From Collector: Contextualizing Consumer Complaints

The CFPB takes some steps to improve its complaint database, but the work is not done.

1/17/2020 10:30 AM

CFPBCollector MagazineNewsAdvocacy
From Collector: Contextualizing Consumer Complaints

Last fall the Consumer Financial Protection Bureau made several changes to its Consumer Complaint Database, which were in line with ACA International’s advocacy on this issue over the past several years.

Despite some important improvements, ACA and its members continue to push for more clarity so the complaint database better reflects the positive impact of the accounts receivable management industry and its work with consumers, Vice President and Senior Counsel, Federal Advocacy Leah Dempsey reports in the January issue of Collector magazine.

ACA has urged the bureau to provide better contextualization of the number of complaints compared to the number of contacts and to do more work to weed out mere inquiries, compared to actual complaints or violations of law.

On Sept. 18, 2019, the CFPB announced that it will continue the publication of consumer complaints, data fields and narrative descriptions through its Consumer Complaint Database, while making several enhancements to the information available to users of the database. It also indicated that more changes are to come this year.

“Since its inception, the Consumer Complaint Database has not been without controversy,” CFPB Director Kathy Kraninger said. “When the Bureau asked for feedback in 2018, we received nearly 26,000 comments from a wide array of stakeholders including government officials, consumer groups, companies, academics, and individual consumers. After carefully examining and considering all stakeholder and public input, we are announcing the continued publication of complaints with enhanced data and context that will benefit consumers and users of the database while addressing many of the concerns raised. The continued publication of the database, along with the enhancements, empowers consumers and informs the public.”

The changes it announced included: modified disclaimers to provide better context to the published data; integrating financial information and resources into the complaint process to help address questions and better inform consumers before they submit a complaint; and information to assist consumers who wish to contact the financial company to get answers to their specific questions.

During the CFPB’s Request for Information process, ACA filed two different comment letters urging that changes should be made to the complaint database. We appreciate that some of our concerns were addressed.

ACA’s comments noted that our members overwhelmingly supported “an improved process of classifying consumer submissions to the bureau. As for this specific point, 100% of the ACA members who responded to a recent survey state they would like to see the bureau require consumers to classify their submissions affirmatively as a complaint or inquiry prior to submission. ACA understands, however, that this may be difficult for some consumers; therefore, ACA recommends two possible options for the bureau. One option would be for the bureau to develop a series of questions on the complaint portal to help consumers classify their issues as a complaint or inquiry, which then would direct consumers to different areas of the portal in order to ensure correct routing.”

However, many of ACA’s concerns have not been fully addressed. Most notably, ACA has urged the bureau that more must be done to normalize the data being released to the public beyond just broad disclosures. For example, consumers and others in the marketplace may improperly look at the current number of complaints as an appropriate indicator of performance when, once normalized, the rate of complaints might be quite low compared to the number of contacts with consumers.

ACA also remains concerned that the bureau cites much of its past flawed data in parts of its proposed rule for the Fair Debt Collection Practices Act. As the bureau moves forward in any areas of reevaluating the complaint database, ACA will continue to work to highlight our concerns. Read Dempsey’s complete report for more information on changes to the CFPB consumer complaint database and ACA’s advocacy efforts.

Subscriptions to the Collector magazine digital edition and email notifications for each new issue are available for ACA International members by logging in to ACA International’s website here. Members and nonmembers can also purchase a print subscription. Nonmembers can create a guest profile on ACA’s website to subscribe to available publications.


Follow ACA International on Twitter @ACAIntl and @acacollector, Facebook and request to join our LinkedIn group for news and event updates. ACA International members are welcome to submit news items for possible publication to comm@acainternational.org. Visit our publications page for news submission guidelines and subscriptions to ACA Daily, Collector magazine and Pulse.

Advertising is available for companies wishing to promote their products or services. Be sure to visit the ACA Events Calendar on the Education and Training page to view our listing of upcoming CORE Curriculum and Hot Topic seminars featuring critical educational opportunities for your company.


