The CFPB continues to work to expanding the feedback consumers can supply and publicly disclose when submitting a compliant to the Bureau’s consumer complaint portal. On November 29, the CFPB published a new notice in the Federal Register inviting comments on the Bureau’s submission of the proposal to the Office of Management and Budget (OMB). The CFPB also submitted a Supporting Statement to OMB which includes the Bureau’s responses to comments it received on the proposal. Comments on the Bureau’s latest proposal must be submitted by December 29, 2016.
In August 2016, the Bureau published a proposal in the Federal Register describing the additional information that the Bureau intends to collect during the consumer complaint process. We discussed that proposal in blog post that you can read here. Simply put, the Bureau’s proposal would allow consumers to opt-in and provide additional feedback publicly by rating the company’s handling of the complaint on a one-to-five scale and providing a narrative description in support of the rating. The proposed rating and narrative feature would replace the existing “dispute” option that currently allows the consumer to indicate dissatisfaction with a company’s response.
Comments on the August proposal were due by September 30. Of note were comments from various trades groups who objected to the proposed changes. For example, several groups claimed that the rating system is highly subjective and will not provide sufficient benefits to consumers. Trade groups also pointed out that the new consumer survey is subjective in several ways, including the arbitrary nature of the proposed survey’s one-to-five scale.
This has led some to liken the Bureau’s complaint portal to a “consumer finance ‘Yelp’-style rating platform.”
We share the financial industry’s concerns about the Bureau’s latest moves. While the CFPB claims that the consumer narratives will “empower consumers” and enable them to “make more informed decisions,” we fear that the Bureau’s proposed disclosures may lead to widespread disclosure of unverified data. While Bureau claims that it “take[s] steps to confirm a commercial relationship between the consumer and company,” it does not take any steps to verify the allegations before publishing them on the complaint portal. Companies can take little comfort in the Bureau’s disclaimer, as most consumers will assume that the complaint is true because it appears on the CFPB’s website. Unfortunately, the publication of these consumer narratives will serve to harm company reputations just as much as it empowers consumers.
This step is just the latest in the Bureau’s ongoing efforts to develop and enhance information collection and publication in connection with the consumer compliant process.
In June 2012, the Bureau launched its Consumer Complaint Database.
In July 2014, the Bureau issued a proposed policy statement proposing to expand the Bureau’s Consumer Complaint Database to allow consumers to opt-in and publicly disclose complaint narratives.
In March 2015, the Bureau finalized that proposal and outlined its plan in a Final Policy Statement on March 29, 2015.
In June 2015, the Bureau began publishing consumer complaint narratives.
Tags: Consumer Complaints
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