Last week the Consumer Financial Protection Bureau issued a Request for Information (RFI) regarding a topic that is important to just about everyone in the ARM industry -- the Consumer Complaint Portal.

Download the complete RFI here.

Praised by some; reviled by others, the Complaint Portal has been a source of much publicity. The Bureau is now seeking the following input, but notes the list is non-exhaustive and commenters are free to provide other relevant feedback:

  1. Specific, statutorily-permissible suggestions regarding the frequency of the Bureau’s reporting on consumer complaints;
  2. Specific, statutorily-permissible suggestions on the content of the Bureau’s reporting on consumer complaints, including:
    • Whether the Bureau should include more, less, or the same amount of reporting on State and local complaint trends;
    • Whether it is net beneficial or net harmful to the transparent and efficient operation of markets for consumer financial products and services for the Bureau to publish the names of the most-complained-about companies;
    • Whether the Bureau should provide more, less, or the same data fields in the Consumer Complaint Database;
    • Whether the Bureau should provide more, less, or the same amount of context for complaint information, particularly with regard to product or service market size and company share;
    • Whether the Bureau should supplement observations from consumer complaints with observations of company responses to complaints;
    • Whether the Bureau should share more, less, or the same amount of information on month-to-month trends; and
    • Whether the Bureau should share more, less, or the same amount of information on particular products and services;
  3. Specific suggestions on the reporting methodology, including:
    • Should the Bureau continue to analyze data for seasonal fluctuations? If so, how?; and
    • Should the Bureau provide more, less, or the same amount of context for complaint information, particularly with regard to product and service market size and company share, including what data set(s) or data source(s) the Bureau should use;
  4. Specific, statutorily-permissible suggestions for the publication process of consumer complaint information, including:
    • Whether the Bureau should provide the public with a publication schedule;
    • Whether the Bureau should notify the most-complained-about companies of their inclusion in a Bureau report prior to publication and invite company comment;
    • Whether the Bureau should devote resources to building tools to enable users to analyze complaint information; and
    • Whether the Bureau should expand, limit, or maintain the same level of access to complaint information available to external stakeholders such as financial institutions and the public.

The announcement states that the Bureau is not seeking comment at this time regarding consumer inquiries and related process activities but will issue a subsequent RFI.

Publication of the RFI on Consumer Complaints in the Federal Register is expected tomorrow, March 7. The deadline for comments is June 4, 2018.

On January 17, 2018 CFPB Acting Director Mick Mulvaney announced that he was issuing a "call for evidence" to ensure the Bureau is fulfilling its proper and appropriate functions to best protect consumers. Since then a series of requests has been released about activities including:

Also expected soon are calls for evidence on these topics:

  • Rulemaking Processes
  • Bureau Rules Not Under §1022(d) Assessment
  • Inherited Rules
  • Guidance and Implementation Support
  • Consumer Education
  • Consumer Inquiries

 

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insideARM Perspective

Many have written about their frustrations with the CFPB's Complaint Portal, including the lack of context provided with reports of debt collection complaints. Industry is undoubtedly pleased for the opportunity to provide input.

However for debt collection leaders these requests come at a time when they are already doing double-duty, working to provide specific input to the new CFPB leadership regarding possible debt collection rules. Acting Director Mulvaney has made it clear that he is re-prioritizing the work of the Bureau, and has mentioned on multiple occasions that because of the volume of debt collection complaints, he sees the market as a top priority.

This is an important time for the ARM industry, from creditors to collection agencies, debt buyers, attorneys and service/technology providers. There has probably not been such an opportunity in decades for your voice to be heard and to make an impact. insideARM suggests one thing overall -- get involved.


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