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Financial Services Law Insights and Observations

CFPB releases RFI on complaint reporting

Federal Issues RFI CFPB Succession Consumer Complaints

Federal Issues

On March 1, the CFPB released its sixth Request for Information (RFI) in a series seeking feedback on the bureau’s operations. This RFI solicits public comment regarding “potential changes that can be implemented to the Bureau’s public reporting practices of consumer complaint information.” Under the Dodd-Frank Act (Dodd-Frank), one of the Bureau’s primary functions is “collecting, investigating, and responding to consumer complaints.” Dodd-Frank requires the Bureau to annually report to Congress information and analysis of the consumer complaints it receives, and to include an analysis of complaints in its semi-annual reports to the president and certain congressional committees. In addition to its specific statutory obligations, the Bureau also produces monthly complaint reports, special edition complaint reports, and a variety of reports from the Bureau’s special population offices relating to consumer complaints.

The RFI broadly requests feedback on all aspects of consumer complaint reporting and publication practices but also highlights specific topics on which comment is requested, including suggestions consistent with the Bureau’s statutory obligations on (i) the frequency of complaint reporting; (ii) the data fields provided in the Consumer Complaint Database; (iii) whether the Bureau should supplement consumer complaints with observations of company responses to complaints; (iv) the inclusion of information related to product and service size and company share; and (v) whether companies should be notified of their inclusion in a public report prior to publication. The RFI is expected to be published in the Federal Register on March 7. Comments will be due 90 days from publication.