On June 25, 2015, the CFPB published nearly 8,000 consumer complaint narratives on its website for the first time. The CFPB complaint database has been “live” since June 2012. However, the database initially included only basic, anonymized data about the nature of the complaint; including subject matter and a general description of the company’s response to the consumer. With the changes implemented last month, consumers can now publish a detailed narrative of their complaint, without publicly disclosing their private information.
Presently, consumers can submit a complaint (or just tell their story) through the CFPB’s website by:
- Selecting a complaint category, such as mortgages, credit card, or credit reporting;
- Providing information about themselves and the company that is the subject of their complaint;
- Furnishing a detailed description, or “narrative,” of the issue the consumer is complaining about; and
- Deciding whether to “opt in,” which would allow the CFPB to publish the consumer’s complaint narrative, after removing the consumer’s private information. If the company elects to do so, it selects from a list of pre-set response options, such as “company disputes the facts presented in the complaint,” or “company chooses not to provide a public response.” Although the CFPB will verify certain details about the complaint, such as the consumer’s business relationship with the company, it does not verify the facts in the complaint before publication.
The CFPB’s complaint database is also more than a simple collection of consumer complaints. It features an analytical tool enabling any user to filter information based on any of the data points collected by the database – such as geography, issue type, company name – and also enables users to perform a full text search of the complaint narrative. The CFPB uses these analytics to generate a monthly “Complaint Snapshot,” which tracks complaint trends by product type, state, and company, and “spotlights” complaints filed in different parts of the country. The CFPB’s announcement that it will issue monthly Complaint Snapshots can be found here; the July 2015 Complaint Snapshot report – the first such report generated by the CFPB – can be accessed here.
The CFPB’s complaint database has drawn criticism, including that: (1) the database may contain inaccurate information because the CFPB does not verify the facts underlying consumers’ complaints; (2) the database provides a skewed perspective to consumers, given that the database only contains data about entities large enough for the CFPB to regulate; and (3) the database limits the ability of companies to more fully respond to consumers’ public complaints beyond the pre-set selections provided by the database (though whether companies would actually choose to provide narrative responses if given the opportunity is an open question, due to privacy concerns and customer relationships). See, e.g., articles from American Banker, The Wall Street Journal, and USA Today. Despite the criticism, however, the CFPB’s expanded database will provide important insight into industry trends as the CFPB sees them (possibly through the complaints the CFPB chooses to “spotlight”), which should preview the direction that the CFPB’s regulatory and enforcement efforts will take.