WASHINGTON (5/27/15)--A platform that can affect a company's reputation--whether it carries consumers' compliments or complaints--must be carefully constructed so it successfully performs its function without unintended negative consequences, CUNA noted in a comment letter to the Consumer Financial Protection Bureau (CFPB).
“While credit unions have not been the subject of a sizable number of complaints and seem unlikely to become so, we nonetheless believe that the public data release, including feedback that is purportedly positive, could have unintended consequences,” the letter reads. “CUNA supports providing fundamental fairness to consumers, and also to financial institutions, whether they are credit unions or not.”
CUNA was commenting on the CFPB's plan to establish a system of consumer compliments for the successful resolution of complaints.
The CFPB conceives of two potential avenues for sharing positive consumer feedback about companies: Either by providing more information about a company’s complaint handling, or by collecting and providing consumer compliments completely independent of the complaint process.
The plan is an offshoot of the bureau's consumer complaints database, established under requirements of the Dodd-Frank Act, and perhaps a direct response to its plan to allow consumers' unvetted narratives to accompany complaints.
CUNA opposes a new database of consumer compliments that is being contemplated by the CFPB, an approach that would entail new submission types, channels and processes for the bureau. It could include use of the CFPB’s “Tell Your Story” feature, which allows consumers to share experiences regarding financial products and services.
“We are surprised the CFPB, as a data driven agency, is considering such an approach that would likely facilitate only anecdotal stories with no validation,” the CUNA letter reads. CUNA also warned that approach could unfairly promote institutions supervised by the CFPB. Other institutions, such as most credit unions, which are examined and supervised by their prudential regulators, would not have such responses posted for public view.
CUNA does believe that there could be some value in a metric approach that expresses positive feedback by providing more information about a company’s complaint handling. This would include metrics such as a total number of complaints, a company’s final responses and the timeliness and speed with which complaints are resolved.
Unlike the approach discussed above, this approach would not involve a new, separate intake for consumer compliments.
CUNA has expressed concerns with the consumer complaint database in a number of comment letters filed since 2011, the most recent being in September 2014. CUNA does not support the public release of certain complaint information that is separate from the CFPB’s periodic reports that provide more complete complaint information.
Under the current system, CUNA believes it is possible that some institutions are unable to respond to narrative complaint descriptions due to privacy restrictions.