If you’ve heard about the CFPB’s new rating system and wondered whether it will become a reality, in my opinion the answer is – yes -- I see no possible way they wouldn’t have built their rating system into the upcoming release of the consumer complaint portal. 

The new system allows the complainant to select a 1 to 5 rating, and also type a short narrative.  My analysis of the public statements and FOIA materials indicates the following conditions will exist before a complainant has the option to provide a rating and narrative:

  1. The complaint was entered through an existing CFPB input channel
    1. Web
    2. Phone
    3. Mail
    4. Fax
    5. Referral
  2. The complaint was successfully routed to a company participating (registered) on the portal (e.g. Banks > $10-billion)
  3. The company provided a response through their secure “Company Portal”
  4. The consumer visits their “Consumer” portal, calls the call center, or uses any current dispute method
  5. The consumer provides a rating and narrative, and also consents to them being shared

Once met, these conditions seem to satisfy the CFPB enough to provide this information publicly.  Rather than the benign “dispute,” left purposefully undefined, we may have a somewhat Yelpish future.  We love Yelp, but Yelp themselves are the only ones who can “do” Yelp.   

What could prevent this rating system from happening?

  1. Analysis of the public comments about the proposed system were overwhelmingly negative about the concept
  2. CFPB’s cranky new neighbor finds a way to stop it

Please reach out with any questions or concerns; It will be important to understand this new system and its ramifications – early.

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