CFPB Asks For Input Regarding New Consumer Complaint Feedback Process

Yesterday the Consumer Financial Protection Bureau published a new Request for Comment in the Federal Register, regarding a proposed Consumer Response Customer Response Survey. 

According to the posting,

The purpose of this information collection is to incorporate a short survey into the complaint closing process. Consumers will have the option to provide feedback on the company’s response to and handling of their complaint via all channels including online, phone, fax, and mail. The results of this feedback will be shared with the company that responded to the complaint to inform its complaint handling. The feedback will also be used to inform the Bureau’s work to supervise companies, enforce federal consumer financial laws, write better rules and regulations, and monitor the market for consumer financial products and services.

Consistent with the Bureau’s policy statement on Disclosure of Consumer Complaint Data, the Bureau will evaluate the data collected from consumer feedback before publication on the Consumer Complaint Database. The Bureau anticipates publication of consumer feedback to highlight positive company behavior, provide the public with timely and understandable information about consumer financial products and services, and improve the functioning, transparency, and efficiency of markets for such products and services. Only those feedback narratives for which opt-in consumer consent is obtained, and to which robust personal information scrubbing standard and methodology is applied, will be eligible for publication.

This information collection reflects comments received in response to the March 24, 2015 (80 FR 15583) Notice and Request for Information (RFI), seeking input from the public on the potential collection and sharing of information about consumers’ positive interactions with financial service providers including providing more information about a company’s complaint handling such as highlighting the quality of responses to consumers by replacing the consumer ‘‘dispute’’ function with a two-part consumer feedback process as well as comments received during the 60-day comment period and user testing conducting concurrent with the 60-day comment period. The consumer will have the ability to answer three questions about the company’s response to and handling of his or her complaint, to rate the company’s overall response using one to-five stars and provide a narrative description in support of the rating.

Positive feedback about the company’s handling of the consumer’s complaint would be reflected by both high satisfaction scores and by the narrative in support of the score. Negative feedback about the company’s handling of the consumer’s complaint would be better supported and more useful to companies than the current ‘‘dispute’’ function. The Consumer Complaint Company Response Survey will replace the ‘‘dispute’’ option and allow consumers to offer both positive and negative feedback on their complaint experience.

insideARM wrote about this initial proposal back in August when the sample survey was released and the Bureau issued a 60-day Federal Register notice (on August 1, 2016, with comments due by September 30, 2016). The CFPB said then that this survey built on a public inquiry issued last year seeking public input on ways to highlight consumers’ positive experiences with financial service providers. Positive feedback about the company’s handling of the consumer’s complaint would be reflected by both high satisfaction scores and by the narrative in support of the score. Negative feedback about the company’s handling of the consumer’s complaint would offer new context and be more useful to companies.

The Bureau says that comments were solicited and continue to be invited on:

• Whether the collection of information is necessary for the proper performance of the functions of the Bureau, including whether the information will have practical utility;
• The accuracy of the Bureau’s estimate of the burden of the collection of information, including the validity of the methods and the assumptions used;
• Ways to enhance the quality, utility, and clarity of the information to be collected; and
• Ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques or other forms of information technology. 

Written comments on this latest request must be received on or before December 29, 2016 to be assured of consideration.