Date: May 16, 2014

Issue: Consumer Data


Filing Type: CFPB

Description: The performance of the CRS Database to date has confirmed our concerns about the publication of unverified consumer complaint data and the unfair burdens that it places on companies. As the CFPB’s own data now shows, the vast majority of these “complaints” have been resolved with an explanation by the company, thus calling into question whether the CFPB’s system in fact is displacing—and disrupting—existing and effective customer service channels. We accordingly believe it appropriate to reevaluate the design of the Consumer Response System and the premises that justified the publication of unverified complaint data. The SORN issued by the CFPB makes clear that the Privacy Act poses no impediment to such a reevaluation. We urge the CFPB and its Inspector General to address these important issues.

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