CFPB Announces Review of Consumer Complaint Process

The Consumer Financial Protection Bureau has announced the latest area of its operation that it is opening up for review – the consumer complaint process.

This marks the sixth such review that the CFPB has rolled out in the past two months. The others include: the civil investigative demand letter process, the administrative adjudication process, the external engagement process, the supervision process, and the enforcement process.

Since its inception, the CFPB has accepted and published complaints from consumers regarding different areas of the financial services industry. One of the largest sources of consumer complaints have been those related to the debt collection process.

The CFPB is seeking feedback on the following areas of the consumer complaint process:

1. Specific, statutorily-permissible suggestions regarding the frequency of the Bureau’s reporting on consumer complaints
2. Specific, statutorily-permissible suggestions on the content of the Bureau’s reporting on consumer complaints, including:
   1. Whether the Bureau should include more, less, or the same amount of reporting on State and local complaint trends
   2. 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
   3. Whether the Bureau should provide more, less, or the same data fields in the Consumer Complaint Database
   4. 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;
   5. Whether the Bureau should supplement observations from consumer complaints with observations of company responses to complaints
   6. Whether the Bureau should share more, less, or the same amount of information on month-to-month trends
   7. Whether the Bureau should share more, less, or the same amount of information on particular products and services
3. Specific suggestions on the reporting methodology, including:
   1. Should the Bureau continue to analyze data for seasonal fluctuations? If so, how?
   2. 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
4. Specific, statutorily-permissible suggestions for the publication process of consumer
   complaint information, including
   1. Whether the Bureau should provide the public with a publication schedule
   2. Whether the Bureau should notify the most-complained-about companies of their
      inclusion in a Bureau report prior to publication and invite company comment
   3. Whether the Bureau should devote resources to building tools to enable users to
      analyze complaint information
   4. 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