WASHINGTON (7/19/12)--The Consumer Financial Protection Bureau's (CFPB) consumer credit card complaint database and policy statement, unveiled last month, could create privacy risks for credit unions and other financial institutions, the Credit Union National Association (CUNA) reiterated in a comment letter filed on Wednesday.
CUNA raised similar points as the CFPB was developing the consumer complaint database earlier this year.
The CFPB database, which now lists 1749 complaints against financial institutions of at least $10 billion in assets, provides details on the credit card issue that prompted a consumer complaint, the zip code of the consumer that made the complaint, and the company against which the complaint was made. Information on how the complaint was resolved and whether it was resolved in a satisfactory fashion is also included.
The bureau plans to add consumer complaints on other types of financial products to the consumer complaint database.
While credit unions will not likely be the subject of a sizable number of consumer complaints, CUNA said it was still concerned that the public data release could have unintended consequences.
CUNA warned that sensitive or confidential business or consumer information could be inadvertently disclosed when consumer complaints are filed in the database. "The bureau should take steps to minimize privacy risks and other unintended consequences," the CUNA comment letter said.
CUNA also encouraged the CFPB to make any necessary adjustments to the data to minimize potentially misleading implications. "The publicly released data should be adjusted to account for differences among institutions and the product or service at issue, such as the size of the institution, the relative size of the institution's offering of the product or service, and the different types and characteristics of the financial product or service," CUNA said.
The CFPB is planning to include only non-narrative data that does not contain confidential information for complaints on other non-credit card financial products.
CUNA in the letter urged the CFPB to consider the potential benefits of including some limited narrative information in these databases. "For example, it may be helpful to the public to have a better understanding of the substance of the complaint if the consumer's description and institution's written response were included along with the other information regarding the complaint," CUNA wrote.
For the full CUNA comment letter, use the resource link.