In a notice published in today’s Federal Register, the CFPB is seeking comments on a proposed addition to the current complaint intake form. The new field would include a survey that consumers may choose to respond to, providing their feedback on the company’s response to their complaint. The consumer would be able to opt-in and provide this feedback publicly, much the way they can with their complaint narrative. The CFPB anticipates that, in addition to providing additional public information for future consumers, the feedback field will enable consumers to “highlight positive company behavior.” Comments must be received on or before September 30, 2016.
The proposed feedback field would replace the existing “dispute” function that currently allows consumers to indicate their dissatisfaction with a company’s response. Instead, consumers will have the option to score the company’s response from 1 to 5 and to provide a narrative description of the rationale for the number they selected.
The ability to emphasize positive outcomes and exceptional customer service have been a major focus of industry commentary throughout the development of the complaint portal, and especially in response to last year’s proposed publication of consumer narratives. (The CFPB adopted the proposal in March 2015 and began publishing narratives in June 2015.) The CFPB’s request for information appears to be an effort to be responsive to industry commentary by allowing for positive, in addition to negative, feedback, and thus ostensibly rewarding companies for being responsive through the Portal. With this latest move, the CFPB is increasingly shaping the Portal to resemble a consumer finance “Yelp”-style rating platform.