Appleseed submits comments to CFPB regarding Bureau public reporting practices of consumer complaint information

Below is the text of Appleseed’s formal comments to the CFPB supporting the public complaint process. For further information, please contact Annette LoVoi, Appleseed’s Director of Financial Access and Asset Building.

​Consumer Financial Protection Bureau
1700 G St., N.W.
Washington, DC 20552
Bureau of Consumer Financial Protection
Via email: FederalRegisterComments@cfpb.gov

Docket # – CFPB -2018-0006

Re: CFPB RFI # 6 – Request for Information Regarding Bureau Public Reporting Practices of Consumer Complaint Information

June 4, 2018

Dear Acting Director Mulvaney:

Appleseed writes to express our support of the CFPB’s public complaint process and to respond to the Consumer Financial Protection Bureau’s (CFPB) Request for Information (RFI) on the public reporting of consumer complaint information.

The Bureau has rightly developed a robust, trustworthy complaint process that includes access to a public complaint database to meet its consumer protection mandate. This process has been successful.

The public complaint database is a tool that empowers individuals to inform and protect themselves in the marketplace. Appleseed has successfully used this tool to gather and validate information received from other sources. It also helps consumers evaluate a company’s practices as they decide where to take their business and creates incentives for companies to treat their customers fairly. It helps both consumers and businesses resolve problems when they arise and helps the market reward good products and services by providing consumers with the ability to publicly share their experiences. The complaint database also allows companies to identify and correct problems on their own without the impetus of a new rule or enforcement action.
It is in both the public’s and government’s best interest – and a key part of the CFPB’s mission– to use data to provide the public with “timely and understandable information to make responsible decisions about financial transactions.”

Providing consumers access to a public complaint database also fulfills the Bureau’s obligations to protect consumers from unfair, deceptive, or abusive acts and practices and from discrimination” and identify risks to consumers in the “collecting, researching, monitoring, and publishing (of) information relevant to the functioning of markets for consumer financial products and services.”

Usefulness of complaint reporting and analysis

Among other initiatives, Appleseed works to provide greater financial access opportunities for immigrants. A recent review of the complaint database shows that problems persist for individuals using remittances, or money transfers, to send money home.

The most common complaint reported is delay in remittance delivery. This money is often the life-blood for a family, representing the ability to buy food and secure medical care. Other complainants report delays in sending remittances, refusal of service by a company, or refusal to refund. Persistent throughout Appleseed’s decade of work on this subject is report from complainants that they are receiving less money in foreign currency than originally disclosed pre-transaction. Complaints arising from crypto-currencies are also common.

A review of this singular financial service establishes the importance of a robust complaint system with public-facing data.

Appleseed believes that such information should be retained in a public format to enable the public, companies and the CFPB to analyze complaints geographically, by service, and among immigrants from particular countries. Appleseed specifically notes the success of the database with over 1.1 million complaints received and amount of money returned to consumers.

It is essential that the CFPB not retreat from its core mission to protect and inform consumers and to make our financial markets more fair, accountable, transparent and competitive.

The CFPB consumer complaint database allows consumers to make better financial choices, encourages firms to improve their customer service and take notice of competitors’ practices that they should avoid. We urge the Bureau to maintain public access to the consumer complaint database.

Thank you for taking the time to thoughtfully review our comments.

Sincerely,

Annette LoVoi
Appleseed
Director of Financial Access and Asset Building