Compliance Blog

Written by Michael Coleman, Regulatory Compliance Counsel

We previously blogged about the CFPB's Consumer Complaint Database on a couple of occasions, highlighting the (relatively ineffective) disclaimer at the top of the page among other things. In the wake of the release of the CFPB Consumer Complaint Database, we also discussed member complaints and the reputation risks associated with the nature of viral media, NCUA's member complaint procedures, and supervisory committee complaint procedures.

On October 10^th, 2012, the CFPB announced that its Consumer Complaint Database left the beta stage. The CFPB blog had this to say about the move out of beta:

"While we will continue to expand functionality, data fields, and the 'œlook and feel' of the database, after performing for three months as designed and without incident, the database is no longer a beta product."

Another important update to the Consumer Complaint Database is the addition of consumer credit card complaint data going back to December 1, 2011. The Complaint Database previously contained only those credit card complaints received by the CFPB on or after June 1, 2012.

Also, the CFPB has reiterated its intention to include other financial products in the Consumer Complaint Database, from the blog post:

"One potential area for database expansion is the inclusion of additional products and services. Over the summer we asked for public comment on this idea and got a wide range of comments from a range of interested stakeholders. We are in the process of evaluating those comments and anticipate a final Bureau decision in early 2013."

The CFPB's notice for public comment (referenced in the quote above) outlines the CFPB's rationale for expanding the database to include other financial products services in addition to credit cards. NAFCU submitted a comment letter to the CFPB expressing its continued concerns that the release of unverified complaints to the public poses serious reputation risk issues to credit unions given the nature of viral media and the speed at which information is disseminated, and that this expansion will only compound those concerns. This comment letter echoes NAFCU's previous comment letter regarding the Consumer Complaint Database.

Note that the database will only contain information of credit unions directly supervised by the CFPB, those with over $10 billion in assets, and that NCUA has not expressed any intention to create a similar database. However, if a member of a credit union with less than $10 billion in assets submits a complaint to the CFPB, the CFPB will forward the complaint to NCUA's Office of Consumer Protection for resolution according to NCUA's procedures.