CFPB Proposes Feedback Mechanism for Consumer Complaint Handling

The Consumer Financial Protection Bureau today announced plans to change the “dispute” function in its consumer complaint database to allow complainants to take a short survey on the company’s response to their complaints. The survey information — a one-to-five rating of the company’s response and an optional narrative — would be shared with the company that is the subject of the complaint and, with the complainant’s permission, be posted in the complaint database.

This process contrasts with the present dispute process, which does not allow for positive feedback and provides less information about the company’s response. The bureau said it expects companies to benefit when positive complaint handling stories are shared and that it anticipates implementing this revised feedback process in early 2017.

The bureau is treating this change as an “information collection” subject to the Paperwork Reduction Act, not as a legislative rule subject to the rulemaking procedures of the Administrative Procedure Act. The American Bankers Association has expressed concern over the CFPB’s increasingly common practice of using information collections as a substitute for notice-and-comment rulemaking. Comments are due by Sept. 30. For more information, contact ABA’s Jonathan Thessin.