American Financial Services Association general counsel Philip Bohi sent a letter this week to Consumer Financial Protection Bureau acting director Russell Vought, addressing an information request from the regulator about its consumer response intake form.

AFSA said the CFPB made some “important” changes in February to the consumer complaint portal to reduce the volume of credit reporting disputes submitted to the bureau.

Under the Fair Credit Reporting Act (FCRA), the association explained that disputes about credit reporting are to be submitted to the furnisher of credit reporting information, or to the consumer reporting agency.

In past years, AFSA said, there has been an exponential increase in credit reporting disputes being submitted to the CFPB complaint portal.

“AFSA members report receiving illegitimate complaints, including complaints from people who are not actually customers of the financial institution receiving the complaint,” Bohi wrote to the CFPB. “There are reports of consumer complaints stating that due to illness, the consumer would like the account closed and removed from the consumer’s credit file. These are inquiries at best rather than legitimate complaints.

“The problem relating to credit disputes is particularly acute,” Bohi continued in his letter. “Over the past several years, industry has observed a proliferation of formal (credit repair organizations) and informal (social media) misinformation telling consumers how to clean or repair their credit histories in order to increase their credit scores.

“Some of these encourage consumers to file form complaints that are effectively credit disputes on the CFPB complaint portal, which is contrary to the provisions of the FCRA. The FCRA provides that credit disputes are to be initiated by the consumer communicating with a consumer reporting agency or the furnishing creditor directly.”

Bohi then articulated eight steps the CFPB should consider to improve the quality of the information in the consumer complaint portal, including:

—Use technology to screen for repetitive complaints. Reject complaints that contain the same information as prior complaints, including template complaints that do not contain adequate customer or account information to be actionable.

—Use technology to screen complaints for actual allegations of harm rather than vague assertions of dissatisfaction.

—Require consumers filing complaints to confirm their identity when filing a complaint.

—Require consumers filing complaints to offer documentary evidence that they have a relationship with the entity about which they are filing a complaint.

—Investigate other means to reduce the number of negligent or intentional misrepresentations in submissions to the CFPB complaint portal.

—Allow companies to make corrections to inaccurate consumer-input data, such as product type, complaint issue, or sub-issue.

—Introduce a mechanism for companies to quickly close frivolous complaints.

—Provide financial institutions with feedback regarding the resolution of complaints.

“While the complaint portal includes a mechanism to designate duplicate complaints, repeat filings are sometimes submitted with minor modifications that prevent effective duplicate classification,” Bohi told the CFPB.

“AFSA recommends that the bureau explore enhancements to its repeat-filer detection protocols to ensure that materially duplicative complaints are identified and consolidated. This would support administrative efficiency while preserving consumers’ ability to raise legitimate concerns,” Bohi said.