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TCH Comments on CFPB Consumer Inquiry Database Proposal

The Clearing House Association, along with four other trade associations, submitted a comment letter to the CFPB Implementation Team on the proposed establishment of a Consumer Inquiry and Complaint Database. The associations believe that the resolution of consumer concerns is an important and delicate matter, and expressed concerns that (i) the Implementation Team may not promptly refer all consumer complaints or inquiries received by the Implementation Team to existing prudential regulators, which are best equipped to address them, (ii) the breadth of routine uses proposed for the Implementation Team CIC Database will result in consumer inquiry and complaint information disclosures not anticipated or expected by consumers, and (iii) responding to and resolving consumer complaints and inquiries is beyond the scope of Treasury’s statutory authority.