AFSA Comments on Consumer Complaint Database December 28, 2017 AFSA last week submitted a comment letter on the CFPB’s consumer complaint database highlighting concerns with the privacy and security of consumers’ sensitive information. The CFPB was seeking comment on the consumer response intake form, as well as the consumer complaint system in general. Specifically, the CFPB was asking the Office of Management and Budget (OMB) for approval to test and pilot new questions for the intake form. AFSA’s letter asked that the complaint process be reviewed. The letter stated, “AFSA does not believe that OMB should grant the CFPB’s requests without substantial changes to the complaint process.” While the Dodd-Frank Act requires that the CFPB establish reasonable complaint procedures, it does not require the massive amount of data collection the CFPB has set up, nor the publication of the complaint database. AFSA wrote that it, “… has strong concerns about the CFPB’s ability to ensure consumer privacy and data security as it continues to collect an unprecedented amount of personal data. With any additional data collection or any expansion of the complaint database, the CFPB should address ongoing problems to ensure consumers are protected. Both the Inspector General and CFPB Ombudsman have expressed concerns about the complaint database.” The letter acknowledged that CFPB Acting Director Mick Mulvaney has identified data security concerns at the Bureau and taken the important step of freezing its collection of personal information. “We commend the seriousness with which the director takes data security,” AFSA wrote.