The Consumer Financial Protection Bureau (CFPB) is modifying its complaint database so that consumers can post narratives about their experiences with financial service providers.  According to the CFPB’s release, available at, the purpose of the database enhancement is to help consumers make informed choices and identify market trends.  But the implementation could result in a more harmful than helpful exchange of information due to lack of oversight or the opportunity for providers to meaningfully respond to complaints.  Specifically, the CFPB may not adequately monitor the content posted, and may not have sufficient protections in place to ensure its accuracy.  In addition, providers will have a limited opportunity to respond to complaints and may not be able to dispel falsities or explain why a situation is unique to a particular customer.  Although the provider will be given an opportunity to select a pre-determined “structured response,” that rejoinder may be insufficient to address false notions or information.  Moreover, it is unlikely that complaints will be removed from the database, even if they are remedied.  Given that narratives may begin to be posted as early as June of this year, financial service providers should carefully consider their approach to those database posts.  Depending on the pre-determined response options that are made available by the CFPB, providers may institute policies addressing how and when a response is necessary.  Providers may also consider taking ameliorative action to address concerns raised in the database, including by addressing concerns in their own policies and procedures and customer outreach programs.