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The CFPB's Consumer Complaint Database Will Soon Include Consumers' Complaint Narratives. Are You Ready?

In case you missed it, the CFPB is trying to become the next Yelp or Angie's List.

The CFPB began accepting complaints from consumers as soon as it opened its doors in 2011—with over half a million currently on file.  In June of 2012, it started publishing a limited amount of data from the complaints on its website. Now, it has decided to give consumers a platform to "publicly share their stories." 

The CFPB's website already allows a consumer to describe his or her complaint in narrative form in a text box on the complaint webpage. The consumer can also attach documents to the complaint. The CFPB forwards the complaint to the company, requests a response, gives the consumer a tracking number, and updates the consumer on the status of the resolution.

In March, the CFPB revised its consumer complaint policy to allow consumers to publish their grievances—in their own words—on the CFPB's website.   Beginning later this month (May 2015), when consumers submit complaints to the CFPB, they will have the option to check a box to share their narrative. The narratives will have names, telephone numbers, account numbers, Social Security numbers, and other identifiers redacted. The CFPB will not, however, verify the truth or accuracy of the facts asserted in the consumer's complaint. 

Banks and other companies will be given the option to select from a limited list of structured response options within 180 days after the consumer complaint is routed to them. The response cannot be customized. Actually, the final policy says that the financial institution can "recommend" one of the pre-set response to the CFPB, but the CFPB reserves the right to reject the response.

Complaints will be listed in the public database only after the financial institution responds to the complaint or after it has had the complaint for 15 days, whichever comes first. The CFPB will publish the consumer complaint narrative when the financial institution provides its public-facing response, or after the financial institution has had the complaint for 60 days, whichever comes first. If, within 15 days of receiving a notice of the complaint, a financial institution tells the CFPB that it has no record of a financial relationship with the complaining person, or if the financial institution tells the CFPB that it believes the complaint is fraudulent, the CFPB is not supposed to publish the complaint.

Despite the fact that this sort of information can become stale and of marginal value over time, the CFPB has determined that complaints will remain on the public database indefinitely.  Furthermore, the final policy fails to address whether complaints will be removed or changed when a financial institution merges or is acquired, or when a division is spun out.

I have written and spoken before about the importance of online reputation management for financial institutions. This development underscores the need for each financial institution to have a comprehensive online reputation management strategy. Aside from behaving honestly and ethically, the best (but not the only) thing a financial institution can do to protect its reputation online is to inundate the web with positive content. While there are some legal concerns to address when a financial institution expands its presence on the web, this strategy is the most effective way to ensure that the overall narrative reflects the financial institution's mission and message.


Image credit: matt cordell using (x-ray delta one)



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