Alert April 16, 2013

CFPB Issues Final Policy on Disclosure of Consumer Complaint Data

The CFPB issued a final policy statement providing guidance on how it plans to publicly disclose certain consumer complaint data. The policy statement provides that the CFPB will extend existing disclosure practices applicable to consumer complaints about credit cards to other types of consumer financial products. The additional financial products include bank accounts and services, private student loans, and other consumer loans. The CFPB originally published a notice of proposed policy making in June 2012 (see June 26, 2012 Alert), to which it received comments to the proposed expansion and the type of information collected and/or disclosed. In response to the comments, the CFPB decided to (1) limit zip code disclosures to five digits in order to decrease the ability to identify consumers; (2) not disclose discrimination field data in the public database; and (3) develop the technical ability to publish additional date fields, including the company’s response date.