Comment on CFPB-2011-0023-0001

I am quite pleased to see progress around a proactive disclosure of credit card compliant data. Despite the concerns of complaints failing to be representative of the entire marketplace, I do believe collection, public reporting, and synthesizing of information leads to empowering consumers to make well-informed decisions, which should be a paramount concern of a regulatory agency. I am fully supportive of the two goals in this proposed policy statement; first, to make data publicly available from the CFPB regarding consumer complaints and second, to allow the CFPB to publish reports on such data. However, I am disappointed around the current denial of any narrative comments into such public data and reports. In a narrative statement, a consumer can best explain the issue and what the desired change would be. I do look forward to further study around the inclusion of narrative statements. More concerning is that the current proposed policy statement does not include a complete list of what the non-narratives fields are that will be included in the public data. Therefore, this makes assessment of the proposed rule difficult and uninformed. Will the non-narrative questions include the cost of the complaint in terms of company imposed fees or penalties on the consumer; time spent to remedy the issue; the number of occurrences this consumer has had a problem with the issuing company; or a question regarding any litigation status? Without an exhaustive list of non-narrative questions, I do not feel that I am able to fully assess the potential impact of this proposed policy.