The Consumer Financial Protection Bureau (CFPB), created by the Dodd-Frank Act to act in conjunction with the Federal Trade Commission to oversee and regulate certain sectors of the financial marketplace, recently announced the launch of a consumer complaint database available to the public containing basic information about individual complaints against credit card issuers.
The Consumer Complaint Database allows the public to know what is being complained about and why. It contains certain individual-level field data collected by the CFPB, including the type of complaint, the date of submission, the consumer’s zip code, and the company that the complaint concerns. The database also includes information about the actions taken on a complaint – whether the company’s response was timely, how the company responded, and whether the consumer disputed the company’s response.
The database will be populated by credit card complaints received by the CFPB on and after June 1, 2012. Complaints are only uploaded after the company verifies that it has been correctly identified by the complainant. That may be done within days or a company may take the full 15 days that the CFPB allows. As it is a live database that updates daily, the public will see more information in the database as more complaints are received.
The database is a ‘beta’ version and is limited to complaints submitted to the CFPB since June 1, 2012. The CFPB plans to update the database with all complaints received since it began accepting complaints in July 2011. Unfortunately, it appears the complaints will be posted as received, without being screened for duplication or misdirection.
We recently discussed Dodd-Frank’s Section 1071, whose stated purpose is “to facilitate enforcement of fair lending laws and enable communities, governmental entities, and creditors to identify business and community development needs and opportunities of women-owned, minority-owned, and small businesses.” Like Section 1071, the consumer credit card complaint database, with its unscreened, often duplicative or misdirected complaints, may have the undesired effect of restricting the marketplace to a point where fewer lenders will find it profitable to operate — which, again, is certainly not good news for those the law is intended to protect.
If you have questions about whether your business is or will be affected by the CFPB, the Dodd-Frank Act, or any other area of law, contact us today. The attorneys at Glass & Goldberg provide high quality and cost-effective legal services and advice for clients in all aspects of business litigation and transactional law. Call us at (818) 888-2220, email