Summary: BCFP Request for Information Regarding the Bureau’s Consumer Complaint and Consumer Inquiry Handling Processes

Bureau of Consumer Financial Protection
Prepared by the NASCUS Legislative & Regulatory Division
May 2018

The BCFP is seeking comments and information from interested parties to assist the Bureau in assessing its handling of consumer complaints and consumer inquiries and, consistent with law, considering whether changes to its processes would be appropriate.

Comments are due on July 16, 2018.  The RFI can be found here.

The Bureau routes complaints about consumer financial products/services directly to financial companies and works with them to get consumers a timely response from the company, usually within 15 days.  In addition, the Bureau provides consumers with a toll-free number for inquiries regarding financial products/services. 

The Bureau is using this RFI to seek public input regarding potential changes that can be implemented to the Bureau’s consumer complaint and inquiry handling processes, consistent with law, to consider whether any changes to existing practices would be appropriate given the Bureau’s statutory objective to provide consumers with timely and understandable information about consumer financial products/services to make responsible decisions, as well as its statutory obligations to (i) establish reasonable procedures to provide timely responses to consumers and (ii) centralize the collection of consumer complaints regarding consumer financial products/services. 

The Bureau requests that where possible, comments include:

  • Specific discussion of the positive and negative aspects of the Bureau’s complaint/inquiry processes;
  • Specific suggestions regarding any potential updates or modifications to the Bureau’s complaint/inquiry processes including in as much detail as possible, the nature of the modification and supporting data or other information on impacts/costs;
  • Specific best practices from complaint/inquiry processes given the Bureau’s statutory objectives/functions, including ensuring consumers are provided with timely and understandable information to make responsible decisions about financial transactions and centralizing the collection of consumer complaints about consumer financial products/services.

In addition, the Bureau is seeking feedback on all aspects of its consumer complaint and inquiry handling processes such as:

Specific statutorily-permissible suggestions regarding how the Bureau currently allows consumers to submit complaints/inquiries including:

  • Should the Bureau require consumers to classify their submission affirmatively as a consumer complaint or inquiry prior to submission?
  • How should the Bureau explain the difference between a consumer complaint and a consumer inquiry to consumers at the point of submission?
  • Should the Bureau develop a process for companies to reclassify consumers’ submissions? If so, what criterial should the Bureau establish to help companies differentiate consumer complaints from consumer inquiries?

Specific-statutorily-permissible suggestions regarding the Bureau’s consumer complaint processes including:

  • The Bureau currently receives complaints via six channels: website/referral from Federal and State entities/agencies, telephone, mail, fax and email.  Should the Bureau add or discontinue ay channels for accepting complaints?
  • Consistent with the Dodd-Frank Act’s definition of “consumer,” the Bureau currently allows consumers to authorize someone else (such as lawyer, advocate, power of attorney) to submit complaints on their behalf.  Should the Bureau expand, limit, or maintain the ability of authorized third parties to submit complaints?

Specific-statutorily-permissible suggestions regarding the Bureau’s consumer inquiry processes including:

  • The Bureau currently accepts consumer inquiries via telephone and mail.  Should the Bureau add or discontinue any channels for accepting inquiries?
  • Should the Bureau develop web chat systems to support consumers’ submission of inquiries?
  • Should the Bureau develop a process for companies to provide timely responses to consumer inquiries sent to them by the Bureau? If so, how should the Bureau balance its objective of providing timely and understandable information to consumers with its objective of reducing unwarranted regulatory burden on companies?
  • Should the Bureau publish data about consumer inquiries? If so, what types of data or analyses about consumer inquiries should be shared with public?