15572 Federal Register / Vol. 80, No. 56 / Tuesday, March 24, 2015 / Notices 

1http://www.nist.gov/pml/div684/upload/ 

FederalVisionQIS.pdf. 

1 Disclosure of Certain Credit Card Complaint 

Data, 77 FR 37558 (June 22, 2012) (‘‘2012 Notice of 

Final Policy Statement’’); Disclosure of Consumer 

Complaint Data, 78 FR 21218 (Apr. 10, 2013) (‘‘2013 

Notice of Final Policy Statement’’). 

Science and the Needs of U.S. Industry 

is to solicit input from stakeholders 

about the broader needs of the industrial 

community in the area of quantum 

information science (QIS). Topics to be 

discussed include opportunities for 

research and development, emerging 

market areas, barriers to near-term and 

future applications, and workforce 

needs. Information gathered at this 

workshop will be used in the 

development and coordination of U. S. 

Government policies, programs, and 

budgets to advance U.S. 

competitiveness in QIS. 

This workshop will focus on the 

needs of industry in the following areas: 

(1) Opportunities 

Quantum information science 

includes, for example, quantum 

computing and processing, quantum 

algorithms and programming languages, 

quantum communications, quantum 

sensors, quantum devices, single photon 

sources, and detectors. What areas of 

pre-competitive QIS research and 

development appear most promising? 

What areas should be the highest 

priorities for Federal investment? What 

are the emerging frontiers? What 

methods of monitoring new 

developments are most effective? 

(2) Market Areas and Applications 

The 2008 ‘‘A Federal Vision for 

Quantum Information Science’’ 1

identified exciting new possibilities for 

QIS impact, including mineral 

exploration, medical imaging, and 

quantum computing. Now, six years 

later, what market areas are wellpositioned to benefit from new 

developments in QIS? 

(3) Barriers 

Funding levels and mechanisms, 

technology, dissemination of 

information, and technology transfer are 

some of the potential barriers to 

adoption of QIS technology. What are 

the greatest barriers to advancing 

important near-term and future 

applications of QIS and what should be 

done to address these barriers? 

(4) Workforce Needs 

Addressing opportunities in QIS and 

barriers to applications requires a 

workforce spanning many disciplines, 

ranging from computer science and 

information theory to atomic scale 

manipulation of materials, and 

possessing a range of knowledge and 

skills. What knowledge and skills are 

most important for a workforce capable 

of addressing the opportunities and 

barriers? In what areas is the current 

workforce strong, and in what areas is 

it weak? What are the best mechanisms 

for equipping workers with the needed 

knowledge and skills? 

The workshop will include invited 

presentations by leading experts from 

academia, industry, and government 

and time for group discussion. 

There is no cost for participating in 

the workshop. No proprietary 

information will be accepted, presented 

or discussed as part of the workshop, 

and all information accepted, presented 

or discussed at the workshop will be in 

the public domain. 

Workshop Registration: All workshop 

participants must pre-register at the 

following web address to be admitted: 

http://www.nist.gov/pml/div684/ 

quantum-information-scienceinnovation-and-the-path-forward.cfm. 

Anyone wishing to attend this meeting 

must register by 5 p.m. Eastern Time on 

April 3, 2015, in order to attend. Also, 

please note that under the REAL ID Act 

of 2005 (Pub. L. 109–13), federal 

agencies, including NIST, can only 

accept a state-issued driver’s license or 

identification card for access to federal 

facilities if issued by states that are 

REAL ID compliant or have an 

extension. NIST also currently accepts 

other forms of federal-issued 

identification in lieu of a state-issued 

driver’s license. For detailed 

information please contact Gail 

Newrock at (301) 975–3200 or visit: 

http://www.nist.gov/public_affairs/ 

visitor/. 

Richard R. Cavanagh, 

Acting Associate Director for Laboratory 

Programs. 

[FR Doc. 2015–06848 Filed 3–20–15; 4:15 pm] 

BILLING CODE 3510–13–P 

BUREAU OF CONSUMER FINANCIAL 

PROTECTION 

[Docket No. CFPB–2014–0016] 

Disclosure of Consumer Complaint 

Narrative Data 

AGENCY: Bureau of Consumer Financial 

Protection. 

ACTION: Final Policy Statement. 

SUMMARY: The Bureau of Consumer 

Financial Protection (the ‘‘Bureau’’) is 

issuing a final policy statement (‘‘Final 

Policy Statement’’) to provide guidance 

on how the Bureau plans to exercise its 

discretion to disclose publicly 

unstructured consumer complaint 

narrative data (‘‘narratives’’ or 

‘‘consumer narratives’’) via its webbased, public facing database (the 

‘‘Consumer Complaint Database’’ or 

‘‘Database’’). Only those narratives for 

which opt-in consumer consent is 

obtained and a robust personal 

information scrubbing standard and 

methodology applied will be eligible for 

disclosure. The Final Policy Statement 

supplements and amends the Bureau’s 

existing policy statements establishing 

and expanding the Consumer Complaint 

Database.1

DATES: Applicability date: The Bureau 

will not publish any consented-to 

narrative for at least 90 days after 

publication in the Federal Register. 

FOR FURTHER INFORMATION CONTACT: 

Scott Pluta, Assistant Director, Office of 

Consumer Response, Bureau of 

Consumer Financial Protection, at (202) 

435–7306. 

SUPPLEMENTARY INFORMATION: 

Authority: 12 U.S.C. 5492(a), 5493(b)(3), 

(d), 5496(c)(4), 5511(b), (c), 5512, 5534(a), (b). 

I. Overview 

A. Final Policy Statement 

Under the Final Policy Statement, the 

Bureau extends its existing practice of 

disclosing data associated with 

consumer complaints via the Consumer 

Complaint Database to include 

narratives for which opt-in consumer 

consent is obtained and a robust 

personal information scrubbing 

standard and methodology has been 

applied. The purposes of the Consumer 

Complaint Database include providing 

consumers with timely and 

understandable information about 

consumer financial products and 

services, and improving the functioning, 

transparency, and efficiency of markets 

for such products and services. The 

Bureau believes that adding additional 

information to the Consumer Complaint 

Database, here narratives and structured 

company responses, is consistent with 

and promotes these purposes. 

II. Background 

A. Complaint System 

In the Bureau’s previous notices of its 

policy statements, establishing and 

expanding the Consumer Complaint 

Database, the Bureau generally 

described how the Office of Consumer 

Response (‘‘Consumer Response’’) 

handles consumer complaints 

(collectively the ‘‘Complaint 

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Federal Register / Vol. 80, No. 56 / Tuesday, March 24, 2015 / Notices 15573 

2 2012 Notice of Final Policy Statement, 77 FR at 

37559 (June 22, 2012); 2013 Notice of Final Policy 

Statement, 78 FR at 21219 (April 10, 2013). 

3The Complaint System is described in more 

detail in the 2013 Consumer Response Annual 

Report (March 31, 2014) at: http:// 

www.consumerfinance.gov/reports/2013-consumerresponse-annual-report./ 

4 Disclosure of Consumer Complaint Narrative 

Data, 79 FR 42765, 42767 (July 23, 2014). 

5This group included: Americans for Financial 

Reform; Alliance for a Just Society; Arkansas 

Community Organization; California Reinvestment 

Coalition; Connecticut Citizen Action Group; Center 

for Digital Democracy; Center for Responsible 

Lending; Community Legal Services, Philadelphia; 

Connecticut Fair Housing Center; Consumer Action; 

Consumer Federation of America; Consumers for 

Auto Reliability and Safety; Consumer Watchdog; 

Demos; Electronic Privacy Information Center; 

Empire Justice Center; Florida Alliance for 

Consumer Protection; Home Defenders League; 

International Union, United Automobile, Aerospace 

& Agricultural Implement Workers of America 

(UAW); Keystone Progress; Leadership Conference 

on Civil and Human Rights; Massachusetts 

Consumers’ Coalition; MASSPIRG; Miami Valley 

Fair Housing Center, Dayton, Ohio; Missourians 

Organizing for Reform and Empowerment; NAACP; 

National Association of Consumer Advocates; 

National Consumer Law Center (on behalf of its low 

income clients); National Council of La Raza; 

National Fair Housing Alliance; National People’s 

Action; New Economy Project; New Jersey Citizen 

Action; New Jersey Communities; United Oregon 

Consumer League; Privacy Rights Clearinghouse; 

Privacy Times; Project on Government Oversight; 

Public Citizen; Public Justice Center; South 

Carolina Appleseed Legal Justice Center; Southwest 

Center for Economic Integrity; Texas Legal Services 

Center; The Institute for College Access and 

Success; U.S.PIRG; Virginia Citizens Consumer 

Council; Woodstock Institute; and the World 

Privacy Forum. 

System’’).2This Final Policy Statement 

does not affect how a consumer’s 

complaint is substantively handled by 

the Bureau. Consumer Response screens 

all complaints submitted by consumers 

based on several criteria, including 

whether the complaint should be routed 

to another regulator and whether the 

complaint is complete. Screened 

complaints are forwarded via a secure 

web portal to the appropriate company. 

