The CFPB has announced the creation of the “Repeat Offenders Against Military Database” (ROAM) to collect information on enforcement actions taken by federal and state officials against perpetrators of financial scams against the military community. According to the CFPB, ROAM is “the first database of its kind” and represents a joint effort with State Attorneys General and the Department of Defense. The CFPB’s announcement includes a letter from the Attorneys General of Kansas and Kentucky (who co-chair the Consumer Protection Committee of the National Association of Attorneys General) to AGs around the country to encourage them “to send copies of the complaints and final judgments, or case names and docket numbers” to ROAM. According to the letter, the CFPB “will build the database incrementally, beginning with the collection of publicly available data.” This statement suggests the CFPB and AGs expect ROAM to eventually include non-public information shared by enforcement authorities.
Could ROAM be a prototype for one or more similar databases that will collect information about enforcement actions against companies in specific industries such as payday or student loan lenders? That seems consistent with how the CFPB has approached its complaint portal–which began with credit card complaints only but now also takes mortgage loan complaints and is expected to eventually take complaints about other consumer financial products.