To the Editor:

Since we opened our doors over four years ago, listening to consumers has been a priority for the Consumer Financial Protection Bureau. Every day, we hear directly from people who are struggling to correct an error on a credit report, deal with an abusive debt collector, or fix a problem with a student loan. We take these complaints very seriously and companies should too.

We publish certain consumer complaint information in an online, public database to allow everyone to benefit from this resource. Responsible companies are using consumer complaints to identify pain points and improve their customer service.

The consumer complaint database has evolved and improved over time, and it was disappointing that a recent American Banker article, "Errors Abound in CFPB Complaint Portal," was itself riddled with inaccuracies about the database and how it works.

Just two months ago, the CFPB's Inspector General published a comprehensive audit report, never mentioned in this story, which found only a "relatively small" number of complaints with inaccuracies. Likewise, the story cites only three purported "errors" out of hundreds of thousands of complaints handled. And since American Banker refused to provide documentation or tracking numbers to the Bureau, it is unclear whether any of these were at all significant.

The article describes how one complaint referred by another agency supposedly became 35 separate complaints in our database. If a consumer in fact complained about multiple companies in a single complaint, or perhaps in a lengthy letter to their state banking regulator, we would indeed create multiple complaints, one for each company, and then give each company the opportunity to confirm or deny a customer relationship.

For example, a consumer who complains about threatening phone calls from a debt collector based on problems with multiple online loans would lead to a complaint being sent to all the companies mentioned. This commonsense approach makes it easier for the consumer to describe a complex problem involving multiple companies with a potential role to play in solving it. In other cases, however, we take steps to consolidate duplicate complaints.

The second "error" indicated a complaint was mistakenly sent to a bank named in the complaint instead of a payday lender also named in the complaint. The Bureau only publishes a complaint in its public database after the company has had time to consider the complaint and confirm a commercial relationship with the consumer. Companies can and do notify us about complaints submitted by noncustomers, and we do not publish them. Companies can also explain why a specific complaint does not involve them, and if the bureau determines the company has no role in solving the consumer's problem, we will not publish it.

The third "error" was a complaint allegedly submitted under the wrong individual's name – apparently the name of a state official who forwarded the complaint. That is not likely to affect the consumer involved, and it is unclear how this situation would affect the accuracy of the public database (which, of course, does not include consumer names).

Companies also play a key role in helping to ensure the accuracy of the information in the database. They can let the Bureau know if the complaining consumer is not their customer, if a complaint was submitted by an unauthorized party, or if one complaint duplicates another. These complaints will not be published in the database.

We continue to welcome constructive feedback and to enhance the database as a valuable resource for consumers and industry. If you have a problem with a consumer financial product or service, we encourage you to submit a complaint and let us hear about the situation in your own words at www.consumerfinance.gov. We are listening carefully to your voice, and we are working hard to see that you are being treated fairly.

Richard Cordray
Director
Consumer Financial Protection Bureau

The editors respond:

We are happy to publish Director Cordray's response, and to incorporate his perspective into our coverage of CFPB database errors. That said, Director Cordray does not dispute any of the examples given in the article. American Banker spoke with five current and former CFPB officials for the story. Those people, all of whom had knowledge of the database and its inner workings, agreed that it had serious problems, so much so that they were afraid to trust information from it.

As to the letter's specifics, with respect to the example of 35 separate complaints stemming from a single letter filed on behalf of a consumer, Director Cordray reiterates that it is the CFPB's practice to file a new complaint for every company mentioned in a complaint letter.

In the second example, the complaint, which was made explicitly against a payday lender, was filed by the CFPB against a bank. As of the morning of Nov. 30, there was still no complaint against that payday lender in the public portal.

In the third example, Cordray states that inaccurate information – in this case, a complaint filed under the wrong name – is unimportant because the database doesn't publish the consumer's name. A critical point of the story is that CFPB officials rely not just on the public portions of the database, but on other parts as well.

Cordray correctly notes that an inspector general's report said the database contained few mistakes, something American Banker should have noted in the original article. But that report did not address the issues that our CFPB sources were raising. (As noted in the story, American Banker did not publish the documentation we obtained because we did not want to inadvertently reveal our sources.)