CBA Submits Letter on Bureau’s Complaint Reporting Processes

June 4, 2018

WASHINGTON, D.C. – The Consumer Bankers Association today submitted comments on the Bureau of Consumer Financial Protection’s consumer complaint reporting processes. The comments are part of the Bureau’s ongoing requests for information.


“CBA members strive to ensure their customers receive a swift and complete review of their complaints and inquiries.  In fact, the overwhelming majority of complaints filed with the Bureau are successfully resolved by consumers’ financial institutions,” said CBA Vice President and Associate General Counsel David Pommerehn.


“To improve the complaint reporting process, we believe the Bureau should assist in complaint resolution and red flag potential problems for further evaluation.  The public release of unverified, non-normalized complaint data increases privacy risks and offers no actionable value for consumers.”

The letter discusses three main issues of concern regarding the complaint reporting process:

  • The Database Creates Consumer Harm and Privacy Concerns: The Database does not protect consumers from re-identification risks and creates consumer harm. 


  • The Database Does Not Enhance Consumers’ Ability to Compare: The publication of raw complaint narratives subjects companies to inaccurate and unfair criticism that is often subjective and potentially misleading without institutional proprietary context or facts.  As such, this information may actually misinform consumers; doing the exact opposite of what the Bureau is mandated to accomplish.


  • The Dodd-Frank Act Does Not Require or Contemplate the Database be Public: The authors of Dodd-Frank did not intend for Bureau to publicly share complaints.  In fact, plain reading of the statute indicates that they did not specifically authorize it as they have in other contexts.


You may read the full letter here.