Consumer Complaint Database and Public Narratives


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August 2014
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For some time we have known about the Bureau's "Consumer Complaint Database" ("Database").

The CFPB's new proposal would expand the "public-facing database" to include "unstructured consumer complaint narrative data" ("Narratives").

The Bureau promises that only those Narratives for which an opt-in consumer consent has been obtained and a "robust personal information scrubbing standard and methodology" applied would be subject to disclosure.

In this article, I provide an analysis of the CFPB's position on Narratives and its declared intent to implement them.

I hope you enjoy the article!

President and Managing Director   

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The Bureau believes that there are three areas of interest that need to be considered in order to implement its plan to include the Narratives: (1) the direct and indirect benefits to consumers, (2) the benefit to the Bureau, and (3) the advancement of open government principles. Permit me to provide a synopsis of each of these vectors.

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Before I jump into the deep pool of consumer complaint machinations of the Consumer Financial Protection Bureau ("Bureau"), I would like to offer a definition of a word. That word is "allegation." Here's my definition of an "allegation", liberated from its legalistic moorings: 'An accusation that someone has done something illegal or wrong, which may be true or may be false, typically made without proof, or sufficient proof, and eventually may or may not lead to somebody being found innocent or guilty of doing something illegal or wrong.'  


Please keep my definition in mind as we explore together the Bureau's new Proposed Policy Statement regarding consumer complaints, issued on July 16, 2014.

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