ETA Submits Comments to the CFPB Regarding its Public Reporting Practices of Consumer Complaint Information

The Electronic Transactions Association (“ETA”) submits these comments in response to the Consumer Financial Protection Bureau (“CFPB”) Request for Information (“RFI”) Regarding Bureau Public Reporting Practices of Consumer Complaint Information.

ETA is the leading trade association for the payments industry, representing over 500 companies that offer electronic transaction processing products and services. ETA’s members include financial institutions, mobile payment service providers, mobile wallet providers, and non-bank online lenders that make commercial loans, primarily to small businesses, either directly or in partnership with other lenders. ETA member companies are creating innovative offerings in financial services, revolutionizing the way commerce is conducted with safe, convenient, and rewarding payment solutions and lending alternatives.

As noted in the RFI, the Bureau is tasked with “collecting, investigating, and responding to consumer complaints.”1 ETA agrees there are significant consumer, public policy, and other benefits associated with the Bureau’s role in addressing consumer complaints. However, while consumer complaints are an important source of information for the Bureau, there are a variety of risks in making the complaints available publicly. For example, the complaint data are often incomplete, unrepresentative, and unverified. Moreover, only companies that have registered with the Bureau, and adhere to the Bureau’s complaint response procedures, are incorporated into the consumer complaint process; companies that are not registered deal with direct consumer complaints. As a result, and given a lack of greater overall context, consumer complaints made to the Bureau can be an unreliable and misleading source of information. This harms industry stakeholders, and confuses consumers.

Read the full comments here.