WASHINGTON—CUNA has sent a letter to the CFPB in response to the agency Request for Information (RFI) on the potential collection and sharing of consumer compliments about providers of consumer financial products and services.
Noting it has filed three previous letters with the CFPB related to the consumer complaint database, in which it did not support the public release of certain complaint information that is separate from, and in addition to, the CFPB’s periodic reports and analyses, CUNA noted that while credit unions have not been the subject of a sizable number of complaints and seem unlikely to become so, “we nonetheless believe that the public data release, including feedback that is purportedly positive, could have unintended consequences. CUNA supports providing fundamental fairness to consumers, and also to financial institutions, whether they are credit unions or not.”
CUNA called on the CFPB to “take appropriate steps to verify the legitimacy and accuracy, to the extent possible, of a consumer’s complaint and/or compliment prior to public disclosure. Under the current system, we believe it is possible that some institutions are effectively unable to respond to consumers’ narrative description of complaints due to privacy restrictions.”
CUNA said it also has concerns over the handling of complaints related to companies, and urged CFPB to “explore ways in which to modify the user interface of the database to make it more likely that consumers will access and give weight to positive feedback (i.e., complaint resolution).”
CUNA further provided a list of metrics it would like to see used in the event CFPB implements such an approach.
CUNA also noted that outside of its current complaint handling operation, the CFPB is contemplating another possible avenue for highlighting positive company behavior that would involve soliciting, collecting, and sharing consumer compliments that would entail a new submission type, channel, and process for the CFPB as well as a new database to list such compliments.
“The CFPB maintains a feature on its website called Tell Your Story, which gives consumers the opportunity to share their experiences with consumer financial products and services,” CUNA noted in its letter. “These submissions are reviewed by CFPB staff and help the CFPB understand current issues in the financial marketplace. This channel could operate as-is and instances of consumer compliments could be shared with the public.
“We do not support this potential approach,” CUNA continued. “We are surprised the CFPB, as a data driven agency, is considering such an approach that would likely facilitate only anecdotal stories with no validation. Furthermore, this type of public disclosure may unfairly promote institutions supervised by the CFPB, because other institutions, such as most credit unions that are examined and supervised by their prudential regulators, would not have such responses posted for public view.
“Specifically, since this approach would not tie a compliment to a complaint submitted through the CFPB’s database, it would be very difficult, if not impossible, to verify the legitimacy of the compliment, particularly since it would exclude any personally identifiable information,” CUNA’s letter goes on to say. “Purely textual information without specific metrics would not allow for comparability by consumers. This is especially problematic since the CFPB has stated that the purpose of the complaint database is to assist consumers in making informed financial decisions.”