Experience.com has always tried to build an environment where consumers can write honest reviews of their experiences working with professionals such as mortgage loan officers, real estate agents, insurance agents, lawyers, doctors, or even customer service representatives at hospitality, software, and consumer goods businesses.
What makes reviews valuable is the trust that consumers have in their honesty and integrity. This is why our Review Removal Policy is so strict. Certainly, professionals who take pride in their job are often offended when they get a negative review and want nothing more than to hide, suppress, delete, or remove these reviews from their profile.
Any user of Experience.com who has flagged a review for removal is likely to have received a notification that the flagged review has been restored because it does not meet the guidelines we have established.
Some of our clients have been using our API to ingest the review data and then filter out reviews below a certain score and only display the highest score reviews on their website. Previously we have educated our clients that since our profile pages contain all reviews and our widgets mirror that; using the API to curate the reviews that the client wants to display on their website is encouraged.
Until recently, that has been our stance. But, on March 22, 2022 Rohit Chopra, Director of the Consumer Finance Protection Bureau, issued CFPB Bulletin 2022-5. The title of the Bulletin is “Unfair and Deceptive Acts or Practices That Impede Consumer Reviews”.
There are 3 main points in the bulletin:
- Deceiving Consumers Who Wish to Leave Consumer Reviews
- Unfairly Depriving Consumers of Information Using Restrictions on Consumer Reviews
- Deceiving Consumers Who Read Reviews About the Nature of Those Reviews
While it would be helpful for all clients of Experience.com to be familiar with the first 2 points, we do not believe our clients are attempting to limit the ability of consumers to write reviews. On the contrary, by virtue of the fact that you are clients of Experience.com; you are making it as easy as possible for consumers to leave feedback on Experience.com as well as other sites such as Google Business Profiles, Zillow, Lendingtree, BBB, etc.
The purpose of this article is to discuss point #3, Deceiving those who read reviews about the nature of those reviews.
When a consumer visits an Experience.com public profile page (example: Cathy Larson, Go Mortgage) we have been careful to include ALL of Cathy’s reviews. We naturally display these in date order (with the exception of up to 3 reviews that can be pinned to the top). Through our integration with Zillow, we are able to import her Zillow reviews as well. We also have integrations with Facebook and Google to import more reviews. We label reviews as Verified when the survey was completed by a consumer who was sent a survey through a closed-loop integration with Go Mortgage’s system of record (loan origination software). These reviews should carry more weight with consumers that are reading the reviews to justify a decision to work with Cathy.
A consumer visiting this page and eager to know as much as possible about Cathy can sort her reviews from oldest to newest; or lowest score to highest score. They can search by keywords like “first time” or “veteran”. And, if Cathy has replied to any reviews; they can read those replies. We even make it possible for a consumer who has done business with Cathy in the past to write a review about their experience.
Experience.com profile pages are 100% aligned with Executive Director Chopra’s concerns. Our widgets, which many of our customers use to easily display reviews on websites, are also aligned with CFPB’s desire for honesty and transparency. See example.
It is only when our clients have utilized our API to ingest reviews and display them on their website in a curated way do our partners run afoul of CFPB Bulletin 2022-5. Some of our customers will display a long list of reviews, but will not display reviews below 3.5 stars. When a consumer is visiting and sees many review; they would reasonably conclude that this is ALL the reviews from consumers who have conducted business with this professional.
It is deceptive if certain reviews are omitted intentionally and programmatically unless there is either a link that says “click here to see all my reviews” or the reviews are properly labeled “check out what some of my happy customers are saying”.
Experience.com provides the API feed and our customers are certainly entitled to do with the data what they choose. However, we are strongly recommending they analyze their current use of review data on their website and consult with a knowledgeable attorney or mortgage compliance expert to determine what labels or disclaimers should be added to reduce the likelihood that a consumer believes that when they see 334 reviews and the lowest score of those is 4 stars; the consumer will rely on that information and believe that it is a complete picture of the experience they will get.
We are also asking that our clients educate their users to the new emphasis on review integrity being placed by CFPB. Users should be familiar with the Federal Trade Commission, the Consumer Financial Protection Act of 2010, the Consumer Review Fairness Act, and now the CFPB Bulletin 2022-5. In particular, pay attention to the Fashion Nova case mentioned at the bottom of page 8. This is the most relevant.
In the spirit of fairness and integrity and to maintain readers’ trust in reviews, we are strictly adhering to our Review Removal Policy and encourage our clients to educate their teams as to why this is in the best interest of all parties.
We remain committed to protecting the mortgage industry’s best interests and will uphold this responsibility through our Review Removal Policy. As an honest and data driven experience management platform, we strive to provide exceptional experiences for consumers who have left reviews as well as those who have been reviewed. Our Review Removal Policy has and will always evolve according to the current stance of the CFPB, FTC and other regulating bodies. The integrity of each review remains important to the success of our platform and to our loyal customers who also hold regulation in high regard.