So far as I have discovered, only one federal government agency sees the need to include at the top of its website the warning label, “An official website of the United States Government” (preceded by an American flag). The Bureau of Consumer Financial Protection apparently feels that this notice is essential in order to avoid confusion. Presumably readers otherwise might be in doubt. The notice is repeated at the bottom of Bureau webpages.
Also, so far as I can tell, the Bureau is the only Federal Government agency that pays advertising fees to Google to ensure that a search for “consumer bureau” or “consumer protection” brings up a link to the Bureau’s website at the top of the search results page. In fact, it sometimes brings up two Bureau paid-for links. The Bureau is eager to increase traffic to its website. Like healthcare exchanges under the Obamacare law, the Bureau is heralded as a crowning achievement of the Dodd-Frank Act, judging from the Administration’s publicity regarding DFA and what it provides. But what if public interest in the Bureau is low?
Bureau officials have been working on the site’s consumer complaint database to attract visitors. That may render the official USG website label a problem, since the Bureau does not verify the accuracy of the complaint information that it publishes. There is this caution from the Bureau: “We don’t verify all the facts alleged in these complaints, but we take steps to confirm a commercial relationship between the consumer and the company.” O.K., the complainant is a customer, but no assurances about “all the facts alleged” in the complaint. The Bureau replaces caveat emptor with caveat lector, if you are fortunate enough to find the caveat—it is less obvious than the site’s U.S. Government imprimatur. With willful negligence, the Bureau has no qualms about publishing unverified or misleading information, and encourages consumers to learn from it, accurate or not: “Every complaint provides insight into problems that people are experiencing”. Not some, not most, but every complaint offers learning value to consumers, according to the USG consumer protectors.
Potential filers of complaints are told that there are publishing criteria. If the filer is interested in the criteria he can click on a link that takes him to a 32-page policy statement issued by the Bureau in the Federal Register in March 2013. But he does not have to read it in order to have the Bureau publish to the world his complaint narrative.
Again, intended to increase foot traffic to the website, the complaint system as is apparently does not yield results satisfactory to the Bureau. It is proposing to add another bell. The complainant would now be offered the opportunity to rate on a scale of one-to-five the financial firm’s response to its complaint, five being the highest score. Highest of what is not specified. The complainant may also choose to have his rating published to the world.
By the way, the Bureau considers this change to be an exercise under the Paperwork Reduction Act, not a regulatory change subject to the formal rulemaking procedures of the Administrative Procedure Act.
Do not forget that the Bureau is an official agency of the United States Government.