said in January 2020 that Direct Express had maintained satisfaction ratings of 94% or higher for the previous 10 years. (fiscal.treasury.gov)
Did Direct Express callers wait more than an hour?
The CFPB alleged that callers on two vendor-managed lines waited more than an hour on average during March, April, and May 2022, with some waits reaching two and a half hours.
Were those allegations proven in court?
No. The CFPB dismissed the action without prejudice in April 2025, and no final judgment resolved the merits.
How many access complaints were reported?
The CFPB complaint alleged 274 complaints in June 2019 and 358 in July 2019 from users unable to reach one vendor’s service line.
Does Direct Express offer 24-hour support?
Treasury’s current page says customer service is available 24 hours a day, seven days a week.
Why does live support matter so much?
Some Regulation E protections and investigation deadlines depend on when a cardholder reports a lost card, unauthorized transfer, or account error.
Can a high satisfaction score coexist with poor call service?
Yes. Most cardholders may experience routine deposits and purchases without difficulty, while a smaller group needing complex support experiences long waits or failed resolution.
Direct Express service cannot be judged from one percentage or one lawsuit. The available record points to a program that may work smoothly for routine benefit delivery while becoming far less reliable when cardholders need a human being to restore access, investigate fraud, or explain what happened to essential income.
