jim mccarthy

The Consumer Financial Protection Bureau (CFPB) is asking the Office of Management and Budget (OMB) to approve the collection of yet another subjective data point from consumers who complain about your company. 

What is the CFPB asking the OMB to approve? 
The CFPB is asking to gather and publish more data point(s) collected from the consumer and retained in the Consumer Complaint Database (CCDB). 

In short -  upon the receipt of your response in the consumer’s portal, the consumer is asked to rate their experience with your company's complaint process.  This is done by collecting a data point called a rating - a number from one to five, -and a narrative supposedly capturing the elements factoring into the rating.

Who cares, right? 
You should care and you should care a lot.  Here's why.

You've spent time and money building your company's reputation and brand, and now your company is developing a CCDB fingerprint and that fingerprint isn’t going to be private.  That fingerprint tells the world who you are and how you conduct business; period. 

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As you sell your services through the marketplace, consumers or regulators of that service (i.e. your clients, customers, vendors, State AG’s and the CFPB) will have an actual collective report card on how you conduct your business as stated by the consumers who respond to the CCDB request to rate their experience

Assuming someone (maybe a prospective client, maybe a state regulator) someday uses the data in the CCDB to do something big, like a rating system, (hint: it's coming), your company will be left to defend the data belonging to you in the public database. 

Wait, what?

Your staff that is responsible for handling CCDB complaints now holds the keys to the single most important professional and public reputational risk your company faces. 

The next time you are unsuccessful responding to an RFP or the next time a state examiner is so persistent on a certain subject think about your CCDB fingerprint. 

Things to Consider?

  • Who determines the tone in your responses?
    • Tone is used as a human defense mechanism. Your complaint staff gets sick of people complaining when unwarranted.  Tone helps them cope.  Poor tone can kill your reputation.  Right or wrong, find a nice way to say it. And now, its quantitative, so be consistent. 
  • Does your desire to be a lawyer or speak to a regulator through a consumer’s response diminish the effectiveness of your response to the consumer? The bureau wants you to talk to the consumer in plain language.
  • How long do complaint trends go before your complaint staff tells you?
    • Often you focus at the complaint/response level and not enough on the emerging trends.
  • Do you have policies dictating exactly how data is selected and entered by the complaint staff?
    • How do you define and use response categories?
    • Have your marketing and compliance departments worked together to provide templates and/or guidance on positive responses to complaints?
    • Does your response team provide a positive response even when one is not warranted?
  • Does your sales staff understand how to explain your CCDB fingerprint? Are you sure? Really?
    • Do they know how to use your complaint fingerprint to sell your company?
  • Does management take direct responsibility to raise the level of importance of a holistic approach to your complaint strategy and your CCDB fingerprint?

Will you be ready?

  • IMPORTANT: will you be ready when this and many changes to the CFPB complaint process happen in 2017.

Regardless if the customer is right on the facts, they should be able to get an answer.  How you communicate that answer now has value. 

Jim McCarthy is a (former) founding member of the CFPB and expert on the CFPB complaint process.


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