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From Banking and Finance Law Daily, September 16, 2015

OIG has its own complaints about CFPB Consumer Complaint Database

By Katalina M. Bianco, J.D.

The Office of Inspector General for the Consumer Financial Protection Bureau and Federal Reserve Board has published the results of an audit of the bureau’s Consumer Complaint Database. The audit objective was to assess the effectiveness of the CFPB's controls over the accuracy and completeness of the Consumer Complaint Database. According to the report, the OIG determined that there were areas in which management controls should be improved to enhance accuracy and efficiency.

The audit covered CFPB processes from the period of Jan. 1, 2014, through June 30, 2014, and included all complaints in the database through June 30, 2014. The database is updated daily with complaint data.

Findings. The OIG reports that the bureau’s Office of Consumer Response (Consumer Response) has implemented controls to monitor the accuracy of complaint data in the internal case management system, which contains all consumer complaints received by the CFPB, but it has not established separate management controls to ensure the accuracy of data extracted from the system and included in the database. The OIG states that it found inaccuracies in its analysis of the complaints in the database, and while the number of complaints with inaccuracies was relatively small, bolstering controls would help ensure that as the number and types of complaints published increase, the overall reliability of the data is maintained.

The OIG also said it found that the CFPB’s Consumer Response:

  • does not review all company closing responses;

  • fails to consistently publish untimely company responses;

  • allows 60 days for consumers to dispute company responses, rather than 30 days as stated in Consumer Response publications; and

  • does not consistently offer consumers the opportunity to dispute untimely company responses.

The OIG also determined that although the website states that the database is updated daily, it is not always refreshed each day, and the bureau does not consistently notify the public when the database is not updated.

Recommendations. To make the database more effective and accurate, the OIG recommends that the CFPB’s Consumer Response, among other things:

  • implement controls to separately assess the accuracy of complaint fields in the database;

  • formally document standards for the data entry of complaints with foreign addresses;

  • develop approaches for monitoring company closing responses to ensure consistency with the response definition;

  • formally clarify the time limit for consumers to dispute company closing responses; and

  • develop and implement a policy that states when the public should be notified of database update failures.

The OIG noted that the CFPB concurs with the recommendations made in its draft report and has begun addressing issues raised in the report. These revisions should be assessed to verify that consumers can dispute untimely complaints and that dispute data are properly published in the database.

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