I am delighted to be writing my first blog post for the CFPB Monitor as a new member of Ballard Spahr’s Consumer Financial Services Group.  Before joining the Group, I served as an investigator in the CFPB’s Consumer Response Division which is responsible for maintaining the CFPB’s Consumer Complaint Database.

In a new report on internal controls governing accuracy in the Database, the Office of Inspector General (OIG) for the Federal Reserve found a number of ways that the CFPB’s management of the Database could be improved.  The OIG recommended a number of changes to policies and data controls, including increased monitoring of company responses, improved transparency of procedures for consumers filing disputes and companies filing late responses and a number of mechanisms for ensuring accurate uploading of information to the Database.  The study made particular note of the potential for consumer and industry confusion where there is a disconnect between Consumer Response’s public guidance and its internal procedures.  However, much of the study was conducted prior to substantial changes in the management of the Database, with many changes having since been implemented.

In a letter accompanying the report, the Acting Assistant Director of Consumer Response agreed with the OIG’s recommendations and noted that major changes in technology and procedure have been made and are ongoing.

The OIG report draws attention to the efforts being undertaken by Consumer Response to manage the growing volume of complaints, which have nearly tripled since the study was conducted. Industry can expect an increased focus on the quality of responses to consumer complaints, the handling of untimely company responses, and the breadth of information released through the Database.  The addition of consumer narratives may also present additional challenges that were outside the scope of the OIG’s review.

On November 17, 2015, I will be participating in a webinar with other Ballard Spahr attorneys, “Coping with Consumer Complaints and CFPB Expectations,” from 12:00-1:00 p.m. ET.  The registration form is available here.