Along with recommendations on how to alter the nine standard responses the agency plans to embed, the American Financial Services Association shared four more potential finance company replies that would be integrated within the Consumer Financial Protection Bureau public compliant database.

In a letter to CFPB director Richard Cordray, AFSA executive vice president Bill Himpler maintained the association’s concerns with the bureau’s policy how it plans to disclose publicly unstructured and unverified consumer complaint narrative data via its Web-based, public-facing database. The policy states that companies have set responses that they can select from when responding publicly to narratives that the consumer has chosen to publish. The policy also states that the CFPB will not notify companies when a consumer has chosen to make a complaint public.

Although it is a final policy statement, AFSA pointed out the CFPB stated that it was open to feedback and would consider making changes.

Along with the nine responses the CFPB plans to allow, Himpler mentioned four other ones that could help finance companies, including:

— After completing a thorough investigation, the company has determined that the complaint is without merit.

— After completing a thorough investigation, the company has determined that the consumer who submitted the complaint is not a customer of the company.

— The company contacted the customer and resolved the matter privately.

— The company is unable to conclude the investigation because the customer has not responded to the company’s communication attempts.

Himpler closed his four-page letter to Cordray by reiterating the CFPB’s consumer database is “impracticable and unworkable” for four reasons, including:

— It does not adequately protect consumers’ privacy.

— Publicizing unvalidated and unverified consumer narratives will not be beneficial to consumer choices.

— Publishing both the consumer narrative and the company’s response will unfortunately have a chilling effect on communication between the two parties.

— It does not address the unjustified and significant brand and reputational risk to financial services companies.

“It is our understanding that it is not the CFPB’s intention to unfairly damage or hurt the reputation of financial service companies by publishing the consumer narratives,” Himpler said. “The CFPB’s goal, as we understood it from the very beginning, was to create a communication channel between all parties that would provide a fair and unbiased platform in resolving issues between the concerned parties.

“The CFPB states that other government websites include databases with narratives that have helped inform consumers about a range of products,” he continued. “However, those comparisons are not valid. Information about a consumer’s experience with a financial product or service is covered by a number of privacy restrictions. These restrictions do not apply to consumer narratives about other products.”

Himpler’s entire letter can be downloaded here.