CFPB To Publish Narrative Consumer Complaints

Despite loud industry objections and apparent impracticalities, the Consumer Financial Protection Bureau (CFPB) has moved ahead with its plan to allow consumers submitting to its Consumer Complaint Database to go public with narrative descriptions of their complaints. On March 19, the Bureau announced the change and encouraged consumers to "lift their voices" into a potentially cacophonous chorus that could pose significant reputational challenges for consumer financial services companies.

The new policy followed consideration of 137 unique public comments, according to the Bureau's Final Policy Statement on Disclosure of Consumer Complaint Narrative Data. Industry trade associations and companies widely opposed the change. Commenters pointed out, among other things, that the narratives would be unverified even though they posed great potential reputational risk, and that there was no practical way for companies to respond to narrative complaints with a narrative