The company then has 15 calendar days 

to provide an initial response and up to 

60 calendar days to provide a final 

response. Companies have the ability 

within these timeframes to respond 

administratively to the Bureau, e.g., 

responding that no commercial 

relationship exists between the 

complaining consumer and the 

company in question. Typically, the 

company reviews the complaint, 

communicates with the consumer as 

needed, and determines what action to 

take in response. After the company 

responds to the consumer and the 

Bureau via the secure company portal, 

the Bureau invites the consumer to 

review the response and provide 

feedback. Some complaints are 

individually reviewed by Consumer 

Response investigations staff. All 

complaints are subject to follow-up and 

further investigation by Consumer 

Response and other parts of the 

Bureau.3

The Bureau makes publicly available 

some data it collects as part of its 

complaint handling function, while 

continually striving to protect the 

sensitive information contained within 

that data. One way the Bureau currently 

accomplishes this is by sharing some 

fields from de-identified individuallevel complaint data with the public 

through the Consumer Complaint 

Database. The Database was launched 

on June 19, 2012. It was initially 

populated with credit card complaint 

data but has since been expanded to 

include complaint data about other 

products, e.g., mortgages, bank accounts 

and services, student loans, vehicle and 

other consumer loans, credit reporting, 

money transfers, debt collection, payday 

loans, and prepaid cards. Data from 

complaints are disclosed in the Database 

the earlier of: (1) An initial response to 

the consumer and the Bureau 

(confirming a commercial relationship 

with the consumer) or (2) 15 calendar 

days after the complaint was sent to the 

company. Data from a complaint is not 

published in the Database if, among 

other reasons, the company suspects the 

complaint was submitted in furtherance 

of a fraud or it indicates to the Bureau 

that it does not have a commercial 

relationship with the consumer. 

B. Overview of Public Comments 

In its Proposed Policy Statement 

Regarding Disclosure of Unstructured 

Narrative Data From Consumer 

Complaints and Company Responses 

(‘‘Proposed Policy Statement’’), the 

Bureau proposed expanding its 

Consumer Complaint Database to 

include narratives submitted by 

consumers as well as public-facing 

narrative responses from companies.4

The Bureau received 137 unique 

comments from, among others, 

consumer groups, trade associations, 

companies, and individuals. In some 

cases, several organizations jointly 

submitted a single comment letter. One 

financial reform organization, 

Americans for Financial Reform 

(‘‘AFR’’), submitted a single set of 

comments on behalf of 49 consumer, 

civil rights, privacy, and open 

government groups.5 The Bureau 

reviewed unique comments from 39 

individuals, as well as substantially 

identical comment letters from 

approximately 30,000 individuals 

expressing support for the Proposed 

Policy Statement. 

Commenters provided feedback on 

numerous aspects of the Proposed 

Policy Statement. Almost all comments 

concerned the expansion of the 

Database to include narratives. 

Companies and their trade associations 

generally opposed the inclusion of 

narratives in the Database. Many 

industry commenters asserted that the 

publication of ‘‘unverified’’ consumer 

narratives would unfairly damage the 

reputations of companies. Several trade 

associations also commented that 

inclusion of unstructured narratives is 

contrary to the Bureau’s stated mission 

of being data-driven. 

Per the AFR’s comment letter, 

consumer, civil rights, privacy, and 

open government groups supported the 

inclusion of narratives, asserting that 

among other things narratives would: 

‘‘(1) Empower consumers with timely, 

valuable information pre-purchase, in 

order to prevent problems and reward 

companies that respect their customers, 

and post-purchase, in order to report 

unreasonable, unfair or deceptive 

practices and alert others in advance of 

problems; (2) allow others to assist the 

Bureau in detecting destructive patterns 

before they do extensive damage; and 

(3) encourage more people to use the 

Database, as it becomes a more useful 

tool, creating a cycle of increased 

information about consumer 

experiences in the financial services 

marketplace.’’ These groups and 

individual commenters endorsed the 

goals underlying the publication of 

consumer narratives. 

Several commenters focused on 

normalization, or the use of some metric 

to provide context for data, for example, 

by including information on the number 

of accounts a company has for each 

particular product or service. Some 

industry commenters noted the risk of 

potential consumer re-identification and 

the impact certain laws may have on a 

company’s ability to respond publicly to 

a consumer’s complaint. Both trade 

associations and consumer groups 

submitted written comments advising 

the Bureau to be mindful of the privacy 

risks associated with narrative 

publication. Nonetheless, four 

nationally recognized privacy groups— 

Electronic Privacy Information Center, 

Privacy Rights Clearinghouse, Privacy 

Times, and World Privacy Forum— 

signed AFR’s comment letter in support 

of the Proposed Policy Statement. 

Additionally, Privacy Rights 

Clearinghouse submitted an individual 

comment generally supportive of 

disclosing narratives. 

Many submissions included 

comments directed to the Bureau’s 

method of processing consumer 

mstockstill on DSK4VPTVN1PROD with NOTICES

15574 Federal Register / Vol. 80, No. 56 / Tuesday, March 24, 2015 / Notices 

6Consumer Response maintains several feedback 

mechanisms for participants in the Complaint 

System and has plans to expand this capability over 

time. 

7 Disclosure of Consumer Complaint Narrative 

Data, 79 FR 45183 (Aug. 4, 2014). 

8The Administrative Procedure Act exempts 

general statements of policy from notice and 

comment. 5 U.S.C. 553(b)(A). 

9 12 U.S.C. 5512(c)(6)(A). 

10To the extent any features of this policy were 

considered binding on any party, the Bureau 

believes they would constitute procedural rules, 

which are likewise exempt from the requirements 

of notice and comment. 5 U.S.C. 553(b)(A). 

11See Ctr. for Auto Safety v. Nat’l Highway 

Traffic Safety Admin., 452 F.3d 798 (D.C. Cir. 2006) 

(agency’s general statement of policy was not a 

binding legislative rule simply because it had 

practical effects, rather than legal consequences, for 

private parties). Several commenters rely on 

Electronic Privacy Information Center v. 

Department of Homeland Security, 653 F.3d 1 (D.C. 

Cir. 2011), but the Bureau does not believe that case 

supports their argument. The agency action in that 

case, in the court’s view, imposed legally binding 

requirements on airline passengers to go through 

heightened security procedures or be barred from 

entering airport boarding areas. The opportunity to 

provide a public response narrative does not 

impose any similar binding requirement. 

12See 2013 Notice of Final Policy Statement, 78 

FR at 21226 (announcing planned changes to Public 

Complaint Database and stating Bureau’s intention 

to study and solicit further public feedback on the 

efficacy of its complaint policies)(April 10, 2013); 

2012 Notice of Final Policy Statement, 77 FR at 

37568 (same)(June 22, 2012). 

complaints, i.e., the Complaint System. 

To the extent that these comments also 

related to the scope of the Proposed 

Policy Statement, the Bureau addresses 

them below. Whether addressed below 

or not, the Bureau welcomes operational 

feedback and intends to continue to 

refine its Complaint System over time.6

III. Summary of Comments Received, 

Bureau Responses, and Resulting Policy 

Statement Changes 

This section provides a summary of 

the comments received by subject 

matter to the Proposed Policy 

Statement. It also summarizes the 

Bureau’s assessment of the comments by 

subject matter and, where applicable, 

describes the resulting changes that the 

Bureau is making in the Final Policy 

Statement including a change to how 

companies may respond publicly to 

individual complaints. All such changes 

concern the Consumer Complaint 

Database. There are no policy changes 

regarding the Bureau’s issuance of its 

own complaint data reports, e.g., the 

Consumer Response Annual Report. 

A. The Policy Statement Process 

The Bureau is committed to 

transparency and robust engagement 

with the public regarding its actions. 

Although not required by law to do so, 

the Bureau voluntarily solicited and 

received public comments on the 

Proposed Policy Statement. A few 

commenters requested a 60-day 

response period as opposed to the 30 

days originally provided, a request the 

Bureau granted.7 The Bureau received 

substantial public feedback expressing a 

range of viewpoints, and it has carefully 

considered the comments received, as 

described in detail below. As stated in 

the Final Policy Statement, the Bureau 

plans to monitor the effectiveness of its 

policy on an ongoing basis and to 

continue to engage with the public, 

including regulated entities, as it 

assesses the efficacy of the Final Policy 

Statement. 

Several commenters commended the 

Bureau on providing the opportunity to 

comment on the Proposed Policy 

Statement. A number of trade 

associations commented that the 

proposal could not be finalized in a 

general statement of policy and was 

instead a binding legislative rule subject 

to the procedural requirements of notice 

and comment rulemaking.8 Several of 

these groups argued that rulemaking 

was required because the policy would 

obligate companies to provide public 

responses or else suffer reputational 

harm from unanswered complaint 

narratives. Some groups stated that the 

policy would impose new duties on the 

Bureau to verify the details contained in 

the narratives or to protect consumer 

privacy by removing information that 

could lead to consumer reidentification. Two groups commented 

that § 1022(c)(6)(A) of the Dodd-Frank 

Act, which requires the Bureau to issue 

rules concerning the confidential 

treatment of information, dictates that 

any decision involving confidential 

information has to be enacted as a 

legislative rule.9 These groups also 

commented that the proposal would 

effectively amend the Bureau’s existing 

privacy regulations by releasing 

confidential information and therefore 

had to be enacted through notice and 

comment. Two groups pointed to the 

example of the Consumer Product 

Safety Commission, which provided 

details about its statutorily mandated 

database of consumer product safety 

complaints via a legislative rule. The 

groups argued that the Bureau was 

required to follow the same process in 

announcing this policy. Finally, several 

of these groups suggested that the 

importance of releasing consumer 

narratives or the interest in transparency 

meant that full notice and comment 

procedures were required. 

The Final Policy Statement is meant 

to inform the public about the Bureau’s 

intended use of its discretionary 

authority to release certain de-identified 

information. The planned addition of 

narratives to the Consumer Complaint 

Database is properly the subject of a 

policy statement and does not require 

formal rulemaking.10 The Bureau has 

made minor changes to the Final Policy 

Statement to clarify its nature as a 

general statement of policy. The policy 

neither binds private parties with any 

legal responsibilities nor creates any 

legal rights. As the Final Policy 

Statement makes clear, companies are 

under no obligation to recommend 

public-facing responses and will face no 

legal consequences by declining to do 

so. That some companies may decide it 

is worthwhile to recommend a public 

response does not rise to the level of a 

legal obligation.11 For their part, 

consumers are under no obligation to 

opt in to sharing their stories, as the 

consent language will make clear by 

stating that the decision whether to 

provide consent for public disclosure 

does not otherwise affect how the 

Bureau handles the complaint. 

