American Bankers Association president and chief executive officer Frank Keating recently penned a letter to Consumer Financial Protection Bureau director Richard Cordray offering six improvements as to how institutions can respond to complaints that might be published publicly via the agency’s new database policy.

Keating began his appeal to Cordray by mentioning how his positions came stemming from a conversation the pair had back on March 20. Keating told Cordray that appreciated the bureau’s expression of interest in ways to improve the reliability and accuracy of the information published.

But as a result of gathering feedback from ABA members, Keating articulated these six recommendations, including:

1. The bureau should establish a process for identifying a complaint as “materially inaccurate.”

2. The bureau should add a field to the portal that indicates whether the consumer has opted in to publication of the complaint narrative.

3. The bureau should establish a process for identifying a complaint that was not submitted in good faith.

4. The bureau should adopt a stronger and more conspicuous disclaimer as an additional assurance against consumer misinformation.

5. The bureau should establish a process for a financial institution to identify and block the publication of consumer complaints about matters for which the institution had no responsibility.

6. The bureau should work with industry to normalize and provide context for the data, as has been repeatedly promised by the bureau, but never realized.

“ABA believes that the deficiencies in the current iteration of the Database make it a flawed foundation for further expansion, and we urge the bureau to make the policy and operational changes identified above before proceeding with the publication of unverified and potentially misleading consumer narratives,” Keating said in his letter to Cordray, which can be found here.