CFPB Shares Complaints With FTC Consumer Sentinel Database
The Federal Trade Commission (FTC) Consumer Sentinel is an “online database of consumer complaints maintained by the FTC that helps law enforcement track and respond to consumer complaints.” On March 14, 2012, the Consumer Financial Protection Bureau (CFPB) announced that it will be sharing its consumer complaint information contained in the Consumer Sentinel database with other federal and state agencies.
While the CFPB states that sharing these complaints will promote transparency and efficiency, the same concerns for financial institutions remain. Who will have access to these complaints and under what terms? Although the FTC asserts that only law enforcement will be permitted access to this information, how broad is that definition? And, even more concerning, is that while the CFPB mandates that financial institutions’ responses to complaints be made under oath, there is no requirement that consumer complaints be made under penalty of law. While the CFPB obviously is working closely with state Attorneys General and the FTC, the CFPB has not yet disclosed the full implications of its sharing of information. Nonetheless, the fact that consumer complaints drive regulatory enforcement efforts when combined with a greater sharing of these complaints likely will have the practical effect of increasing the number and scope of regulatory enforcement actions taken against banks and non-banks.
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