The Bureau is also not binding itself 

with new legal duties. As explained 

below, the Bureau is not committing to 

verify the details contained in each 

complaint narrative. Although the 

Bureau plans to scrub identifying 

information from the consumer 

narratives, it intends to do so in order 

to assist consumers and ensure its 

compliance with existing laws, rather 

than through the assumption of such a 

duty through the present Final Policy 

Statement. The addition of narratives to 

the Consumer Complaint Database is 

also in keeping with the Bureau’s stated 

intent to continue refining the way it 

receives, shares, and makes use of 

consumer complaint information as well 

as with its past practice of making 

improvements to the Database.12 As part 

of advancing that effort, and in response 

to comments it received in response to 

the Proposed Policy Statement, the 

Bureau is also publishing a Request for 

Information on how it might create or 

enhance opportunities for consumers to 

share accounts of positive experiences 

they have had with providers of 

consumer financial products and 

services. 

The suggestion that § 1022(c)(6)(A) 

requires the Bureau to finalize this 

policy as a legislative rule is 

unpersuasive. That provision mandates 

that the Bureau ‘‘prescribe rules 

regarding the confidential treatment of 

information’’ it obtains in exercising its 

authorities. The Bureau has previously 

prescribed rules regarding the 

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Federal Register / Vol. 80, No. 56 / Tuesday, March 24, 2015 / Notices 15575 

13 Disclosure of Records and Information, 78 FR 

11484 (Feb. 15, 2013). 

14 2012 Notice of Final Policy Statement, 77 FR 

at 37560–61 (June 22, 2012); 2013 Notice of Final 

Policy Statement, 78 FR at 21220 (April 10, 2013). 

15 12 U.S.C. 5534(a). 

16Two commenters point to American Petroleum 

Institute v. SEC, 953 F. Supp. 2d 5 (D.D.C. 2013), 

in support of the argument that the Bureau lacks 

authority for the Database. In that case, the SEC 

contended that a statutory provision 

unambiguously required public disclosure of 

certain annual reports from regulated entities. The 

court held that the provision did not 

unambiguously require public disclosure and that 

the SEC had improperly cabined its discretion. Id. 

at 12–18. The Bureau believes American Petroleum 

Institute does not suggest the Bureau lacks authority 

to disclose consumer complaint narratives. That 

case addressed statutory provisions not at issue 

here. Moreover, the Bureau acknowledges its 

discretion with respect to the public disclosure 

described in the Policy Statement, and it does not 

believe that such disclosure is unambiguously 

required under the statute. 

17 12 U.S.C. 5493(b)(3)(A). 

18 12 U.S.C. 5534(a) & (b). 

19 12 U.S.C. 5511. 

20 12 U.S.C. 5512(c)(3)(B) (emphasis added). 

21 12 CFR 1070.40 through 1070.47. 

22 12 CFR 1070.41 (prohibiting Bureau employees 

from disclosing confidential information other than 

as provided in subpart D); 12 CFR 1070.2 (defining 

‘‘confidential information’’ to include ‘‘confidential 

consumer complaint information’’). 

confidential treatment of information.13

The disclosure contemplated by this 

policy is consistent with those rules, 

and therefore does not require an 

amendment to those rules. Finally, as 

noted previously, several commenters 

contend that the past practice of the 

Consumer Product Safety Commission, 

the general interest in transparency, or 

the importance of releasing consumer 

narratives require the Bureau to proceed 

via legislative rulemaking. None of these 

factors provides a legal basis for 

concluding that notice and comment 

rulemaking is required under the 

Administrative Procedure Act. The 

Bureau also notes that it has made the 

policy process transparent by 

voluntarily soliciting public comment 

and extending the comment period from 

30 to 60 days. 

B. Legal Authority for Consumer 

Complaint Database 

In the Bureau’s previous notices of its 

policy statements establishing and 

expanding the Consumer Complaint 

Database, the Bureau addressed in detail 

several comments related to the 

Bureau’s authority to establish a 

Database.14 Several comments in 

response to the Proposed Policy 

Statement implicate the same or similar 

arguments concerning the Bureau’s legal 

authority. The Bureau directs readers to 

and incorporates its prior discussions, 

and clarifies portions here. 

As was true with respect to the 

Bureau’s prior two policy statements, 

commenters contend that the DoddFrank Act expressly delineates the 

circumstances and manner in which the 

Bureau may collect, resolve, and share 

consumer complaints with others, and 

that a public-facing database is not 

explicitly included. Therefore, by 

adverse inference, they assert that the 

Dodd-Frank Act does not authorize the 

Database. 

Similarly, as was true with respect to 

the Bureau’s prior policy statements, 

commenters argue that § 1034 of the 

Dodd-Frank Act, which requires the 

Bureau to establish ‘‘reasonable 

procedures to provide a timely response 

to consumers . . . to complaints 

against, or inquiries concerning, a 

covered person,’’ 15 does not authorize 

the creation of a public-facing complaint 

database that, instead of aiding 

complainants, enables data mining and 

market research. Commenters also make 

arguments, similar to past comments, 

that § 1021 and § 1022 do not expressly 

grant authority for the Bureau to 

establish a public-facing database or 

disclose consumer complaint narratives 

to the public.16 They also contend that 

the Dodd-Frank Act’s restrictions on 

publishing confidential information 

block the implementation of such a 

database, including narratives. 

The Bureau has considered these 

comments and concluded that the 

Database is authorized by the DoddFrank Act. Among other things, 

§ 1013(b)(3) authorizes the 

establishment of a unit ‘‘whose 

functions shall include establishing a 

single, toll-free telephone number, a 

Web site, and a database or utilizing an 

existing database to facilitate the 

centralized collection of, monitoring of, 

and response to consumer complaints 

regarding consumer financial products 

or services.’’ 17 Section 1034(a) directs 

the Bureau to establish ‘‘reasonable 

procedures to provide a timely response 

to consumers, in writing where 

appropriate, to complaints against, or 

inquiries concerning, a covered person 

. . .,’’ and § 1034(b) provides that ‘‘[a] 

covered person subject to supervision 

and primary enforcement by the Bureau 

pursuant to section 1025 shall provide 

a timely response, in writing where 

appropriate, to the Bureau, the 

prudential regulators, and any other 

agency having jurisdiction over such 

covered person concerning a consumer 

complaint or inquiry. . . .’’18 These 

provisions require and establish 

conditions for specific methods of 

disclosure and responses, but do not 

express or imply any limit on the 

Bureau’s authority to disclose consumer 

complaint information in other ways. 

The Database as described would 

facilitate and supplement, not 

contravene, these provisions. The 

Database is reasonably encompassed 

within the Bureau’s authorities, 

especially in light of the Bureau’s other 

statutory objectives and functions, 

including promoting financial 

education, providing timely 

information, and ensuring that markets 

operate transparently.19 In addition, 

with prescribed limitations, the Bureau 

has broad discretionary authority to 

release information obtained during the 

exercise of its statutory functions and 

the Database, as described in the 

Proposed Policy Statement, would not 

contravene any legal constraints on the 

Bureau. 

Publication of such information 

would also be authorized by the 

Bureau’s express authority pursuant to 

§ 1022 to make certain information, 

including information from consumer 

complaints, public: Section 

1022(c)(3)(B) states that the Bureau 

‘‘may make public such information 

obtained by the Bureau under this 

section as is in the public interest, 

through aggregated reports or other 

appropriate formats designed to protect 

confidential information in accordance 

with paragraphs (4), (6), (8), and (9).’’ 20

This subparagraph permits the Bureau 

to disclose consumer complaint 

information in a non-aggregated format 

as long as the format is designed to 

protect confidential information in 

accordance with other specific 

provisions of § 1022(c). The Database 

would satisfy those criteria. 

The disclosure of information 

contemplated by this policy is also 

consistent with subpart D of the 

Bureau’s Final Rule on the Disclosure of 

Records and Information,21 which the 

Bureau promulgated pursuant to 

§ 1022(c)(6). Commenters are correct to 

point out that subpart D generally 

restricts the authority of the Bureau to 

publicly disclose ‘‘confidential 

information,’’ including ‘‘confidential 

consumer complaint information.’’ 22

However, such disclosure restrictions 

only apply to the extent that consumer 

complaint information is confidential in 

nature. The Bureau’s regulations define 

‘‘confidential consumer complaint 

information’’ to mean ‘‘information 

received or generated by the [Bureau], 

pursuant to [sections 1013 and 1034 of 

the Dodd-Frank Act], that comprises or 

documents consumer complaints or 

inquiries concerning financial 

institutions or consumer financial 

products and services and responses 

thereto, to the extent that such 

information is exempt from disclosure 

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15576 Federal Register / Vol. 80, No. 56 / Tuesday, March 24, 2015 / Notices 

23 12 CFR 1070.2(g). 

24 2012 Notice of Final Policy Statement, 77 FR 

at 37561 (June 22, 2012); 2013 Notice of Final 

Policy Statement, 78 FR at 21221 (April 10, 2013). 

25 2012 Notice of Final Policy Statement, 77 FR 

at 37562 (June 22, 2012). 

pursuant to 5 U.S.C. 552(b) 

[FOIA].’’ 23Because the information to 

be disclosed in the public database is 

disclosed with the consumer’s express 

consent and not exempt from disclosure 

under FOIA, such information does not 

constitute ‘‘confidential consumer 

complaint information.’’ Accordingly, 

§ 1022(c)(6)(A)’s grant of authority to 

issue rules regarding when the Bureau 

will treat information confidentially 

does not limit the Bureau’s discretion to 

disclose information consistent with 

those rules, but provides further 

authority for the policy. 

