I would look to the language in the regulation which is not specific to "complaints" but refers to comments. Does the comment provided to the bank relate to the bank's meeting the community credit needs? If so, then it should be included.
(1) All written comments received from the public for the current year and each of the prior two calendar years that specifically relate to the bank's performance in helping to meet community credit needs, and any response to the comments by the bank, if neither the comments nor the responses contain statements that reflect adversely on the good name or reputation of any persons other than the bank or publication of which would violate specific provisions of law;
Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.