December 29, 2016
Ms. Monica Jackson
Office of the Executive Secretary
Consumer Financial Protection Bureau
1275 First Street NE
Washington, DC 20552
Re: Consumer Response Company Response Survey
Docket No. CFPB-2016-0049
On behalf of the National Association of Federal Credit Unions (NAFCU), the only national trade association focusing exclusively on federal issues affecting the nation’s federally insured credit unions, I am writing to you regarding the request for comment on “Consumer Response Company Response Survey.” See 81 Fed. Reg. 85938 (Nov. 29, 2016).
As member-owned institutions, credit unions have a vested interest in providing effective member service and are generally responsive to feedback; however, proposed changes to the Consumer Complaint Database would undercut these efforts. As NAFCU described in detail in its previous letter, the proposed Company Response Survey (the Survey) would cause unnecessary confusion for consumers and inappropriately burden credit unions with substantial reputational risk. The CFPB’s decision to spotlight unverified criticism at the complaint close-out stage only serves to muddy the success of existing complaint resolution programs, which the proposal completely disregards. While NAFCU and our members support the CFPB’s efforts to promote better customer service, the Company Response Survey (the “Survey”) would neither enhance nor facilitate that process.
As discussed in NAFCU’s letter responding to the CFPB’s original Request for Information, insights gained from the Survey would not be particularly useful for credit unions, the vast majority of which already possess channels and procedures for soliciting feedback on complaint resolution. Additionally, NAFCU and our members do not think it would be productive for credit unions to redirect their resources toward defusing potentially disingenuous Survey criticism in addition to managing ratings across myriad social media platforms. Although the Bureau attempts to characterize the Survey as a tool to collect positive experiences, credit unions are perfectly capable of managing their customer relationships without the looming threat of public disclosure of unverified, negative feedback.
If the Bureau values improving customer service, there are alternative means of accomplishing that goal that do not necessitate public disclosure of subjective criticism through the Survey. For example, the Bureau could invite companies to provide their own, private surveys to customers, which would likely yield more specific and helpful insights. As discussed in NAFCU’s previous letter, making the Survey results public might compromise the usefulness of the data and chill what would ideally be an open dialogue between the company and the consumer.
NAFCU is also concerned that the CFPB has failed to address legitimate criticism of the Survey as it moves forward with plans for implementation next year. For example, the expansive wording of certain Survey questions might lead consumers to present new grievances that would otherwise form the basis of a separate complaint. Despite the possibility that consumers may raise new complaints through the Survey, the CFPB has not proposed any plan for handling misdirection of complaint information.
NAFCU asks that the CFPB suspend its plans to implement the Survey until it has studied its potential impact and undertaken a more complete cost benefit analysis utilizing the feedback it has received. NAFCU suggests that such a study take into consideration the efficacy of existing customer service programs operated by financial institutions, what reputational costs might result from the aggregation of unverified, post-complaint criticism, and how the CFPB intends to mitigate potential confusion resulting from the overly-broad nature of the Survey questions.
NAFCU appreciates this opportunity to share our thoughts on how the CFPB can improve the functionality and usefulness of its Database. As the Bureau continues its study of financial institutions’ customer service, NAFCU and our members hope to be a resource for CFPB staff to share our insights and experiences. Should you have any questions or concern, or if you would like to discuss this issue further, please feel free to contact me at amorris@nafcu.org or (703) 842-2266.
Sincerely,
Andrew Morris
Regulatory Affairs Counsel