Furthermore, the Bureau intends to 

obtain consent from consumers to 

publish their complaint narratives. 

Obtaining written consent for disclosure 

aligns with requirements of 1022(c)(8), 

FOIA, the Privacy Act, and the Bureau’s 

confidentiality rules. The Bureau does 

not intend to release a narrative until 

the consumer expressly consents to 

publication and the Bureau has 

determined that the narrative has been 

de-identified according to a robust 

scrubbing standard. 

C. The Impact of the Disclosure of 

Consumer Complaint Narratives on 

Consumers 

Comments from consumer groups, 

open government groups, privacy 

groups, and individual commenters 

asserted that the publication of 

narratives would empower consumers 

to better understand the context of the 

data currently provided in the 

Consumer Complaint Database. The 

Reporters Committee for Freedom of the 

Press, on behalf of nine major news 

organizations and press trade 

associations, supported the publication 

of all narratives regardless of consent, 

stating that the Database is an 

invaluable resource for journalists as the 

experiences reflected in the narratives 

contribute to the public’s understanding 

of the relationships between consumers 

and financial institutions and inform 

the ongoing democratic debate regarding 

financial regulation. Consumer groups 

added that consumer narratives would 

be a valuable resource for researchers to 

identify trends in the business practices 

of companies, particularly as they relate 

to traditionally underserved consumers. 

Some commenters noted that 

narratives would encourage companies 

to address the sources of common 

complaints. Consumer groups stated 

that the publication of narratives would 

allow companies to better compete 

through customer service, further 

increasing the improvement in customer 

care resulting from the introduction of 

the Database. Other consumer groups 

commented that narratives would aid 

consumer advocacy and legal aid groups 

in serving their communities by helping 

to identify local trends. 

Industry commenters, by contrast, 

asserted that the publication of 

narratives in the Database would 

mislead consumers because the data is, 

in the commenters’ words, unverified 

and unrepresentative. And despite the 

fact that the Bureau confirms the 

existence of a commercial relationship 

before publishing complaints, multiple 

commenters expressed concern that 

complaints, and thus narratives, from 

individuals without a commercial 

relationship with the relevant company 

would appear in the Database. 

In general, the Bureau believes that 

greater transparency of information does 

tend to improve customer service and 

identify patterns in the treatment of 

consumers, leading to stronger 

compliance mechanisms and customer 

service. These have been features of the 

Consumer Complaint Database since its 

inception. In addition, disclosure of 

consumer narratives will provide 

companies with greater insight into 

issues and challenges occurring across 

their markets, which can supplement 

their own company-specific 

perspectives and lend more insight into 

appropriate practices. Other issues 

raised in the comments received by the 

Bureau are addressed below. 

1. Consumer Narratives 

a. Verification 

In its 2012 Notice of Final Policy 

Statement, the Bureau addressed several 

comments related to the disclosure of 

unverified consumer complaints. In 

response to the Proposed Policy 

Statement, several trade associations 

and companies continued to express 

concern, stating that unverified 

complaint narratives are likely to 

mislead consumers. Some trade 

associations suggested that the Bureau 

should only disclose narratives after a 

substantive investigation by the Bureau 

had been completed on that particular 

complaint. Some industry comments 

recommended distinguishing between 

unverified and verified complaints. 

Consumer groups and privacy groups, 

on the other hand, commented that the 

lack of verification presented minimal 

risk of misleading consumers. 

The Bureau incorporates its previous 

statements and analysis on this issue.24

The Bureau acknowledges that the 

Complaint System does not adjudicate 

the merits of each individual complaint 

disclosed in the Consumer Complaint 

Database, specifically stating on the 

Bureau’s Web site that it does not 

‘‘verify the accuracy of all facts alleged 

in complaints.’’ However, the Bureau 

does screen each complaint according to 

various criteria. The complaint is 

reviewed to determine whether it 

should be routed to another regulator. A 

determination is made whether each 

submission is a complaint, an inquiry, 

or feedback. Submissions in the latter 

two categories are not forwarded to the 

identified company for handling as 

complaints. Importantly, the 

commercial relationship between the 

company and the consumer is verified 

before disclosing it in the Database. The 

Bureau also verifies that the complaint 

is submitted by the identified consumer 

or by his or her specifically authorized 

representative before disclosure in the 

Database. Lastly, complaints are only 

forwarded to companies when they 

contain the required fields, including 

the complaint narrative, the consumer’s 

requested resolution, and the 

consumer’s contact information. The 

Bureau believes that with the 

information currently made public, 

supplemented by the contextual 

richness of the de-identified narratives, 

the public and the marketplace will 

have the capacity to assess all the data 

with the appropriate level of 

confidence. 

b. Manipulation 

Several trade associations and 

companies commented that third parties 

like debt negotiation companies could 

use complaint submission as a strategic 

tool to unfairly aid their clients. A 

company commenter claimed that at 

least one outside party has been using 

the company’s name unlawfully to 

defraud consumers, and that several 

complaints have been mistakenly 

lodged against the company as a result. 

Specifically, a third party was 

contacting consumers under the name of 

the other company to collect money and 

defraud consumers, and subsequently, 

several consumers lodged complaints 

against the other company. 

The Complaint System has a number 

of protections against manipulation. 

These protections were addressed in the 

2012 Notice of Final Policy Statement.25

For example, while the process of 

submitting a complaint is designed to be 

user-friendly and straightforward, it 

does require deliberate action and a 

moderate time commitment by the 

consumer. According to the Bureau’s 

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26 Disclosure of Consumer Complaint Narrative 

Data, 79 FR at 42768 (July 23, 2014). 

own calculations, the average amount of 

time required to complete a complaint 

submission via the Web site is eight 

minutes. Consumers must also affirm to 

the government that the information 

they provide is true to the best of their 

knowledge and belief. Again, the 

commercial relationship between the 

consumer and company is confirmed by 

the company before any complaint data 

is disclosed in the Consumer Complaint 

Database. With regard to the example 

provided regarding fraudulent use of a 

company’s identity: (1) Companies have 

the ability to alert the Bureau via an 

administrative response of any 

suspected fraud; (2) if properly 

identified by the company, such 

complaints do not appear in the 

Database; (3) if the Bureau finds any 

pattern of fraud by any entity within its 

jurisdiction, the Bureau can bring 

appropriate enforcement actions; and (4) 

in sending such complaints to the 

company, the Bureau is assisting 

company operations in quickly 

identifying and addressing instances of 

potential fraud. 

c. Misidentification 

Several trade associations and 

companies commented that consumers’ 

confusion about consumer financial 

products and services would lead to 

mistaken identification of the company 

against which the complaint is lodged. 

For example, one company commented 

that a consumer is likely to lodge a 

complaint against a credit reporting 

agency, when the consumer’s complaint 

should be against the data furnisher. 

Trade associations and other 

commenters suggested the inclusion of 

company relationships. For example, 

one consumer group recommended 

including the parent company when 

that company has multiple subsidiaries 

against which complaints are lodged. 

As previously noted, companies have 

the ability to notify the Bureau if no 

commercial relationship exists between 

the consumer and the company; such 

complaints are not suitable for 

disclosure in the Consumer Complaint 

Database. Regarding the credit reporting 

example that was provided, the Bureau 

empowers the consumer to elect whom 

to submit a complaint against 

(dependent, as noted, on an existing 

commercial relationship). Specific to 

the suggestion regarding inter- and 

intra-company relationships, the Bureau 

is exploring expansion of the Database 

to include additional company 

relationship information. 

d. Positive Feedback 

Several trade associations and 

companies commented that the 

Consumer Complaint Database should 

include positive narratives about 

companies in conjunction with 

complaint narratives. One commenter 

suggested that if the Database is to 

function as a marketplace of ideas, then 

it should reflect the entire market and 

not solely consumers submitting 

complaints. Several trade associations 

stated that if the Database is to be 

likened to private web-based review 

sites, then positive feedback is 

necessary. 

Consistent with these comments, the 

Bureau believes that the Bureau should 

share data that provides an unbiased 

perspective on company behavior 

toward consumers. At present, the 

Bureau already collects and shares some 

elements of positive feedback regarding 

company complaint handling. For 

example, the Consumer Complaint 

Database currently discloses 

information that can be used to 

highlight positive company behavior, 

e.g., companies with timely responses or 

low consumer dispute rates. However, 

the Bureau intends to further explore 

ways in which positive company 

behavior may be highlighted. 

Concurrent with the Final Policy 

Statement, the Bureau is publishing a 

Request for Information to solicit and 

collect input from the public on the 

potential collection, identification, and 

sharing of data and feedback specific to 

positive interactions with providers of 

consumer financial products and 

services. 

e. Language Access 

Several consumer groups commended 

the accessibility of the Bureau’s contact 

center, with translation available in over 

180 languages. These groups requested 

that the Bureau make the online 

complaint submission form available in 

multiple languages. 

In addition to telephone support for 

non-English speaking consumers, the 

Bureau plans over time to make its 

online complaint intake form on 

consumerfinance.gov available in 

Spanish, and subsequently to explore 

making the form available in other 

languages as well. The Bureau is 

committed to providing persons with 

limited English proficiency meaningful 

access to its programs and services. 

f. Third Party Submissions and Referrals 

Several trade associations and 

companies raised concerns that 

narratives from third parties without 

authority to make a complaint on behalf 

of a consumer nevertheless would be 

published, and companies would be 

compelled to respond publicly. The 

Conference of State Bank Supervisors 

requested clarification on whether 

narratives within complaints referred 

from other government agencies would 

be disclosed. 

