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MCUA Cites Concerns with CFPB's Plans for its Complaint Database

On May 26, 2015, the Missouri Credit Union Association (MCUA) filed a comment letter citing several concerns related to the Consumer Financial Protection Bureau's (CFPB) Request for Information (RFI) on the "potential collection and sharing of consumer compliments about providers of consumer financial products and services."

The CFPB currently collects and shares some positive feedback regarding company complaint handling. Broadly speaking, the CFPB conceives of two potential avenues for sharing positive consumer feedback about companies: (1) by providing more information about a company's complaint handling, and (2) by collecting and providing consumer compliments (independent of the complaint process).

Regarding option (1) above, MCUA believes there could be some value in an approach that expresses positive feedback by providing more information about a company's complaint handling. Since the database is primarily intended as a repository of consumer complaints, it is unlikely that consumers accessing the database will focus—or even review—information regarding complaint resolution. However, the CFPB could explore ways in which to modify the user interface of the database to make it more likely that consumers will access and give weight to positive feedback (i.e., complaint resolution).

Regarding option (2) above, MCUA does not support this potential approach, which would involve a new (additional) intake that would involve soliciting, collecting, and sharing consumer compliments. MCUA is surprised the CFPB, as a data driven agency, is considering such an approach that would likely facilitate only anecdotal stories with no validation.