A report from the Office of the Inspector General of the Federal Reserve Board and Consumer Financial Protection Bureau released a report recently that details how consumer complaints are used within the bureau and who has access to some of the sensitive information that are included with complaints. The report sheds some interesting light on how complaints are used within the CFPB and who has access to different types of data that accompany complaints filed by consumers.
A copy of the OIG’s report can be accessed by clicking here.
By and large, the OIG’s report gave a thumbs up to the CFPB for how it handles consumer complaints and the personally identifiable information (PII) that occasionally accompanies some of those complaints. While finding that the CFPB’s Office of Consumer Response “inconsistently approved access to two complaint-sharing tools and did not assess whether users needed continued access to one tool or to network drive folders containing complaint reports,” the report noted that the department began “taking actions to improve its access processes,” during the evaluation period.
The report laid out a series of recommendations aimed at improving access authorization to consumer complaints and improving access to shared network folders that contain complaint information.
Along with its recommendations, the report details how complaint data is stored and made available to CFPB employees. For example, there are three complaint sharing tools for employees within the CFPB — Complaint Analytics, Advance Analytics, and the Complaints themselves. Complaint Analytics allows employees to search complaints and perform analysis on the information within the database. There are two components, one of which makes PII available to authorized users. The report also details how many employees within each of the CFPB’s departments have access to complaint information.
The complaint data is heavily used within the CFPB’s Supervision, Enforcement, and Fair Lending (SEFL) unit, according to the report.
We interviewed 17 SEFL users and learned that 94% of them relied on internal complaint data for their work. Of those interviewed, 82% of users reported using the internal complaint data for supervisory activities, 59% for research, 12% to support legal actions, and 6% to prepare products. For example, as part of supervisory activities, seven SEFL users indicated that complaint data contribute to determining the examination schedule. Also, some SEFL users stated that complaint data help to inform enforcement actions by identifying potential violations or supporting leads that have been identified through the examination process.