Many cities and municipalities have non-emergency
"hotlines" designed to provide access to non-urgent
municipal services (e.g., tree trimming, dead animal
removal, sidewalk repair). As of yesterday, this list of services
has expanded to consumer questions and complaints about consumer
financial products and services, at least in Newark, New Jersey.
The Bureau
announced that it is teaming up with the municipality to
connect consumers with the Bureau's Office of Consumer
Response. Newark consumers can now simply dial the local 4311
hotline and, voila!, they will be connected with the Bureau.
Does this development raise UDAAP concerns? You bet! Consumer
complaints are a key source of information and a potential jumping
off point for Bureau investigations. Indeed, in connection with the
Bureau's announcement of this new program, Director Cordray
invoked UDAAP sentiments when he said that "[t]he CFPB's
job is to help consumers navigate the often confusing
