BILLING CODE: 4810-AM-P
BUREAU OF CONSUMER FINANCIAL PROTECTION
[Docket No. CFPB-2022-0040]
Request for Information Regarding Relationship Banking and Customer Service
AGENCY: Bureau of Consumer Financial Protection.
ACTION: Request for information.
SUMMARY: The Consumer Financial Protection Bureau (Bureau or CFPB) is seeking
comments from the public related to relationship banking and how consumerscan assert the right
to obtain timely responses to requests for information about their accounts from banks and credit
unions with more than $10 billion in assets, as well as from their affiliates.
DATES: Comments must be received by [INSERT DATE 30 DAYS AFTER DATE OF
PUBLICATION IN THE FEDERAL REGISTER].
ADDRESSES: You may submit comments, identified by Docket No. CFPB-2022-0040, by any
of the following methods:
• Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions f or
submitting comments.
• Email:
RelationshipBankingAndCustomerService@cfpb.gov. Include Docket No. CFPB-
2022-0040 in the subject line of the message.
• Mail/Hand Delivery/Courier: Comment Intake — Relationship Banking, Consumer
Financial Protection Bureau, 1700 G Street, NW, Washington, DC 20552. Please note
that due to circumstances associated with the COVID-19 pandemic, the CFPB
discourages the submission of comments by hand delivery, mail, or courier.
Instructions: The CFPB encourages the early submission of comments. All submissions
should include document title and docket number. Because paper mail in the Washington, DC,
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area and at the CFPB is subject to delay, commenters are encouraged to submit comments
electronically. In general, all comments received will be posted without change to
https://www.regulations.gov. In addition, once the CFPB’s headquarters reopens, comments will
be available for public inspection and copying at 1700 G Street, NW, Washington, DC 20552, on
official business days between the hours of 10 a.m. and 5 p.m. Eastern Time. At that time, you
can make an appointment to inspect the documents by telephoning 202-435-7275.
All comments, including attachments and other supporting materials, will become part of
the public record and subject to public disclosure. Proprietary information or sensitive personal
information, such as account numbers or Social Security numbers, or names of other individuals,
should not be included. Comments will not be edited to remove any identifying or contact
information.
FOR FURTHER INFORMATION CONTACT: Leslie Parrish, Deputy Assistant Director,
Consumer Credit, Payments, and Deposits Markets, or Ted Wegner, Policy Analyst, Office of
Consumer Education, at 202-435-7700. If you require this document in an alternative electronic
format, please contact CFPB_Accessibility@cfpb.gov.
SUPPLEMENTARY INFORMATION:
I. Background
Under section 1034(c) of the Consumer Financial Protection Act (CFPA), consumers have
a legal right to obtain information from the approximately 175 largest banks and credit unions in
the country with more than $10 billion in assets, as well as from their affiliates.
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Through this
statutory authority, consumers are able to gain valuable insight into their accounts by requesting
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“A covered person subject to supervision and primary enforcement by the Bureau pursuant to section 1025 shall, in a
timely manner, comply with a consumer request for information in the control or possession of such covered person
concerning the consumer financial product or service that the consumer obtainedfrom such covered person, including
supporting written documentation, concerning the account of the consumer.” 12 U.S.C. 5534(c)(1). There are certain
exceptions. See 12 U.S.C. 5534(c)(2); CFPB Depository Institutions(Dec. 2021),
https://files.consumerfinance.gov/f/documents/cfpb_depository-institutions-list_2021-12.pdf.
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certain account information from their depository institution.
In the modern banking environment, consumers reasonably expect financial institutions to
provide responses to their requests for information and high levels of customer service. Some
banks may not be offering the baseline level of customer service that consumers reasonably
expect to receive from companies that have control over their money.
Relationship banking is an aspirational model of banking that meets its customers’ needs
through strong customer service, responsiveness, and care. Relationship banking can play a
critical role in helping to foster fair, transparent, and competitive marketplaces.
The CFPB endeavors to help institutions of all sizes foster an inclusive relationship
banking model that meets consumers’ reasonable expectations of high levels of customer service
and enables consumers to hold financial institutions accountable when they encounter problems.
This model is especially critical during a time when consumers report wanting and valuing high-
quality human interactions in their financial lives, as well as more helpful digital channels to
better facilitate self-help.
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Increasing market concentration in the financial services industry may present challenges
in implementing an inclusive relationship banking model.
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The number of banking institutions
has decreased “from nearly 18,000 in 1984 to fewer than 5,000 in 2021.”
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Bank consolidation
has had mixed results for consumers and customer service experiences.
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2
The Human + Digital Challenge in Banking: Consumers Want Both, Cornerstone Advisors (2021),
https://go.backbase.com/rs/987-MGR-655/images/Backbase_Cornerstone_Human_Digital.pdf.
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Best & Worst Banks According to Consumer Reports Members: Smaller institutions get higher ratings in our latest
survey of more than 72,000 members, Consumer Reports (Mar. 23, 2018),
https://www.consumerreports.org/banks/best-and-worst-banks-and-credit-unions-a5170659592/.
