CBA Submits Comments on Bureau’s Complaint & Inquiry Process

July 16, 2018
Nick Simpson

CBA Submits Comments on Bureau’s Complaint & Inquiry Process


Washington, D.C. – The Consumer Bankers Association submitted comments to the Bureau of Consumer Financial Protection’s request for information on the consumer complaint and inquiry handling process. In its letter, CBA discussed ways to make the process more efficient for the Bureau, consumers and financial institutions without exposing consumers to privacy concerns or misrepresenting the Bureau’s role in the complaint process.


“CBA’s members are dedicated to complaint resolution and customer satisfaction and believe the goal of the Bureau’s complaint data collection ought to be to improve industry performance and service quality, and to provide consumers with an avenue to deal with complaints when the company is unresponsive or is not providing a satisfactory resolution,” CBA Associate General Counsel and Vice President David Pommerehn wrote. “It should not be used as a way to create disharmony between consumers and the financial services industry … CBA believes the Bureau’s efforts should be to ensure every company has a strong complaint resolution process, assist in the resolution of complaints and red flag potential problems for further evaluation. However, the public release of complaint data on the Bureau’s Complaint Database increases privacy risks to the consumer and offers no value.”


To achieve these shared goals, CBA made the following recommendations:


  • Complaint / Inquiry Classification: The Bureau should have consumers classify their submissions as either complaints or inquiries. Currently, without this validation, simple inquiries are often classified as complaints during Bureau reporting.
  • Set a Clear Standard for Complaints: The Bureau should adopt a system similar to the Federal Trade Commission to differentiate between a true complaint against a financial institution as opposed to a statement of dissatisfaction not rooted in wrong-doing or a mistake (i.e.: dissatisfaction over a bank’s hours on Saturday should not be deemed a complaint for Bureau accounting).
  • Complaint Reclassification:  Financial institutions should be able to work with the Bureau to reclassify submissions as either inquiries or complaints if they are mislabeled when submitted to the Bureau.
  • Consumer Inquiry Process:  The Bureau should direct consumer inquiries to the financial institution and encourage the consumer to contact his or her financial institution for prompt resolution. CBA also stated a web chat function on the Bureau’s website could assist consumers and filter inquiries from complaints. 


CBA also underscored the importance of having consumers contact their financial institution and requested the Bureau clarify it does not serve as an advocate for consumers during the complaint process. 


A full copy of CBA’s letter, along with other topics addressed as part of the RFI, is available here.




About the Consumer Bankers Association

The Consumer Bankers Association represents America’s retail banks above $10 billion in assets. We advance legislation and promote policies geared toward creating a stronger industry and economy. Established in 1919, CBA’s corporate member institutions account for 1.6 million jobs in America, extend roughly $3 trillion in consumer loans, and provide $270 billion in small business loans. Follow us on Twitter @consumerbankers.