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June 20, 2012 – The Consumer Financial Protection Bureau is considering whether it should, at some future time, include narrative field data in its public consumer complaint database, bureau representatives said in a briefing Tuesday attended by NAFCU Regulatory Affairs Counsel Dillon Shea.

The bureau launched the beta version of its public database of consumer credit card complaints Tuesday. The database may be expanded to include complaints about other types of products in the future. That could mean expansion to list complaints about entities other than depository institutions.

The CFPB says the public database will only include data involving providers with more than $10 billion in assets. It is also seeking comments on a proposal to expand the public database to address products such as mortgages and other consumer lending products, checking accounts, savings accounts, check cashing services and remittance services.

Shea said staff confirmed that the system launched Tuesday does consolidate repetitive complaints by the same consumer. That means that if a particular complaint is entered more than once by the consumer, it will appear in the database as a single complaint.

Despite these assurances, NAFCU remains concerned that the database does not provide an accurate and complete picture of all the issues surrounding a consumer complaint. It will be keeping in contact with the CFPB as its work in this area progresses.

"NAFCU understands the CFPB has the authority to investigate legitimate consumer complaints," said NAFCU President and CEO Fred Becker. "Unfortunately, we fear that this new database may open the door to frivolous and unsubstantiated complaints. In addition, given the nature of viral media, disclosing all complaints may paint a misleading picture and trigger reputational risks for solid institutions that could raise safety and soundness concerns for the financial institutions in question."

The CFPB indicated Tuesday that it intends to simply disclose the complaints it receives, without providing any commentary regarding the substance or merits of the complaints.