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The Great Consolidation of Banks and Acceleration of Branch Closures Across America, Na tional Community
Reinvestment Coalition (Feb. 16, 2022),https://ncrc.org/the-great-consolidation-of-banks-and-acceleration-of-branch-
closures-a cro ss-america/.
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U.S. Retail Banks Struggle to Differentiate, Deliver Meaningful Customer Experience as Economy Sours, J.D. Power
Finds, J.D. Power (Apr. 7, 2022),https://www.jdpower.com/business/press-releases/2022-us-retail-banking-
sa tisfaction-study; The Human + Digital Challenge in Banking: Consumers Want Both at 12, 30, Cornerstone Advisors
(2021),https://go.backbase.com/rs/987-MGR-655/images/Backbase_Cornerstone_Human_Digital.pdf (Consumers
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Of particular note is the loss of local banks in rural communities. Rural customers are
more likely to visit smaller banks or credit unions, but f ace decreased banking access due to
“[t]rends in banking consolidation[, which] may be a contributing factor to the prevalence of rural
banking deserts.”
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Rural customers rely on smaller banks and the relationship banking they offer,
with local knowledge and long-standing relationships, to help maintain the “civic fabric of rural
communities.”
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Federal consumer financial law has long been concerned with consumers’ ability to access
information. For example, consumers have the right to send a request for information to their
mortgage servicer in order to obtain information with respect to their mortgage loan.
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In
addition, the Fair Credit Reporting Act gives consumers the right to annually request a free copy
of their consumer report f rom each of the nationwide consumer reporting agencies and mandates
that consumers receive notice when a user of a consumer report takes any adverse actions on a
consumer on the basis, in whole or in part, of information contained in a consumer report.
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The CFPA’s section 1034(c) right also provides an ability for consumers to access
information, as Congress made a determination that consumers need additional rights to demand
information from large depository institutions.
II. Request for Comment
report that it takes too long to get what they need done, that they have to repeat information to multiple sources, that
employees aren’t knowledgeable about their situation, and that it’s difficult to find the information they need online.);
Consumer Response Annual Report a t 30-31, Consumer Fina ncial Protection Bureau (Mar. 2022),
https://files.consumerfinance.gov/f/documents/cfpb_2021-consumer-response-annual-report_2022-03.pdf (The CFPB
received a pproximately 37,400 checking or sa vings a ccount complaints in 2021. Of the complaints where the company
confirmed a commercial relationship with the consumer and responded with an explanation or relief, in 94% of those
complaints, consumers reported that they attempted to resolve their issue with the company before submitting a
complaint to the CFPB, indicating that many consumers are unable to resolve their issues through direct contact with
their bank.).
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Data Spotlight: Challenges in Rural Banking Access a t 9, Consumer Fina ncial Protection Bureau (Apr. 2022),
https://files.consumerfinance.gov/f/documents/cfpb_data-spotlight_challenges-in-rural-banking_2022-04.pdf.
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Id at 10.
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12 CFR 1024.36.
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15 U.S.C. 1681j(a); 15 U.S.C. 1681m(a).
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This request for information seeks information from the public on what customer service
obstacles consumers face in the banking market, and specifically, what information would be
helpful for consumers to obtain from depository institutions pursuant to section 1034(c) of the
CFPA.
The CFPB welcomes the public to submit stories, data, and inf ormation related to this
request. To assist commenters in developing responses, the CFPB has crafted the below
questions that commenters may answer.
1. What types of information do consumers request from their depository institution? How are
consumers using the information?
2. What types of information do consumers request from their depository institution, but are
often unable to obtain?
3. How does the channel (phone, in-writing, online, in-person) through which consumers
request information impact their ability to obtain information?
4. How do consumers’ customer service experiences differ depending on the channel through
which they interact with their depository institution (phone, in-writing, online, in-person)?
5. How are customer service representatives evaluated and compensated, and how might
compensation structure and incentives impact the service provided?
6. What customer service obstacles have consumers experienced that have adversely affected
their ability to bank?
7. What unique customer service obstacles do immigrants, rural communities, or older
consumers experience?
8. What are typical call wait times?
9. How often are calls dropped or disconnected? How often do companies use automated and
digital communication channels such as interactive voice response (IVR) systems and
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online chat functions?
10. Are there any fees associated with customer service or requests for information?
11. What are the most important customer service features or experiences that help produce
satisfactory banking relationships between financial institutions and consumers?
12. Please explain the value of consumers having access to the following information pertaining
to their accounts:
a. Internal or external communications about an account.
b. A listing of all companies that are provided with information about an account.
c. The purposes for which information about a consumer’s account are shared.
d. Any compensation that a depository institution receives for sharing information
about an account.
e. Any conditions placed on the use of information about an account.
f. A listing of all companies with authorization to receive automatic or reoccurring
payments from an account.
g. Information reviewed or used in investigating a consumer’s dispute about an
account.
h. Any third-party information used to make account decisions about consumers,
including but not limited to consumer reports and credit or other risk scores.
13. What information would be helpful f or consumers to obtain from depository institutions in
order to improve their banking experience?
14. How have methods of customer engagement changed as a result of the COVID-19
pandemic?
/s/ Rohit Chopra
Rohit Chopra,
Director, Consumer Financial Protection Bureau.
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