This Final Policy Statement does not 

apply to complaints submitted by any 

third parties or via agency referral, and 

the Bureau does not intend to disclose 

such narratives at this time. The 

Complaint System affords companies 

the opportunity to alert the Bureau if 

they are unable to verify the commercial 

relationship with the consumer who 

submitted the complaint before the 

complaint is disclosed in the Consumer 

Complaint Database. 

2. Company Responses 

In its Proposed Policy Statement, the 

Bureau stated that: 

Where the consumer provides consent to 

publish their narrative, the related company 

will be given the opportunity to submit a 

narrative response for inclusion in the 

Consumer Complaint Database. The company 

will be instructed not to provide direct 

identifying information in its public-facing 

response, and the Bureau will take 

reasonable steps to remove personal 

information from the response to minimize 

(but not eliminate) the risk of reidentification. The Company Portal will 

include a data field into which companies 

have the option to provide narrative text that 

would appear next to a consumer’s narrative 

in the Consumer Complaint Database.26

The Bureau received comments from 

companies and trade associations 

arguing that, because of business and 

legal considerations, they would be 

limited in their ability to provide 

meaningful public-facing unstructured 

narrative responses and that such 

responses would be impracticable or 

unhelpful. In response, the Bureau 

intends to adopt an alternative approach 

based on structured company responses, 

as discussed below. 

a. Quality of Company Responses 

Trade associations and companies 

both questioned the fairness of publicly 

disclosing consumer narratives because 

they argued that, under the Bureau’s 

proposal, companies would be limited 

in their ability to provide public-facing 

unstructured narrative responses. 

Several companies, trade associations 

and individual commenters expressed 

concern that their ability to provide 

meaningful public-facing unstructured 

narrative responses would be limited by 

laws such as the Gramm-Leach-Bliley 

Act and Regulation P, the Fair Credit 

Reporting Act and Regulation V, and the 

Fair Debt Collection Practices Act. 

Commenters argued that, under the 

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Bureau’s proposal to permit voluntary 

narrative company responses, they 

might not be able to provide any publicfacing response at all due to legal, 

business, and reputational 

considerations. These commenters 

argued that frank responses may be 

viewed negatively by the public and 

companies would be discouraged from 

attempting to articulate individualized 

responses. They argued that, in practice, 

voluntary public-facing company 

responses would not provide the 

balance suggested in the Proposed 

Policy Statement. Some commenters 

suggested various ways the Bureau 

could mitigate these concerns, including 

providing specific interpretive 

guidance. Consumer groups stated that 

making consumer narratives and 

company responses public would allow 

for consumers to make individual 

determinations regarding the quality of 

the company’s service. 

Responsive to company and trade 

association feedback, the Bureau 

acknowledges that unstructured 

company narratives may not effectively 

provide companies with a mechanism to 

balance a consumer’s narrative. 

Therefore, the Bureau intends to 

provide companies with a finite list of 

optional structured responses from 

which they can choose. Within the 

secure web portal companies use to 

respond to complaints, the Bureau 

intends to add a set list of company 

responses, giving companies the ability 

to recommend a public-facing response 

addressing the substance of the 

consumer’s complaint. Companies will 

be under no obligation to avail 

themselves of this opportunity. The 

Bureau plans to adopt company 

recommendations as a general matter, 

but it reserves discretion to assess 

whether there are good-faith bases for 

the recommendations. In addition, the 

Bureau plans to assess its review 

process over time. The Bureau plans for 

this functionality to apply to all 

consumer complaints disclosed via the 

Consumer Complaint Database (and not 

only those with consumer consent to 

disclose the associated narrative). 

Although this approach was not 

specifically proposed by commenters, 

the Bureau believes that it should 

eliminate or significantly mitigate the 

concerns, raised by companies, arising 

from the risk of public disclosure of 

protected confidential information. 

Companies that voluntarily decide to 

provide a public-facing response will 

not be put in a position of assessing 

what level of detail will address a 

complaint while protecting confidential 

information. The Bureau believes 

companies will be more likely to 

recommend public-facing structured 

responses than they would be to provide 

unstructured public-facing responses, 

and that the reputational risks of 

recommending structured responses 

will be lower. The Bureau also believes 

that this approach will lead to more 

standardized information that may 

facilitate the Bureau’s other functions 

and goals with respect to the Consumer 

Complaint System, such as monitoring 

and reporting on complaints. 

Companies are ultimately responsible 

for ensuring their compliance with all 

legal requirements. The Bureau believes 

that its approach of making publicfacing structured responses voluntary 

allows companies sufficient flexibility 

to assess legal, business, reputational, 

and other considerations relevant to the 

decision of whether to provide publicfacing responses. Finally, while 

providing an opportunity for publicfacing structured company responses 

offers significant benefits, the Bureau 

notes that the benefits of publicly 

disclosing unstructured consumer 

complaint narrative data, as explained 

in this Final Policy Statement, justify 

such disclosures, even absent an 

opportunity for public-facing company 

responses. 

b. Public and Private Company 

Responses 

The Bureau solicited feedback on 

whether any potentially public-facing 

company response should be distinct 

and in addition to the response 

companies currently send directly to the 

consumer. Several companies and trade 

associations commented that it should 

be distinct as the public response will 

have to be adapted to conform to 

applicable privacy laws. Several 

consumer groups and one company, on 

the other hand, commented that the 

same response, but in redacted form, 

should be publicly displayed in order to 

provide the public with the necessary 

context to interpret the data. Some trade 

associations commented that it would 

be operationally burdensome to create 

two separate responses. 

The Bureau plans to ensure that 

companies have the option to provide 

both a private (to-consumer) response 

and recommended public-facing 

structured (to be shared via the 

Database) response to a consumer’s 

complaint. One of the principal benefits 

for consumers of the Bureau’s complaint 

handling services is the requirement 

that companies respond to the consumer 

and the Bureau remains committed to 

keeping the focus on assisting 

consumers with their complaints. Based 

on data available in the Consumer 

Complaint Database, approximately 

62% of complaints are ‘‘closed with 

explanation’’ and the majority of those 

(75%) are not disputed by the 

consumer. The Bureau is concerned that 

mandating that the to-consumer 

company responses be made public 

could have a chilling effect on wellreceived, detailed responses to 

consumers, potentially leading to higher 

consumer dispute rates. Based on 

comments received by companies on 

this issue, this concern would appear to 

be well founded. Allowing the company 

the choice to provide one very detailed 

private communication to its consumer, 

as well as a separate public-facing 

response, would address the Bureau’s, 

companies’ and consumers’ interests on 

this issue. 

c. Response Time 

Currently, companies have 15 days to 

provide an initial response to a 

consumer complaint. Several trade 

associations and companies commented 

that the response time should be 

extended in order to accommodate the 

drafting of a separate, public-facing 

response. Some comments 

recommended extending the initial 

response time to as many as 60 days. 

The Bureau believes that the marginal 

increase in burden associated with 

voluntarily recommending a separate 

structured public response does not 

necessitate a deviation from the current 

complaint handling requirements, 

which themselves are designed to 

provide the complaining consumer with 

a timely response. 

d. Timing of Narrative and Response 

Posting 

Trade associations, consumer groups, 

and individual commenters supported 

the simultaneous posting of the 

consumer narrative and company 

response. One consumer group 

recommended posting the consumer 

narrative after 15 days, and posting the 

company’s public response as it 

becomes available. Several commenters 

recommended 45 days; one company 

recommended 60 days. One commenter 

recommended publication after 35 days, 

to align generally with timing provided 

under the Fair Credit Reporting Act for 

consumer reporting agencies to 

reinvestigate and respond to consumer 

disputes. 

There are at least three timing options 

regarding the disclosure of the 

consumer narrative and company 

response: (1) Disclose the consumer 

narrative and company response (if 

available) when the company provides 

an initial response, but no later than 15 

days after the complaint is routed to the 

company (the system currently in place 

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27 2012 Notice of Final Policy Statement, 77 FR 

at 37564 (June 22, 2012); 2013 Notice of Final 

Policy Statement, 78 FR at 21222 (April 10, 2013). 

28 ‘‘Our Mission’’ http:// 

www.consumerfinance.gov/strategic-plan/. 

for non-narrative complaint data), (2) 

disclose the consumer narrative and 

company response (if available) 15 days 

after the complaint is routed to the 

company, or (3) disclose the consumer 

narrative when the company provides 

its public-facing response, but no later 

than 60 days after the complaint is 

routed to the company. Under all three 

options, the complaint’s structured 

closure responses would continue to 

follow the current disclosure timing 

(option number 1) and the consumer 

narrative would only be disclosed once 

it is scrubbed of personal information. 

However, only option three guarantees 

that a public-facing company response, 

to the extent one is provided within the 

60-day period, would be disclosed 

contemporaneously with the consumer 

narrative. 

After careful consideration, therefore, 

the Bureau intends to adopt option 

number three. Option number one could 

force the company to choose between its 

desire to respond to and close 

complaints quickly versus its desire to 

provide an appropriate public facing 

response. Option number two may 

result in instances in which the 

company legitimately needs additional 

time, has appropriately communicated 

to the Bureau an ‘‘in progress’’ response 

(allowing for up to 60 days to respond), 

and yet the consumer narrative is made 

public on day 15 and possibly without 

an accompanying company response. 

Option three carries a similar risk to 

option number one, potentially creating 

the incentive for companies to delay 

providing an optional public-facing 

response for the full 60-day allowance 

(and thus delaying disclosure of the 

consumer narrative). However, erring on 

the side of fairness to companies by 

ensuring contemporaneous release, the 

Bureau plans to implement option three. 

