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NAFCU Regulatory Affairs Counsel PJ Hoffman told CFPB Monday that the member compliant process credit unions have in place through NCUA is "second to none" and detailed NAFCU's opposition to the bureau's proposed policy to allow disclosure of consumer complaint narrative data.

Under the CFPB's proposed policy, the bureau would offer consumers making complaints the option to share the narrative behind the complaint on the public database, which the bureau said would "help the public detect specific trends in the market, aid consumer decision-making, and drive improved consumer service." Hoffman detailed numerous problems with the proposal:

• Risk to consumers: "Disclosing narrative fields increases the likelihood that personal information will be inadvertently released," Hoffman wrote. This could cause harm to the consumer, he added.
• Reputation risk and safety and soundness concerns: "There's no mechanism to ensure the complaints are valid," Hoffman explained. He wrote that the focus of the narrative disclosures will be on the number of complaints and the unverified stories, not whether the narrative is accurate.
• No direct benefits to consumers: Hoffman said "to provide a direct benefit for the consumer that wants to share their experiences with others, the CFPB would need to provide a place for consumers to share both positive and negative experiences." This compliant database only accommodates negative experiences.
• No-win position: "The proposed policy statement would result in generic statements from credit unions and other financial institutions," Hoffman wrote, since identifiable information would have to be redacted. The published responses would not help consumers.

Hoffman also noted, among other things, the double effort this proposed policy would force on credit unions, which would have to respond to member complaints twice.