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CFPB launches public review of complaint database

Joe Mont | March 2, 2018

Continuing its top-down reassessment of operations and policies, the Consumer Financial Protection Bureau on March 1 issued a Request for Information about the Bureau’s database and public reporting of consumer complaints.

The Bureau is seeking comments and information from interested parties on the usefulness of complaint reporting and analysis, as well as specific suggestions or best practices for complaint reporting.

This is the sixth in a series of RFIs announced as part of Acting Director Mick Mulvaney’s call for evidence to ensure the Bureau is fulfilling its proper and appropriate functions to best protect consumers. This RFI will provide an opportunity for the public to submit feedback and suggest ways to improve outcomes for both consumers and covered entities.

The next RFI in the series will address the Bureau’s rulemaking processes, and will be issued next week.The RFI on complaint reporting is also  available here. Among the suggested topics for commenters:

  • The usefulness of complaint reporting and analysis to external stakeholders, including but not limited to financial industry participants, government agencies, consumer advocacy and financial education groups, trade associations, academic and research organizations, and consumers; and
  • Specific suggestions or best practices for complaint reporting and publication given the Bureau’s statutory objectives, including ensuring that markets for consumer financial products and services operate transparently and efficiently to facilitate access and innovation.
  • Specific, statutorily-permissible suggestions regarding the frequency of the Bureau’s reporting on consumer complaints;
  • Specific, statutorily-permissible suggestions on the content of the Bureau’s reporting on consumer complaints;
  • Whether the Bureau should include more, less, or the same amount of reporting on State and local complaint trends;
  • Whether it is net beneficial or net harmful to the transparent and efficient operation of markets for consumer financial products and services for the Bureau to publish the names of the most-complained-about companies;
  • Whether the Bureau should provide more, less, or the same data fields in the Consumer Complaint Database;
  • Whether the Bureau should provide more, less, or the same amount of context for complaint information, particularly with regard to product or service market size and company share;
  • Whether the Bureau should supplement observations from consumer complaints with observations of company responses to complaints;
  • Whether the Bureau should share more, less, or the same amount of information on month-to-month trends;
  • Whether the Bureau should share more, less, or the same amount of information on particular products and services;
  • Should the Bureau continue to analyze data for seasonal fluctuations? If so, how?;
  • Should the Bureau provide more, less, or the same amount of context for complaint information, particularly with regard to product and service market size and company share, including what data set(s) or data source(s) the Bureau should use;
  • Whether the Bureau should provide the public with a publication schedule;
  • Whether the Bureau should notify the most-complained-about companies of their inclusion in a Bureau report prior to publication and invite company comment;
  • Whether the Bureau should devote resources to building tools to enable users to analyze complaint information; and
  • Whether the Bureau should expand, limit, or maintain the same level of access to complaint information available to external stakeholders such as financial institutions and the public.

The CFPB will begin accepting comments once the RFI is printed in the Federal Register, expected on March 7. The RFI will be open for comment for 90 days. More information about the call for evidence is available here.