3. Maintaining the Complaint Database 

a. Updates to Published Narratives 

Several consumer groups commented 

that consumers should be allowed to 

update narratives to inform the public of 

the status of the complaint. Some trade 

associations asked that consumers be 

provided the ability to remove their 

narratives if they are satisfied with the 

complaint resolution. 

Once given, at any point in the 

process, consumers will have the ability 

to withdraw their consent regarding 

publication of their narrative in the 

Consumer Complaint Database. At such 

time the consumer’s narrative will be 

removed from the Database. However, 

data already downloaded by the public 

cannot be recalled by the Bureau. Based 

on the Bureau’s experience to date 

reviewing consumer complaints, 

company responses, and ensuing 

resolutions, the Bureau believes that no 

additional back-and-forth functionality 

is necessary at this time. 

b. Removal of Old Narratives 

Several trade associations and one 

company commented that complaints 

and narratives should be removed from 

the database after a given step in the 

process or given amount of time, e.g., 

quarterly. 

The Bureau believes that consumers 

and the marketplace are capable of 

independently assessing the value of 

complaints based in part on when those 

complaints were submitted and 

therefore has no plans to remove 

complaints from the Consumer 

Complaint Database based on their age 

or status. 

c. Normalization 

Several trade associations and 

companies commented that the 

unstructured narrative data should be 

accompanied by information providing 

context to the company’s profile, 

including how many transactions the 

company conducts per year, how many 

complaints are received, and how many 

complaints are satisfactorily resolved. 

The Bureau notes the general 

agreement by commenters that 

normalization would improve the 

quality of the data in the Consumer 

Complaint Database. As discussed in the 

Bureau’s notices of its previous policy 

statements, data normalization is a 

complicated issue, and one that the 

Bureau is continuing to explore.27 The 

Bureau also notes that market 

participants, news organizations, and 

consumer groups can and have created 

normalized results. 

d. Protected Group Information 

Several consumer groups requested 

the inclusion of protected group 

information, such as sex, ethnicity, race, 

age, disability, marital status, or 

national origin, on complaint 

submissions. These comments noted 

that it would be helpful to have this 

information to identify trends in 

companies’ business practices. 

The Bureau agrees that the collection 

and public disclosure of protected group 

data has the potential to increase the 

quality of the dataset made available via 

the Consumer Complaint Database. 

However, there remain many open 

questions that the Bureau must first 

explore before moving forward on this 

suggestion, including the 

appropriateness of collecting protected 

group data, its representativeness, and 

the potential challenges with disclosing 

protected group data given the Bureau’s 

sensitivity to re-identification risk. 

Furthermore, as discussed elsewhere, 

the Bureau’s Database scrubbing 

standard would remove demographic 

information such as gender, age, and 

race, and ethnicity provided by 

consumers in the text of their narratives. 

D. Consumer Consent to Disclose 

Narratives 

1. Opt-in Consumer Consent 

Trade associations, consumer groups, 

and individual commenters supported 

the proposed opt-in feature requiring a 

consumer’s consent in order for 

narratives to be eligible for publication. 

A trade association representing news 

organizations asserted its view that 

narratives are subject to disclosure 

under FOIA regardless of consumer 

consent. Based on this viewpoint, it 

urged that at most the Bureau should 

permit consumers to opt-out of 

publication as opposed to having to optin. Commenters also generally agreed 

that consumers should maintain the 

right to revoke their consent at any time. 

A central tenet of the Bureau’s work 

is to empower consumers; providing 

them with the option to opt-in (as 

opposed to requiring them to opt-out) 

and the right to withdraw their consent 

to publication of their narrative in the 

Consumer Complaint Database at any 

time advances that end.28 With respect 

to the comment about the application of 

the FOIA to narratives, the Chief FOIA 

Officer is authorized to grant or deny 

any request for a record of the CFPB, in 

accordance with the requirements of the 

FOIA and the Bureau’s regulations. 12 

CFR 1070.15. If the Bureau receives 

FOIA requests for records that are not 

published in the Consumer Complaint 

Database pursuant to this Final Policy 

Statement, the Chief FOIA Officer will 

determine whether to grant the request, 

or to deny it due to the applicability of 

FOIA exemptions. 

2. Placement and Design of Consent 

Some commenters discussed the 

appearance of the opt-in form. 

Consumer groups requested that the optin be presented to the consumer early in 

the complaint process so that consumers 

can consider the implications as they 

draft their complaints. One company 

recommended providing the option to 

opt-in only once the consumer has 

received a response and has had the 

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29The Bureau emphasizes that the consent 

procedure described in the text for authorizing 

public disclosure of narratives may not be adequate 

to satisfy consent requirements under other statutes 

and regulations that the Bureau administers or 

enforces. 

30 Disclosure of Consumer Complaint Narrative 

Data, 79 FR at 42769 (July 23, 2014). 

opportunity to consider the implications 

of publication. Some consumer groups 

recommended that, to encourage 

publication, the opt-in option be 

displayed prominently on the consent 

form. Additionally, some commenters 

requested that consumers have a 

distinct field on the form in which they 

can specify what personal information 

they want excluded from their narrative. 

The Bureau plans to place the opt-in 

consent at the submission phase of the 

complaint. The Bureau believes the 

decision whether or not to consent is 

most appropriate at the actual time of 

complaint submission. This decision is 

consistent with the practice of the 

Consumer Product Safety Commission, 

which also obtains consent to disclose 

complaint narratives in its public-facing 

database. 

3. Elements of Informed Consent 

Some commenters recommended 

including disclaimers with the opt-in 

feature that notify consumers of what 

the commenters perceived to be a risk 

of defamatory speech. Some trade 

associations and companies commented 

that the Bureau should inform 

consumers of the risks of narrative 

publication, including the possibility of 

re-identification. Trade associations and 

companies generally commented that 

the consumer should be notified of the 

company response procedure and risks 

of consenting to publication. One press 

group commented that the consumer 

should be notified that his or her 

narrative is subject (in the commenter’s 

view) to FOIA disclosure. One 

consumer group commented that 

consumers should be notified that 

consenting to publication may provide 

additional assistance to other consumers 

facing similar issues. The Bureau agrees 

that when a consumer is making the 

decision whether or not to opt-in, it is 

essential that the consumer have the 

information to weigh appropriately the 

risks of consenting to the disclosure of 

their de-identified narrative against 

individual and public benefits of doing 

so. In support of that goal, in addition 

to the consent language, the Bureau 

intends to provide clear, easily 

understandable material describing the 

scrubbing standard, methodology, and 

publication process, the remaining risk 

to privacy, and the possibility of reidentification. The Bureau is committed 

to continuously improving these 

materials over time to empower the 

consumer to make the most appropriate 

choice for his or her individual needs 

and circumstances. 

However, consumers do not waive 

any privacy interests they may have in 

the information merely by submitting it 

to the Bureau.29

E. Personal Information Scrubbing 

Standard and Methodology 

1. Scrubbing Standard and Methodology 

The Bureau requested feedback on the 

standard and methodology it intends to 

utilize for scrubbing personal 

information in the narratives. This 

scrubbing standard would be applied 

comprehensively to all data shared via 

the Consumer Complaint Database. 

Consumer groups offered comments 

supporting the proposed use of 

modified Health Insurance Portability 

and Accountability Act (‘‘HIPAA’’) 

standards for scrubbing narratives. 

Some companies expressed concern that 

significant identifiers associated with 

major life events may remain, 

notwithstanding the scrubbing process. 

One company commented that 

scrubbing should be applied to all 

identifying information, including 

references to third parties. Another 

company noted the differences between 

health data and unstructured narratives, 

expressing concern that a HIPAA-based 

methodology would not be effective and 

that the Bureau has not provided 

sufficient detail on the scrubbing 

mechanism to be used. One privacy 

organization recommended that the 

Bureau scrub company responses. 

The Bureau’s Database scrubbing 

standard is modeled after the HIPAA 

Safe Harbor Method, which is generally 

considered to represent a best practice 

for de-identifying data. In addition to 

adopting most of the specific HIPAA 

identifiers, the Bureau also plans to 

remove: (1) Demographic information 

such as gender, age, race, and ethnicity; 

(2) appropriate analogues to HIPAA 

identifiers in the consumer financial 

domain, e.g., credit card numbers; and 

(3) identifiers which the Bureau knows 

appear in complaints and could 

reasonably be used to identify 

individuals, e.g., references to third 

parties other than the company that is 

the subject of the complaint. The 

scrubbing methodology contemplates a 

computer-based automated step and a 

quality assurance step or steps 

performed by human reviewers. 

2. ZIP Codes 

The Bureau requested feedback on 

whether to disclose 5-digit ZIP codes 

alongside redacted narratives.30 By and 

large the responses that were received 

supported two options. The majority of 

commenters suggested the Bureau 

disclose 5-digit ZIP codes, except where 

population in the ZIP code contains 

fewer than 10,000 people. The second 

most cited option recommended 

disclosing full 5-digit ZIP codes, 

regardless of population. On the other 

extreme, one commenter suggested that 

ZIP codes should be excluded 

altogether, with state or county being 

used as the geographic identifier. 

While the Bureau acknowledges the 

unique value of detailed geographic 

data, it is also acutely aware of the 

heightened risk 5-digit ZIP codes can 

create for re-identification. Accordingly, 

the Bureau plans to disclose 5-digit ZIP 

codes, except where the population in 

the ZIP code contains fewer than 20,000 

people. In such cases, the Bureau plans 

to disclose the 3-digit ZIP code, except 

where the 3-digit ZIP code population 

contains fewer than 20,000 people, in 

which case the Bureau does not intend 

to disclose any ZIP code data. While 

this approach represents a different 

approach than those suggested by most 

commenters, the Bureau believes that 

this option appropriately balances the 

utility of geographic data with the 

associated risk to individual consumer 

privacy. As with all elements of its 

scrubbing standard, the Bureau intends 

to make adjustments in the future 

guided by the goal of simultaneously 

maximizing data utility and individual 

privacy. 

