The Consumer Financial Protection Bureau (“CFPB”) has published its final policy statement on how the Bureau plans to publicly disclose consumer complaints regarding consumer financial services and products via its Consumer Complaint Database.
The CFPB launched its Consumer Complaint Database in June 2012; according to the Bureau, the Web-based database has collected more than 558,800 consumer complaints as of March 1, 2015. The consumer narratives are provided anonymously and include the date of submission, the consumer’s zip code, the name of the company, the type of product, the issue the consumer is complaining about and how the company has handled the complaint.
Last July, the CFPB announced its intentions to publicly share consumer complaint narratives. The final policy statement details the specific procedures and safeguards the Bureau has put into place to publish the narratives:
Consumers must opt-in to share their complaint by checking a consent box when they file the complaint at consumerfinance.gov. They may also opt-out at any time.
Personal information will be deleted from publicly shared narratives.
Companies have the opportunity to select from a set list of response options to describe how the complaint is being handled. There is no obligation to respond, and companies have 180 days from the time the complaint is sent to them to select a response.
Complaints must meet certain requirements in order to be published: (1) it must be submitted through the CFPB website; (2) it must not be a duplicate submission; and (3) the consumer must have a confirmed relationship with the financial institution.
Complaints will only be listed in the database after the company responds or has had the complaint for 15 days, whichever comes first.
Complaints will only be listed publicly after the company provides its response or has had the complaint for 60 calendar days, whichever comes first.
The CFPB said that in order to financial institutions to familiarize themselves with the new system, the Bureau will not publish any consumer narratives for at least 90 days after the publication of the policy in the Federal Register. The Bureau published the final policy statement in the Federal Register on March 24, 2015.
The attorneys at Glass & Goldberg in California provide high quality, cost-effective legal services and advice for clients in all aspects of commercial compliance, business litigation and transactional law. Call us at (818) 888-2220, send an email inquiry to info@glassgoldberg.com or visit us online at glassgoldberg.com to learn more about the firm and to sign up for future newsletters.
