CFPB Amends Complaint Manual; Banks Will Be Subject to Public Complaints on Credit Cards


The Consumer Financial Protection Bureau (CFPB), which has been taking complaints from consumers over its internet page, has updated its Complaint Systems Manual. The manual addresses how institutions should handle complaints received from consumers on credit cards and mortgages. (The CFPB plans on expanding the range of products about which consumers may complain.) In addition to more detail, the updated manual now allows an institution 15 days instead of 10 within which to give an initial response to a complaint, although the CFPB made it clear that this expected timeframe would not supersede any laws that require an earlier response. The CFPB also indicated it would be more likely to take enforcement action if an institution did not respond within 30 days of receiving the complaint, or if a response was "in progress' for more than 60 days.

Due to the business risk that the complaint process raises for non-compliant institutions, we are reprinting the proposed text of the "Policy Statement" that the CFPB issued last month for comment. The text of the proposed Policy Statement is as follows:

Purposes of Credit Card Complaint Data Disclosure

The CFPB receives credit card complaints from consumers. The CFPB intends to disclose certain information about credit card complaints in a public database and in the CFPB’s own periodic reports. The purpose of this disclosure is to provide consumers with timely and understandable information about credit cards and to improve the functioning of the credit card market. By enabling more informed decisions about credit card use, the CFPB intends for its complaint data disclosures to improve the transparency and efficiency of the credit card market.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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