3. Re-identification 

Several trade associations and 

companies commented that despite the 

proposed scrubbing methodology, an 

unacceptably high risk of reidentification will remain. Some 

commented that in areas with small 

populations, even scrubbed narratives 

could lead to re-identification based on 

other details not covered by HIPAA 

standards. One company also 

commented that the risk of narrative 

content being repeated through social 

media raises the possibility of reidentification by individuals familiar 

with the consumer. Consumer and 

privacy groups commented that the risk 

of re-identification is minimal, and 

offset by the benefits of the policy and 

rigor of the scrubbing standard. 

As the Bureau stated in the Proposed 

Policy Statement, sharing data 

containing any personal information 

presents a tension between data utility 

and individual privacy. As a particular 

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Federal Register / Vol. 80, No. 56 / Tuesday, March 24, 2015 / Notices 15581 

31 2012 Notice of Final Policy Statement, 77 FR 

at 37562 (June 22, 2012). 

personal information scrubbing 

standard becomes more or less stringent, 

the utility of a given de-identified 

dataset may become respectively less or 

more useful. The publication of 

narratives involves risks, including the 

potential harm associated with the reidentification of actual consumers 

within the Consumer Complaint 

Database. The Bureau believes that it is 

appropriate to publish only those 

narratives for which opt-in informed 

consumer consent has been obtained, 

that have also been subjected to 

scrubbing under a robust personal 

information scrubbing standard and 

methodology. 

F. Impact of Narrative Publication on 

Companies and the Marketplace 

1. Reputational Harm 

Trade associations commented that 

the public disclosure of unverified 

narratives would result in reputational 

harm to companies. Some comments 

argued that any perceived benefit to 

consumers through narrative 

publication would be outweighed by the 

reputational harm suffered by 

companies. 

The Bureau takes seriously company 

and trade association concerns that 

financial institutions could incur 

intangible reputational damage as a 

result of the disclosure of narratives. As 

stated in previous policy statements, to 

a large extent, this risk is inherent in 

any release of complaint data. In 

deciding to release the structured 

complaint data, the Bureau considered 

this concern and concluded that, while 

there is always a risk that market 

participants will draw erroneous 

conclusions from available data, the 

marketplace of ideas would on the 

whole be able to determine what the 

data show and their relative importance. 

The Bureau believes this to be equally 

true with respect to narratives, and that 

consumer narrative publication will in 

fact make it easier for the marketplace 

to evaluate the rest of the complaint 

data by providing more information and 

context. Likewise, the Bureau also 

believes that the option for companies 

to provide public-facing structured 

responses will enhance the effectiveness 

of the Database and provide an 

opportunity for companies to enhance 

their reputation and mitigate potential 

concerns. 

Consistent with these comments, the 

Bureau believes that the Database 

should include data that provides an 

unbiased perspective on company 

behavior toward consumers. 

Accordingly, in parallel to the 

finalization of the instant Final Policy 

Statement, the Bureau intends to further 

explore ways in which positive 

company behavior may be highlighted. 

Concurrent with the Final Policy 

Statement, the Bureau is publishing a 

Request for Information to solicit and 

collect input from the public on the 

potential collection, identification, and 

sharing of data and feedback specific to 

positive interactions with providers of 

consumer financial products and 

services. 

2. Effect on Consumer Relations 

Several companies, trade associations, 

and a public interest organization 

commented that publicly posting 

narratives could create disincentives for 

consumers to deal directly with 

companies to resolve their disputes. 

Some commenters requested that 

narratives only be posted after the 

consumer has directly contacted the 

company. A few trade associations 

commented that narrative publication 

would cause general harm to customer 

relations by making the process more 

adversarial. 

The data collected from the Bureau’s 

credit card intake form and survey work 

shows that the vast majority of 

consumers have already attempted, 

often several times, to resolve the 

complained-about issue with the 

company before seeking assistance from 

the Bureau. As previously stated, a 

central element of the Bureau’s mission 

is to empower consumers; the Bureau 

believes that requiring consumers to 

contact the company before engaging 

the Bureau would work against that 

goal. Such an additional procedural 

hurdle may also discourage some 

number of consumers from submitting 

complaints, which would have the 

effect of depriving the Bureau of the 

information underlying the complaint. 

This could serve to undermine Bureau 

functions that rely, at least in part, on 

complaint data to inform their 

respective activities. 

Similarly the Bureau is skeptical of 

concerns that disclosing narratives 

would create disincentives for 

consumers to deal directly with the 

company and would cause general harm 

to customer relations by making the 

process more adversarial. Feedback the 

Bureau has received suggests the 

introduction of the Consumer 

Complaint Database and the Bureau’s 

activities generally have caused greater 

investment by companies in their 

customer service operations, which 

includes company complaint handling. 

The Bureau views this development as 

a positive step for customer service at 

companies that are making such 

investments. 

3. The Appearance of Validating 

Complaints by the Act of Disclosing 

Them 

Several trade associations, companies, 

and individual commenters stated that 

by including unverified comments on a 

government Web site, the narratives will 

be portrayed as being validated by the 

Bureau. 

Similar concerns were previously 

raised and addressed by the Bureau in 

the 2012 Notice of Final Policy 

Statement.31 The Bureau acknowledged 

the possibility that some consumers 

may (or may be led to) draw erroneous 

conclusions from the data. That is true, 

however, for any market data. In 

recognition of this risk the Bureau 

provides the following disclaimer on the 

Consumer Complaint Database: ‘‘We 

don’t verify all the facts alleged in these 

complaints but we take steps to confirm 

a commercial relationship between the 

consumer and company. Complaints are 

listed here after the company responds 

or after they have had the complaint for 

15 calendar days, whichever comes first. 

We remove complaints if they don’t 

meet all of the publication criteria. Data 

is refreshed nightly.’’ The Bureau 

believes this disclaimer to be sufficient 

to address the risk identified by 

commenters. 

As discussed elsewhere, it is 

noteworthy that several other 

government agencies make consumer 

complaint narratives available, 

including the Consumer Product Safety 

Commission, the National Highway 

Transportation Safety Administration, 

and, pursuant to FOIA requests, the 

Federal Trade Commission. 

4. Consumer Confusion and Lack of 

Context 

Several trade associations commented 

that unstructured narrative data 

provides minimal benefit to consumers 

as required scrubbing would remove 

any useful information from the 

narrative and responses. Some trade 

association comments added that the 

Bureau’s resources would be better 

utilized by providing more context for 

data already provided in the Database. 

Some consumer groups requested better 

organization of the data provided in the 

Database. 

As noted previously, sharing data 

containing personal information 

presents a tension between data utility 

and individual privacy. The Bureau 

believes, based on the comments 

received from various consumer and 

privacy groups, that it is possible to 

strike a balance between these two 

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15582 Federal Register / Vol. 80, No. 56 / Tuesday, March 24, 2015 / Notices 

important interests and still disclose a 

dataset that provides significant benefit 

to the marketplace. The Bureau will 

continually monitor this balance for 

opportunities to adjust its personal 

information scrubbing standard, which 

the Bureau intends to describe on its 

Web site. Furthermore, the Bureau is 

committed to the continuous 

improvement of the Consumer 

Complaint Database, which includes the 

addition of increasing levels of context, 

organization, and data normalization. 

5. Increased Litigation 

A few companies and trade 

associations commented that the 

publication of narratives would lead to 

increased litigation, either through 

potentially ‘‘defamatory’’ narratives 

posted by consumers or as a result of 

additional information available to 

prospective plaintiffs. One company 

expressed the concern that complaints 

and narratives could be sources of 

information appropriately left to be 

obtained during the discovery process. 

One trade association also commented 

that the privacy risks of published 

narratives could increase the risk of 

legal liability and heighten litigation 

costs. One legal aid organization 

commented that the availability of 

complaint narratives would help 

consumer advocacy groups to identify 

local trends of unlawful behavior and 

target legal efforts more effectively. 

The Bureau believes the risk of 

increased litigation following the 

disclosure of narratives to be low. The 

closest analogs to the Bureau’s plan for 

narrative disclosure are the Consumer 

Product Safety Commission’s publicfacing complaint database and the 

Federal Trade Commission’s disclosures 

pursuant to FOIA requests; the Bureau 

is not aware of any information that 

those disclosures have increased 

litigation against companies. Ultimately, 

the Bureau believes there is significant 

value in making available Bureau 

complaint data to help in the 

identification of and calling attention to 

potentially unlawful behavior. 

6. Increased Company Costs 

Several trade associations and 

companies commented that the 

additional procedure of creating a 

second, public-facing response, and 

ensuring its compliance with potentially 

applicable laws, would increase 

operational costs for companies. Some 

of these commenters also emphasized 

the increased costs to the Bureau 

resulting from additional infrastructure 

necessary to publish narratives. One 

public interest group also highlighted 

the financial burden of producing 

additional responses to narratives. 

As noted above, and in light of the 

comments received, the Bureau intends 

to provide companies with a finite list 

of optional structured responses that 

will allow them to recommend to the 

Bureau an optional public response to 

address the substance of consumers’ 

complaints. The Bureau believes that 

this approach significantly decreases the 

operational costs of providing 

independent public-facing responses, as 

compared to the Bureau’s proposal of 

providing separate narrative responses. 

