Yelp better watch out, there is a new competitor in the business—the CFPB.
Earlier this year, the CFPB released a Policy Statement outlining its plan to publish consumer complaint narratives in its consumer complaint database. Last week, the new policy went into effect, with an initial release of 7,700 consumer narratives.
The CFPB maintains an online, searchable database that aggregates complaints on most consumer financial products and services. As of June 1, 2015, the database included over 627,000 complaints, with mortgage and debt collection having the most complaints. Consumers now have the right to ‘opt-in’ to publicly share their narratives in the database. The CFPB reports over half of consumers have elected to do so.
In the CFPB’s press release last week, Director Richard Cordray noted, “Every complaint tells us what people are facing in the financial marketplace. Publishing these consumer stories today is a historic milestone that we believe will lead to better outcomes for everyone.”
Everyone? Well, maybe not everyone.
The CFPB’s Policy Statement specifically notes that the industry is generally opposed to disclosing narratives. A few months ago in a blog post, we outlined the key problem with this approach—namely, the CFPB is now publishing complaints that may be unverified, unsubstantiated and unproven. Have you ever had a customer say something (possibly) untrue to avoid paying a loan? What about a frivolous or irrelevant complaint?
There are other industry concerns as well. One is that a company cannot adequately respond to or rebut the consumer’s narrative. The database offers a finite list of structured responses, but a company cannot address the consumer’s public narrative with its own narrative. Similarly, there is no dependable way to determine that the complaint was submitted by the consumer (as opposed to a third party such as a family member or a credit repair organization). Some companies are also concerned that the data will be used by competitors.
Sampling a few of the complaint narratives is fascinating, and, in some ways, scary. Some include legal conclusions (e.g., the company violated the FCRA or FDCPA); others even include moral conclusions (e.g., the company charged “unethical” fees). Of course, there are many with legitimate issues (e.g., identity theft or incorrect credit reporting), but there is no way to filter the legitimate complaints.
Financial institutions should expect a significant increase in the number of complaints logged with the CFPB. As we have stressed before, every company needs to sufficiently address consumer complaints and maintain comprehensive records. A complaint response protocol is one of the fundamental elements in a company’s compliance management system.
But, I guess everything you read on the Internet is true, right?