NASCUS comments on CFPB’s proposed policy statement on disclosure of consumer complaint narrative data

ARLINGTON, VA (September 23, 2014)  On Monday, the National Association of State Credit Union Supervisors (NASCUS) submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) with regard to its proposed policy statement that would expand the complaint data it publicly discloses in its Consumer Complaint Database to include “unstructured” complaint narratives.

The CFPB, under the proposal, would publish consumer complaint narratives if the consumer provided informed consent, which at any time could be withdrawn. According to the CFPB, companies would also be able to submit a narrative response that would appear next to the consumer’s narrative. All personal information would be removed by the CFPB from both the company’s public response and the complaint narrative.

NASCUS, in its comment letter, noted the significant regulatory burden that drafting these public responses to both types of narratives would create, straining especially the resources of moderately-sized institutions, thus impeding their efforts to identify and correct legitimate problems.

Ultimately, “state credit union regulators believe that the risks and potential complications of including narrative complaint data outweigh the potential benefits of increased complaint filings,” NASCUS stated.

NASCUS pointed out the CFPB’s “Tell Your Story” function on their website, which gathers narrative-type information independently from the complaint process and urged the Bureau to maintain the distinction between these two portals and to focus on improving official complaint data through verification methods and expanded descriptions of the resolutions reached on verified complaints.

To read NASCUS’ comment letter in its entirety, please click here.

The National Association of State Credit Union Supervisors (NASCUS) is the primary resource and voice of the state governmental agencies that charter, regulate and examine the nation’s state-chartered credit unions. NASCUS membership is made up of state-chartered credit unions, state regulators and other supporters of the state credit union system. NASCUS is the only organization dedicated to the defense and promotion of the state credit union charter and the autonomy of state credit union regulatory agencies. To learn more about NASCUS, visit

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