Subscribe to ACA Daily NEWSROOM

From Collector: Contextualizing Consumer Complaints

Last fall the Consumer Financial Protection Bureau made several changes to its Consumer Complaint Database, which were in line with ACA International’s advocacy on this issue over the past several years.

Despite some important improvements, ACA and its members continue to push for more clarity so the complaint database better reflects the positive impact of the accounts receivable management industry and its work with consumers, Vice President and Senior Counsel, Federal Advocacy Leah Dempsey reports in the January issue of Collector magazine.

ACA has urged the bureau to provide better contextualization of the number of complaints compared to the number of contacts and to do more work to weed out mere inquiries, compared to actual complaints or violations of law.

On Sept. 18, 2019, the CFPB announced that it will continue the publication of consumer complaints, data fields and narrative descriptions through its Consumer Complaint Database, while making several enhancements to the information available to users of the database. It also indicated that more changes are to come this year.

“Since its inception, the Consumer Complaint Database has not been without controversy,” CFPB Director Kathy Kraninger said. “When the Bureau asked for feedback in 2018, we received nearly 26,000 comments from a wide array of stakeholders including government officials, consumer groups, companies, academics, and individual consumers. After carefully examining and considering all stakeholder and public input, we are announcing the continued publication of complaints with enhanced data and context that will benefit consumers and users of the database while addressing many of the concerns raised. The continued publication of the database, along with the enhancements, empowers consumers and informs the public.”

The changes it announced included: modified disclaimers to provide better context to the published data; integrating financial information and resources into the complaint process to help address questions and better inform consumers before they submit a complaint; and information to assist consumers who wish to contact the financial company to get answers to their specific questions.

During the CFPB’s Request for Information process, ACA filed two different comment letters urging that changes should be made to the complaint database. We appreciate that some of our concerns were addressed.

ACA’s comments noted that our members overwhelmingly supported “an improved process of classifying consumer submissions to the bureau. As for this specific point, 100% of the ACA members who responded to a recent survey state they would like to see the bureau require consumers to classify their submissions affirmatively as a complaint or inquiry prior to submission. ACA understands, however, that this may be difficult for some consumers; therefore, ACA recommends two possible options for the bureau. One option would be for the bureau to develop a series of questions on the complaint portal to help consumers classify their issues as a complaint or inquiry, which then would direct consumers to different areas of the portal in order to ensure correct routing.”

However, many of ACA’s concerns have not been fully addressed. Most notably, ACA has urged the bureau that more must be done to normalize the data being released to the public beyond just broad disclosures. For example, consumers and others in the marketplace may improperly look at the current number of complaints as an appropriate indicator of performance when, once normalized, the rate of complaints might be quite low compared to the number of contacts with consumers.

ACA also remains concerned that the bureau cites much of its past flawed data in parts of its proposed rule for the Fair Debt Collection Practices Act. As the bureau moves forward in any areas of reevaluating the complaint database, ACA will continue to work to highlight our concerns. Read Dempsey’s complete report for more information on changes to the CFPB consumer complaint database and ACA’s advocacy efforts.

Subscriptions to the Collector magazine digital edition and email notifications for each new issue are available for ACA International members by logging in to ACA International’s website here. Members and nonmembers can also purchase a print subscription. Nonmembers can create a guest profile on ACA’s website to subscribe to available publications.


Follow ACA International on Twitter @ACAIntl and @acacollector, Facebook and request to join our LinkedIn group for news and event updates. ACA International members are welcome to submit news items for possible publication to comm@acainternational.org. Visit our publications page for news submission guidelines and subscriptions to ACA Daily, Collector magazine and Pulse.

Advertising is available for companies wishing to promote their products or services. Be sure to visit the ACA Events Calendar on the Education and Training page to view our listing of upcoming CORE Curriculum and Hot Topic seminars featuring critical educational opportunities for your company.


Subscribe to ACA Daily NEWSROOM

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