CFPB Consumer Response Clarifies Definition of Duplicate Complaint, and Other Updates

Today the CFPB released an updated version of its Consumer Response Company Portal Manual. The accompanying note explains that the new manual clarifies and updates several items:

The revised portal manual identifies the available “Administrative Response” options for use in situations when, for example, you cannot validate a commercial relationship with the complaining consumer, you believe that the complaint was submitted by an unauthorized third party, or you identify that the complaint is a duplicate of one already received by your company and previously responded to through the portal.
To help you identify and manage “duplicate” complaints, we have clarified the definition of “duplicate” complaint.
We have also updated the text that will display in the Consumer Complaint Database for any “No Public Response” optional company public response submitted after 3/2/2016. The description displayed in the Consumer Complaint Database will now be “Company has responded to the consumer and the CFPB and chooses not to provide a public response”.

On February 23, 2016 the CFPB also posted a note saying that the Consumer Complaint Database was expanded to include two new fields. One indicates whether the consumer consented to publication of their scrubbed complaint narrative. The other provides a tag indicating whether the complaint was submitted by or for a servicemember and/or older American.

Complaints have a tag of ‘servicemember’ if the complaint was submitted by or on behalf of a servicemember, or the spouse or dependent of a servicemember. (Servicemember includes anyone who is active duty, National Guard, or Reservist, as well as anyone who previously served and is a Veteran or retiree.)

Complaints have a tag of ‘older American’ if the complaint was submitted by or on behalf of a consumer who is 62 years or older. Both tags are based on submitters’ selections and go back to when the Bureau began publishing complaints.

Updates in today’s Portal Manual vs. the last edition, dated August 2015:

August 2015 - 4.2 Attachments. Documents related to the complaint as provided by the consumer or by the company for viewing by the consumer.

March 2016 - 4.2 Attachments. Documents related to the complaint as provided by the consumer or by the company for viewing by the consumer and the company. [emphasis added to highlight the change]

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August 2015 - 5.3.6 through 5.3.10 (Alerted CFPB, Incorrect company, Redirected to related company, Duplicate CFPB case reported, Sent to regulator) are listed under Response Categories

March 2016 – These same items are now separated under a broader item 5.4 Administrative response categories, with this introduction:

The responses in this section are provided to the CFPB to categorize complaints when further review by the CFPB may be needed. Complaints that receive appropriate administrative responses are not published in the Consumer Complaint Database.

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August 2015 – 5.3.9 A “duplicate” complaint is one that is a verbatim copy of a complaint to which your company has responded to via the Portal. You must provide the original complaint number in your response.

March 2016 – (now 5.4.4) A “duplicate” complaint is one submitted by or on behalf of the same consumer that that does not describe or include any new issue, instance, or information. You must provide the original complaint number with your response.

insideARM has reported extensively on complaints, and on the CFPB Complaint Portal. Here is a representative group which follows the history: