The National Association of Federal Credit Unions (NAFCU) has offered a series of operational suggestions to the Bureau of Consumer Financial Protection, as the Bureau reviews its data collection practices.
NAFCU officials included scaling back existing data collections, limiting access to personally identifiable information (PII) and reconsidering which data are made public, among its listed suggestions, noting the feedback followed was following a request for information also including a report on data sources and uses.
“NAFCU appreciates the opportunity to comment on the Bureau’s request for information regarding data collections,” Andrew Morris, NAFCU senior counsel for Research and Policy, wrote in correspondence to the Bureau. “As the Bureau contemplates potential changes to the policies and procedures governing its data intake operations, it should seek to limit data collection activities that elevate risks to credit union member privacy or create reputational risks for credit unions.”
Morris noted while the Bureau must work towards addressing data security issues identified by the Office of Inspector General (OIG) as quickly as possible, the NAFCU commends the Bureau for its transparency regarding its current data handling processes.
“NAFCU urges the Bureau to re-evaluate agency policies governing the collection and publication of consumer complaint information received through the Consumer Complaint Database (Database),” Morris wrote. “As member-owned institutions, credit unions have a paramount interest in resolving their members’ issues efficiently, effectively, and in a manner that preserves confidentiality; however, successful complaint resolution programs are undermined when the Bureau publishes unverified narratives that often take the form of subjective criticism.”
He added the NAFCU supports the Bureau’s efforts to ensure markets for consumer financial products and services operate transparently and efficiently, but the publication of unverified complaint data frustrates that goal.