The CFPB will now give consumers submitting complaints the ability to make their complaint narratives public (more information available here: CFPB's Final Policy Statement). What impact will this have on banks that are not directly regulated by the CFPB? I assume complaints will be forwarded to the other regulators as usual, but have not found much clarification on the handling of the narratives.

I've received some feedback from the OCC and FDIC. At this point, both are assuming the CFPB's new policy is limited to CFPB-supervised institutions (those with assets over $10 billion). The CFPB should continue forwarding complaints for smaller institutions to the appropriate regulators. Those regulators have not yet changed their complaint practices, so they should not begin publishing narratives. However, they could always follow the CFPB's lead and adopt similar policies in the future.

In my conversation with a Bureau spokesman, I was told the Bureau won't be publishing narratives for complaints that are bucked to other agencies.

Good news for the "little guys."

So would you say it would still behoove a bank not regulated by the CFPB to make mention of the new policy in their complaint policy?

Not unless the Bureau changes its practice.

Thank you