September 22, 2014
Office of the Executive Secretary
Consumer Financial Protection Bureau
1700 G Street NW
Washington, DC 20552
(submitted via regulations.gov)
Re: CFPB-2014-0016, Request for Comment on Disclosure of Consumer Complaint
Dear Ms. Jackson:
Young Invincibles is a national non-profit, non-partisan organization that amplifies the
voices of young adults ages 18 to 34 to expand economic opportunity for our generation. We commend the Consumer Financial Protection Bureau (Bureau or CFPB) for bringing attention to challenges facing consumers. In particular, the Bureau occupies a critical role in addressing poor student loan servicing. We have found that harmful servicing practices by both government and private servicers affects millions of borrowers across the country. CFPB has done a great job providing a space for consumers to log complaints, processing those complaints, and disseminating them through semi-annual reports. As a result, we have encouraged many individuals to file complaints with the Bureau. Borrowers feel a sense of relief when they know that they have a place to turn.
We thank you for the opportunity to comment on the decision to allow borrowers to make their complaints regarding private student loan servicers public. We believe this choice will spotlight poor loan servicing practices to the public ultimately leading to improved servicing quality. The Bureau should expand disclosure to include unstructured consumer complaint narrative data (‘‘narratives’’) for the following reasons:
1) Publically monitoring these complaints improve student loan servicing.
2) Public narratives are integral to the work of consumer advocates.
3) Borrowers themselves have a lot to gain from reading public narratives.