Still, the Bureau acknowledges that 

additional effort and expense may be 

borne by companies in connection with 

preparing public-facing responses to 

consumer narratives. The Bureau has 

weighed these factors, in addition to the 

increased burdens on the Bureau’s own 

complaint handling operation. The 

Bureau considers it a matter of fairness 

to provide companies with the 

opportunity to address publicly 

consumer complaints from the 

company’s perspective. It is important 

to recognize that no company will be 

required to recommend a public-facing 

response, and it is entirely up to the 

company whether it wants to take 

advantage of this forum. The Bureau 

does not believe that the additional 

burden a company may bear in taking 

advantage of this opportunity, 

particularly given the Bureau’s 

movement to structured responses and 

away from unstructured narrative 

company responses, outweighs the 

benefit of publicly disclosing narratives 

to consumers and the marketplace. 

7. Confidentiality Agreements 

One individual commented that the 

public posting of consumer narratives 

would create an incentive for companies 

to require consumers to sign nondisclosure agreements when creating an 

account. This commenter recounted an 

experience in which he submitted a 

complaint to the Bureau and when 

settling the matter with the company, 

the company asked him to sign a 

confidentiality agreement. 

The Bureau’s experience to date has 

not uncovered widespread company use 

of non-disclosure agreements in 

connection with the Consumer 

Complaint Database, and no company 

comments on the proposed Policy have 

indicated that companies intend to 

utilize non-disclosure agreements as gag 

orders in the way envisioned by this 

comment. The Bureau’s market 

monitoring will remain alert to 

developments along these lines. 

However, the Bureau would likely look 

disfavorably upon agreements that 

require a consumer to withdraw his or 

her consent to have a narrative 

published as a condition of settlement. 

IV. Implementing the Final Policy 

Statement 

Following publication of the Final 

Policy Statement, the Bureau will turn 

to implementation of the policy. The 

Bureau intends to modify its Web site 

and online complaint intake form to 

collect informed opt-in consumer 

consent. In conjunction with the 

collection of consumer consent, the 

Bureau intends to finalize and post on 

its Web site the Consumer Complaint 

Database scrubbing standard. The 

Bureau will also modify the company 

web portal to add functionality to allow 

companies to provide the recommended 

public-facing responses, reach out to 

companies on the company web portal 

to offer training and provide technical 

support related to the policy. The 

Bureau will finalize its automated and 

manual review processes and then begin 

scrubbing narratives. 

The Bureau will not disclose any 

scrubbed and consented-to narratives 

until sufficient time has elapsed to 

allow the Bureau to adequately 

complete and assess the above actions. 

V. Final Policy Statement 

The Bureau hears directly from the 

American public about their 

experiences with the nation’s consumer 

financial marketplace. An important 

element of the Bureau’s mission is the 

handling of individual consumer 

complaints regarding consumer 

financial products and services. 

In June 2012, the Bureau began 

making de-identified individual-level 

complaint data available via its webbased, public-facing database (the 

‘‘Consumer Complaint Database’’). Since 

launch, the Consumer Complaint 

Database has been expanded to include 

additional consumer financial products 

and data fields as products have been 

added to its complaint handling system. 

Consistent with its strategic vision, the 

Bureau is committed to the continued 

growth and refinement of the Consumer 

Complaint Database in a manner that 

helps inform consumers and the 

marketplace while still protecting 

privacy and incorporating appropriate 

security controls. 

A. Consumer Narratives 

The Bureau plans to provide 

consumers who submit their complaints 

directly to the Bureau the opportunity to 

share their individual stories with other 

consumers and the marketplace by 

including consumer complaint 

narratives in the Consumer Complaint 

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Federal Register / Vol. 80, No. 56 / Tuesday, March 24, 2015 / Notices 15583 

32 45 CFR 164.514. 

Database where consent for publication 

is first obtained from the consumer. 

Only those narratives for which opt-in 

consumer consent is obtained and a 

robust personal information scrubbing 

standard and methodology is applied 

will be eligible for disclosure. 

B. Consumer Consent To Disclose 

Narratives 

The Bureau intends to disclose only 

narratives for which informed consent 

has been obtained and that have been 

scrubbed for personal information. To 

obtain informed consumer consent, the 

Bureau plans to give consumers who 

submit a complaint the opportunity to 

check a consent box, with 

accompanying language that will state, 

among other things, and in plain 

language, that: (1) Whether or not 

consent is given will not otherwise 

impact how the Bureau handles the 

complaint; (2) if given, the consumer 

may thereafter inform the Bureau that 

the consumer withdraws consent at any 

time and the narrative will be removed 

from the Consumer Complaint Database; 

and (3) the Bureau will take reasonable 

steps to remove personal information 

from the complaint to address risk of reidentification. 

C. Personal Information Scrubbing 

Standard and Methodology 

Sharing data containing personal 

information presents a tension between 

data utility and individual privacy. As 

a particular personal information 

scrubbing standard becomes more or 

less stringent, the utility of a given deidentified dataset may become 

respectively less or more useful. 

Within its judgment and discretion, 

and in order to address the risk of reidentification, the Bureau intends to 

apply to all publicly-disclosed 

narratives a robust personal information 

scrubbing standard and methodology. In 

designing its scrubbing standard, the 

Bureau relied heavily on guidance by 

the Department of Health and Human 

Services regarding de-identification of 

health data, as outlined in the Health 

Insurance Portability and 

Accountability Act (‘‘HIPAA’’) Privacy 

Rule.32 The Bureau’s current scrubbing 

standard is modeled after the HIPAA 

Safe Harbor Method, which is generally 

considered to represent a best practice 

for de-identifying data. In addition to 

adopting (and removing) most of the 

specific HIPAA identifiers, the Bureau 

also plans to remove: (1) Demographic 

information such as gender, age, race, 

and ethnicity; (2) appropriate analogues 

to HIPAA identifiers in the consumer 

financial domain, e.g., credit card 

numbers; and (3) identifiers which the 

Bureau knows appear in complaints and 

could reasonably be used to identify 

individuals, e.g., personal information 

pertaining to third parties other than the 

company that is the subject of the 

complaint. All consumer complaint data 

shared via the Consumer Complaint 

Database will be subject to this standard 

and methodology, including, e.g., ZIP 

code. The Bureau plans to make this 

scrubbing standard available on the 

Bureau’s Web site. The scrubbing 

methodology contemplates a computerbased automated step and a quality 

assurance step or steps performed by 

human reviewers. 

D. Company Response 

The Bureau plans to give companies 

the opportunity to respond publicly to 

the substance of the consumer 

complaints they receive from the 

Bureau. Within the secure web portal 

companies use to respond to 

complaints, the Bureau intends to add a 

set list of structured company response 

options; a responding company will be 

given an opportunity to recommend to 

the Bureau which option, if any, it 

would like included as a public-facing 

response to address the substance of the 

consumer’s complaint. Companies will 

be under no obligation to avail 

themselves of this opportunity. 

E. Continuous Improvement 

The Bureau plans to implement a 

testing and continuous improvement 

process to ensure that as applied, the 

Bureau’s standard and methodology for 

scrubbing personal information 

adequately protects consumers. The 

Bureau intends to continue to adjust its 

scrubbing standard and methodology, 

guided by the goal of simultaneously 

maximizing data utility and individual 

privacy. 

VI. Effect of Policy Statement 

This Policy Statement is intended to 

provide information regarding the 

Bureau’s plans to exercise its discretion 

to publicly disclose certain data derived 

from consumer complaints. The Policy 

Statement does not impose any legal 

obligations on third parties, nor does it 

create or confer any substantive or 

procedural rights on third parties that 

could be enforceable in any 

administrative or civil proceeding. 

Dated: March 12, 2015. 

Richard Cordray, 

Director, Bureau of Consumer Financial 

Protection. 

[FR Doc. 2015–06722 Filed 3–23–15; 8:45 am] 

BILLING CODE 4810–AM–P 

BUREAU OF CONSUMER FINANCIAL 

PROTECTION 

[Docket No. CFPB–2015–0013] 

Request for Information Regarding the 

Consumer Complaint Database 

AGENCY: Consumer Financial Protection 

Bureau. 

ACTION: Notice and request for 

information. 

SUMMARY: The Bureau of Consumer 

Financial Protection (the ‘‘Bureau’’) is 

issuing a Notice and Request for 

Information (‘‘RFI’’) to solicit and 

collect input from the public on the 

potential collection and sharing of 

consumer compliments about providers 

of consumer financial products and 

services and more information about a 

company’s complaint handling. 

DATES: Submit comments on or before 

May 26, 2015. 

ADDRESSES: You may submit responsive 

information and other comments, 

identified by Docket No. CFPB–2015– 

0013, by any of the following methods: 

• Electronic: http:// 

www.regulations.gov. Follow the 

instructions for submitting comments. 

• Mail: Monica Jackson, Office of the 

Executive Secretary, Consumer 

Financial Protection Bureau, 1700 G 

Street NW., Washington, DC 20552. 

• Hand Delivery/Courier: Monica 

Jackson, Office of the Executive 

Secretary, Consumer Financial 

Protection Bureau, 1275 First Street NE., 

Washington, DC 20002. 

Instructions: The Bureau encourages 

the early submission of comments. All 

submissions must include the document 

title and docket number. Because paper 

mail in the Washington, DC area and at 

the Bureau is subject to delay, 

commenters are encouraged to submit 

comments electronically. In general, all 

comments received will be posted 

without change to http:// 

www.regulations.gov. In addition, 

comments will be available for public 

inspection and copying at 1275 First 

Street NE., Washington, DC 20002, on 

official business days between the hours 

of 10 a.m. and 5 p.m. Eastern Time. You 

can make an appointment to inspect the 

documents by telephoning (202) 435– 

7275. 

All submissions, including 

attachments and other supporting 

materials, will become part of the public 

record and subject to public disclosure. 

Sensitive personal information, such as 

account numbers or Social Security 

numbers, should not be included. 

Submissions will not be edited to 

remove any identifying or contact 

information. 

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