Comments of Financial Regulation and Consumer Protection Scholars, and Former Regulators on CFPB's RFI Regarding Bureau Public Reporting Practices of Consumer Complaint Information (Docket No. CFPB-2018-0006)

Abstract

This is a response to the Consumer Financial Protection Bureau (CFPB)'s request for information regarding the CFPB's reporting practices of consumer complaint information.

Publicly releasing information about consumer complaints is essential to the CFPB's primary purpose of ensuring that “markets for financial products and services are fair, transparent, and competitive.” The response primarily focuses on the benefits of the CFPB's public consumer complaint database. Making public a database with data from consumers’ complaints not only advances the CFPB's primary purpose, but it also advances the CFPB's statutory duty to release marketplace data “as is in the public interest.” Consumers, advocates, companies, academics, and policymakers benefit from the database because it fosters transparency and data analysis. Consumers use the database to learn about the companies and industries they do business with, while advocates, academics, and policymakers analyze trends and identify problems in the marketplace. The database also provides important feedback to companies about concerns consumers encounter with their products and services.

The response also details the benefits of adding more data to the database, of continuing to publish reports based on complaint data, of publishing more tailored reports based on the complaint data, and of evaluating the design of the online interfaces through which consumers lodge complaints and access the database. These improvements will further enhance the operation of a fair, transparent, and efficient marketplace.

Keywords: Consumer Financial Protection Bureau, CFPB, consumer law, consumer protection, consumer complaints, consumer complaint database