Last month the Consumer Financial Protection Bureau (CFPB) published its final policy statement opening a new online feature on its consumer complaint database. Since 2012, the agency has solicited and collected consumer complaints related to consumer financial products and services pursuant to the authority delegated in the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).

The CFPB collects complaints on credit cards, mortgages, bank accounts, student loans, auto loans, debt collection, money transfers, credit reporting and payday loans.  Nearly 600,000 complaints have been collected to date. Previously, individual complaints had been kept confidential and were published only in aggregate data.  Under the new policy, consumers will be able to opt-in for their complaint narratives to be published publicly. The firms named in these complaints will have little recourse. They are only able to publish a response to the complaint. This policy change has some obvious repercussions on reputation risk. The banking industry lobbied heavily when the complaint database was originally created to ensure that complaints would not be made public.

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