Letters to Regulators: Advocate Letter Urging CFPB Not to Hide Complaint Narratives

View or download pdf of the letter and the referenced attachment.

Director Kathleen Kraninger
Consumer Financial Protection Bureau
1700 G St. N.W.
Washington, D.C. 20552

Re: Hidden Narratives in the CFPB Consumer Complaint Database

August 11, 2020

Dear Director Kraninger:

The undersigned consumer, civil rights, community, housing and privacy organizations are
grateful for the Consumer Financial Protection Bureau’s (CFPB) September 2019 decision
to maintain public access to the Bureau’s Consumer Complaint database and to continue to
publish the complaint narratives—the core of the complaint.

However, we are compelled to urge you to reconsider your decision to bury the narratives,
making it much harder for non-experts to find this essential element.

After much consideration, analysis and internal debate in 2015, the Consumer Bureau
decided to add the narrative field to the information it publishes in its public complaint
database, with each consumer’s permission.The complaint narratives give consumers a
window into what the actual unresolved problems are between a consumer and a financial
firm. The narrative often expresses the crux of the ongoing dispute and can help both the
Bureau and individuals begin to detect patterns of unfair, deceptive, even abusive behavior.

Access to the complaint narratives helps to educate and empower consumers to make wise
financial decisions and meets the Bureau’s mandate to inform and protect consumers. The
complaint details description of “what happened” can help to prevent future problems by
warning individuals in advance of others’ unresolved disputes with companies that the
Bureau is responsible for overseeing. Public access to this critical information also helps to
hold companies accountable for their behavior in the financial marketplace.

We are well aware of some industry representatives’ vehement opposition to the public’s
access to this valuable information. To that end, the Bureau has accommodated their
concerns by adding disclaimers and prioritizing information that warns consumers that the
complaints listed “are not necessarily representative of all consumers experiences” and are
not contextualized.

While the Bureau has generally improved the ease of use of the database and has added
helpful features (e.g., Trends view), in an effort to appease business fears, several changes
are very concerning.

First, the home page no longer includes a “Browse public complaints about companies”
direct link to the database (Attachment, Figure 2).

No longer can a consumer find a link or the “Read consumer narratives” box that was
previously available (Attachment, Figure 3) to access this important information.

Instead these critical complaint details are hidden from view. They are no longer
mentioned as a source of information in website copy. In the rare instance where complaint
narratives are noted, they are raised without adequate explanation and only to devalue
them. Further, some of us have found that Bureau staffers no longer explain the narrative
field when the complaint database is discussed.

Consumers new to this tool would never know they could access this crucial information.
Without a direct link on the home page, individuals seeking complaint data would first have
to locate the database under the home page’s Data and Research tab. They would then
have to click on the View complaint data box.

Then consumers would have to somehow glean that they could uncover complaint
narratives by selecting “List view” (the default is “Map view”). Only in “List view” can
consumers locate actual complaints. Finally, they would have to scroll down the left menu
to nearly the end of all filter options and click on “Only show complaints with
narratives”—but this assumes that all users understood that “narratives” contain the
essential “what happened” details of the complaint.

The complaint database search page, as it appeared as recently as January 6, 2020,5 offered
the “Only show complaints with narratives” option as the very top filter selector
(Attachment, Figure 1.) This was a far superior way to inform consumers about the
narrative field.

The decision to bury complaint narratives was a clever attempt at balancing financial and
consumer interests but this effort has bent too far in one direction, weakening the value of
this complaint tool and making it far less meaningful for those who you have committed to
serve—the consumer.

We urge the Bureau to reinstate the “Read consumer narratives” button to the database
landing page to vastly improve transparency (Attachment , Figure 3). We recommend that
the button automatically link consumers to the “List” tab, which would auto-select a reordered, prominent “Only show complaints with narratives” filter.

Thank you for considering our serious concern over these hidden narratives and the simple
solution we propose.


Advocacy for Principled Action in Government
Alaska PIRG
American Federation of Teachers
Americans for Financial Reform Education Fund
Better Markets
California Reinvestment Coalition
Center for Digital Democracy
Center for Economic Integrity
Constitutional Alliance
Consumer Action
Consumer Federation of America
Electronic Information Privacy Center
Empire Justice Center
Montana Organizing Project
Mountain State Justice
National Association of Consumer Advocates
National Association of Consumer Bankruptcy Attorneys
National Community Reinvestment Coalition
National Consumer Law Center (on behalf of its low income clients)
National Fair Housing Alliance
National Housing Law Project
National Housing Resource Center
National Urban League
National Workrights Institute
Northwest Side Housing Center
Privacy Rights Clearinghouse
Public Citizen
SC Appleseed Legal Justice Center
Student Borrower Protection Center
Student Debt Crisis
The Institute for College Access and Success (TICAS)
Virginia Organizing
Woodstock Institute