CFPB Finalizes Policy Statement on Publishing Consumer Complaint Narratives

The CFPB has issued a final policy statement providing guidance on how the agency will publish online “consumer complaint narratives” about financial institutions with more than $10 billion in assets. 

Background. The CFPB launched its “Consumer Complaint Database” in June of 2012. The database publishes online data about consumer complaints about several types of financial products, such as credit cards, mortgages, bank accounts, private student loans, and more. Currently, complaints are published with generic descriptions, such as “using a debit card,” “fraud or scam,” or “loan servicing,” without including any narrative information written by the consumer.

In July of 2014, the CFPB proposed a policy to expand the public disclosure of its complaint data to include “unstructured consumer complaint narrative data,” meaning the written portion of a consumer's complaint. Many banking industry commenters raised privacy and reputational concerns by the publication of unverified complaint narratives on an official government website.

The new complaint process. The final policy statement moves ahead with publishing consumer narratives on the CFPB's Consumer Complaint Database, with some minor changes from the originally proposed policy.

  • Submitting the complaint. Consumers must affirmatively opt-in to sharing complaint narratives and can withdraw their consent at any time. 
  • Scrubbing and screening information. The CFPB will not verify the information published in the complaint narratives beyond confirming that the consumer has or had a relationship with the company complained about. It also will screen out duplicate submissions and remove personal information, such as names and account numbers.
  • Company response. After the CFPB forwards a complaint to a company, the company may choose to publicly respond to the complaint. However, the company must select its response from a set list of structured responses (which the CFPB has not yet completed). A company cannot respond with its own narrative, as was originally proposed.
  • Publication. As under the CFPB's current policy, generic complaint information will be published within 15 days after the company receives a copy of the complaint. The narrative portion will be added within 60 days and will include the company's structured response if the company chooses to publicly respond.
  • Effective date. The Bureau will not publish any narratives for at least 90 days after the final policy has been published in the Federal Register.

For more information, see the CFPB press release and blog post. For more information about the CFPB's consumer complaint process, see the 2013 Consumer Response Annual Report.  

The CFPB also released a request for comment on possibly collecting and publishing positive consumer feedback and data about specific companies. Comments are due within sixty days after the request is published in the Federal Register. View the request here.