CBA Comments on Proposed Addition of Consumer Narratives to the CFPB Complaint Portal

CBA Comments on Proposed Addition of Consumer Narratives to the CFPB Complaint Portal

Washington, D.C. (September 23, 2014) – The Consumer Bankers Association (CBA) has written to the Consumer Financial Protection Bureau (CFPB) commenting on the Bureau’s proposed addition of consumer complaint narratives to the CFPB’s Consumer Complaint Portal. While CBA supports the Bureau’s ability to confidentially collect complaint data in order to better serve consumer complaint resolution, CBA strongly opposes the public disclosure of any consumer complaint information, including narratives.   

CBA believes the Bureau’s proposal is ill-advised and creates bad policy for a number of reasons, primarily:

  1. The CFPB is under no mandate to publish consumer complaint data and has a statutory responsibility to protect sensitive consumer information.
  2. The proposed policy does not adequately protect consumers’ personally identifiable information, thus creating the potential for serious risk of re-identification of individual complainants and possibly causing harm to consumers.
  3. Financial institutions will be restricted from offering complete responses, if any, to individual narratives presented publicly through the Consumer Complaint Portal for fear of violating federal privacy laws, thereby resulting in a one-sided unsubstantiated complaint process with the potential to misinform consumers and causing possible harm.
  4. The Consumer Response Portal presents a skewed and misleading representation of the current financial services market by publishing unverified complaints that are neither normalized or a complete representation of the entire financial services industry, offering no benefit to consumers.
  5. To the best of our knowledge, the Bureau has done no internal review of the use of the current Consumer Response Portal by consumers in making decisions on whether to patronize a particular financial institution or use their products or services and has no data to support the notion that the portal provides consumers with a useful tool for comparing financial products and services.

NOTE: The full comment letter is attached.

About CBA

The Consumer Bankers Association (CBA) is the trade association for today's leaders in retail banking - banking services geared toward consumers and small businesses. The nation's largest financial institutions, as well as many regional banks, are CBA corporate members, collectively holding two-thirds of the industry's total assets. CBA’s mission is to preserve and promote the retail banking industry as it strives to fulfill the financial needs of the American consumer and small business.

The Consumer Bankers Association is the recognized voice on retail banking issues in the nation’s capital. Founded in 1919, CBA provides leadership, education, research and federal representation on retail banking issues. For more information, please contact Tom Crosson,, (703) 869-1246 or visit