CFPB Publishes RFI on Consumer Complaint Database

The Consumer Financial Protection Bureau is finally at the end of the line after releasing the last in a series of 12 Requests For Information, seeking input on how the federal regulator manages its entire operation.

The last RFI was issued yesterday, on the topic of how the bureau handles consumer complaints and inquiries.

The other requests were on its civil investigative demand letter process, its administrative adjudication process, its enforcement process, its supervision program, how it conducts external engagements, how it manages its consumer complaint database, its rulemaking process, its adopted rules and rulemaking authority, its inherited rules, its guidance materials, and its financial education activities.

One of the primary components of the CFPB’s operations is the consumer complaint database, which provides individuals with an outlet to share issues about financial services organizations with the federal government. The database just recently had its 1 millionth complaint published.

Among the areas of consumer complaints that the CFPB is seeking information are:

1. Specific statutorily-permissible suggestions regarding how the Bureau currently allows consumers to submit complaints and inquiries, including:
   1. Should the Bureau require consumers to classify their submission affirmatively as a consumer complaint or inquiry prior to submission?
   2. How should the Bureau explain the difference between a consumer complaint and a consumer inquiry to consumers at the point of submission?
   3. Should the Bureau develop a process for companies to reclassify consumers’ submissions? If so, what criteria should the Bureau establish to help companies differentiate consumer complaints from consumer inquiries?
2. Specific statutorily-permissible suggestions regarding the Bureau’s consumer complaint processes, including:
   1. The Bureau currently receives complaints via six channels: website, referral from Federal and State entities/agencies, telephone, mail, fax, and email. Should the Bureau add or discontinue any channels for accepting complaints?
   2. Consistent with the Dodd-Frank Act’s definition of “consumer,” the Bureau currently allows consumers to authorize someone else (e.g., lawyer, advocate, power of attorney) to submit complaints on their behalf. Should the Bureau expand, limit, or maintain the ability of authorized third parties to submit complaints?
3. Specific statutorily-permissible suggestions regarding the Bureau’s consumer inquiry processes, including:
   1. The Bureau currently accepts consumer inquiries via telephone and mail. Should the Bureau add or discontinue any channels for accepting inquiries?
   2. Should the Bureau develop web chat systems to support consumers’ submission of inquiries?
   3. Should the Bureau develop a process for companies to provide timely responses to consumer inquiries sent to them by the Bureau? If so, how should the Bureau balance its objective of providing timely and understandable information to consumers14 with its objective of reducing unwarranted regulatory burden on companies15?
   4. Should the Bureau publish data about consumer inquiries? If so, what types of data or analyses about consumer inquiries should be shared with the public?