Consumer Complaint Database
The CFPB launched the public-facing Consumer Complaint Database in 2012. In November 2013, the CFPB began adding debt collection complaints to the database. Despite significant opposition, in June 2015, the CFPB finalized a policy to add consumer complaint narratives to the Consumer Complaint Database.
Given the CFPB’s broad definition of a complaint to include a consumer’s expression of mere “dissatisfaction” coupled with the CFPB’s admission that it does not verify the substance of complaints for accuracy or even wrongdoing, ACA has serious concerns about the CFPB posting company-level complaint data in its public database. ACA continues to advocate for the CFPB to, at a minimum, develop and implement fair and transparent metrics to normalize the complaint data it makes publicly available on the database, narrow the definition of “complaint” so that it covers only alleged conduct that would be unlawful if true, and to consistently use prominent disclaimers that appropriately describe the limitations of published complaint data.
Complaint Handling RFIs and Proposals
The CFPB has issued several Requests for Information and other proposals related to the Consumer Complaint Database.
- PRA Request: Consumer Complaint Closing Survey (Deadline: Sept. 30, 2016)
- Request for Information: Data Normalization in the Consumer Complaint Database (Deadline: August 31, 2015)
- Request for Information: Consumer Complaint Database and Positive Feedback (Deadline: May 26, 2015)
PRA Request: Consumer Response Intake Form (Deadline: Feb. 27, 2015)
Proposed Policy: Consumer Complaint Narrative Data (Deadline: Sept. 22, 2014)
ACA Comments Related to Complaint Database
ACA International consistently looks for opportunities to advocate for changes to the Consumer Complaint Database to make it more reliable, accurate, and fair. One important way ACA does this is by submitting comments in response to CFPB proposals related to the Consumer Complaint Database and the CFPB’s complaint handling process.
- 09.30-16 - ACA Submits Comments on CFPB’s Proposed Consumer Complaint Closing Survey
- 08.31.15 - ACA Submit Comments on the Consumer Complaint Database: Data Normalization
- 5.26.15 - ACA Submits Comments on the CFPB’S Positive Company Feedback RFI
- 02.27.15 - ACA Submits Comments on the CFPB’S Consumer Response Intake Form
- 02.02.15 - ACA Submits Comments Urging the CFPB to Revise Proposed Company Portal Boarding Form
- 09.22.14 - ACA Submits Comments on the Disclosure of Consumer Complaint Narrative Data
- 07.19.12 - ACA Submits Comments about Consumer Complaint Data
- 02.09.11 - ACA Submits Comments Regarding CFPB’s Proposed Complaint Database