Complaint database expansion draws concerns

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Oct. 15, 2012 – NAFCU is continuing to express concerns to the Consumer Financial Protection Bureau about a consumer complaint database that the agency is looking to soon expand beyond credit cards.

Last week, the CFPB announced it dropped the “beta” tag from its consumer credit card complaint database and is proceeding with plans to expand the range of complaints it makes public beyond just credit cards. The CFPB also collects consumer complaints relating to deposit accounts, mortgage loans, student loans and consumer loans.

Earlier this year, the CFPB released a final policy statement on the database, which so far, is limited to credit card complaints. The CFPB also issued a proposal for comment on extending the database to financial products other than credit cards. NAFCU issued a Regulatory Alert and a comment letter this summer.

NAFCU continues to communicate to the CFPB what it has already stated in in-person meetings and an earlier comment letter: that the practice of making such complaints public will cause reputational risks that can affect stability. The association has repeatedly urged against disclosing specific complaints or names of institutions involved.

Currently, the individual-level field data collected by the CFPB, includes:

  • the type of complaint;
  • the date of submission;
  • the consumer’s zip code;
  • the company cited in the complaint; and
  • actions taken on the complaint, including whether the company’s response was timely, how the company responded and whether the consumer disputed the company’s response.

The database does not include confidential information about a consumer’s identity.

The CFPB says it has the authority to collect and make public such information under the Dodd-Frank Act, which authorizes the bureau to make public information about the markets for consumer financial products and services.