CONSUMER FINANCIAL PROTECTION BUREAU

INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT

FOR

CFPB’S CONSUMER COMPLAINT INTAKE SYSTEM 

COMPANY PORTAL BOARDING FORM

INFORMATION COLLECTION SYSTEM

(OMB CONTROL NUMBER 3XXX-XXXX)

TERMS OF CLEARANCE: Not applicable. This is a new information collection 

request.

ABSTRACT: The Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law 111-203, Title 

X, provides for CFPB’s consumer complaint handling function. Among other things, the CFPB is to 

facilitate the centralized collection of, monitoring of, and response to complaints concerning consumer 

financial products and services. The support the appropriate routing of complaints to the companies 

that are the subjects of the complaints, the CFPB is developing a form which will allow companies to 

proactively participate in the CFPB’s Company Portal (Company Portal), a secure, web-based interface 

between the CFPB’s Office of Consumer Response (Consumer Response) and companies. The Company 

Portal allows companies to view and respond to complaints submitted through the CFPB’s complaint 

handling system. Many companies have sought to register with the Company Portal before consumer 

complaints have been submitted to the CFPB about their companies to ensure early notice of potential 

complaints and allow companies’ users to acclimate to the software and security protocols needed to 

access the Company Portal. The CFPB’s proposed form, the Company Portal Boarding Form (Boarding 

Form), will serve to streamline information collection from these companies, result in a greatly 

enhanced and efficient experience from both the consumers and companies’ perspectives.
2 | Page CFPB’s Consumer Complaint Intake System Company Boarding Form

INTRODUCTION

The importance of consumer complaints in the work of the Consumer Financial Protection Bureau 

(“CFPB” or “the Bureau”) may be gathered from key passages of the Dodd-Frank Wall Street Reform and 

Consumer Protection Act (“Dodd-Frank Act”) such as the primary functions section: the Bureau’s 

statutory duties include “collecting, investigating, and responding to consumer complaints.”1

 The Office 

of Consumer Response (Consumer Response) is the unit that serves as the consumer complaint and 

inquiry response operations of the Bureau, accepting complaints about credit cards, mortgages, bank 

accounts and services, private student loans and more. 

A secure, web-based platform, called the Company Portal, provides the interface between Consumer 

Response and companies that are the subject of consumer complaints. Consumer Response routes 

complaints to companies through the Company Portal where companies can view and respond to 

complaints. The Company Portal makes consumer complaint handling more efficient than manual 

processing and mailing, and helps protect confidential financial information.

Before Consumer Response shares personally identifiable information (PII) such as bank account 

numbers and telephone numbers with companies that are the subjects of complaints, it authenticates

company identity through its due diligence process. By matching company-provided information with 

consumer-provided information and comparing relevant data, Consumer Response provides for the 

secure routing of consumer complaints to the appropriate companies. Consumers provide company 

information that helps Consumer Response identify the companies that are the subject of their

complaints using a consumer complaint Intake Form, a collection approved by the Office of 

Management and Budget (OMB) pursuant to the Paperwork Reduction Act (PRA).2

 As consumerprovided company information may be limited, Consumer Response further “authenticates” the 

relationship between a consumer and a company that is the subject of the complaint by collecting 

information from the company. This helps ensure a “match.” 

Since beginning to accept complaints on July 21, 2011 through September 1, 2014, the CFPB has handled 

approximately 439,800 consumer complaints. Complaint volume has steadily increased, rising 80% from 

91,000 in 2012 to 163,700 in 2013. With the increasing volume of complaints received by Consumer 

Response, a similar form is required to collect needed information proactively from companies and their 

affiliates, the Company Portal Boarding Form. By collecting information voluntarily from companies who 

are subject to the Bureau’s regulatory authority, Consumer Response will gather the data needed to 

further support a structured, secure, and efficient complaint handling process. 

 1 12 U.S.C. 5511(c).

2 OMB Control No. 3170-0011 (“Consumer Response Intake Form”). Originally approved as a Treasury Department 

form (No. 1505-0241), this Office of Management and Budget (OMB) approved information collection was 

transferred to the Bureau on November 21, 2011. ICR Reference Number 201111-3170-004. Nearly all 

standardized collections of information by a federal agency that involve identical questions posed to, or reporting 

or recordkeeping requirements imposed on, “ten or more persons” must be approved by OMB under the PRA.
3 | Page CFPB’s Consumer Complaint Intake System Company Boarding Form

A. JUSTIFICATION

1. Circumstances Necessitating the Data Collection

Following the receipt of a consumer complaint, Consumer Response verifies the identity of the company 

that is the subject of the complaint prior to sending the complaint to the company. Post-complaint 

submission gathering of information from a company that is specifically named by a complainant in 

order to review the submitted complaint has not presented PRA concerns as a collection of information 

obtained during an agency complaint investigation.3 However, the current approach to collecting 

company information, which is triggered by a consumer complaint submission, does not take into 

account companies who wish to proactively join the Company Portal to facilitate early notice of 

complaint submissions, before any complaint has been submitted against them. These companies 

understand that by enrolling in the Company Portal proactively, they can greatly reduce the time 

required to access and respond to their first consumer complaint because the needed Internet website 

link, software, and security protocols will have already been established. The CFPB’s consumer 

complaint intake system Company Portal Boarding Form (Boarding Form) will serve to streamline 

information collected from respondent companies, resulting in a greatly enhanced and efficient 

consumer experience.

The Company Portal Boarding Form will be used to collect information from companies that will help 

identify the correct company to include organization information, identification of company 

representatives, affiliate relationships, licensure, business identification numbers and consumer market 

presence. Moreover, companies are encouraged to voluntarily provide their logos to help consumers 

identify companies through brand recognition.

2. Use of Information

Information collected from companies completing the Boarding Form will support due diligence 

authentication of company identity, inform complaint processing, and give companies’ users secure web 

portal access to complaint information. The proposed Boarding Form (attached) provides a 

comprehensive list of questions to be posed to companies’ representatives through collections that will 

be primarily mail-in (paper), facsimile, and web-based. The form of questions will include open-ended 

and closed-ended (e.g., multiple choice) along with free-form text boxes. 

3. Use of Information Technology

The CFPB has created, and will continue to improve, a system that provides companies and their 

representatives with the ability to submit their complaints electronically, and give companies’ 

authorized users secure web portal access to complaint information. The CFPB will use enhancements 

such as drop down menus and error checks when possible to minimize burden. 

 3 44 U.S.C. § 3518(c)(2); 5 C.F.R. § 1320.4(b).
4 | Page CFPB’s Consumer Complaint Intake System Company Boarding Form

4. Efforts to Identify Duplication

This information collection request does not seek to duplicate any other form being developed by other 

Federal or State agencies. The information collections proposed will improve the processing of 

individual consumer complaints and inquiries. The CFPB strives to integrate cutting-edge technology to 

make the process efficient and user-friendly for companies. 

5. Efforts to Minimize Burdens on Small Entities

Some small businesses and other small entities may be involved in the proposed information collections. 

For instance, a small business engaging in offering or providing a consumer financial product or service 

or hired by a large financial institution to help process consumer complaints may choose to enroll 

voluntarily in the Company Portal with the idea of future use of the Company Portal to view consumer 

complaints. However, all of the information collections proposed under this request are voluntary and 

are not anticipated to burden small businesses significantly. The CFPB will minimize any burden by 

requesting readily available information and using the easy-to-complete proposed Boarding Form.

6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction

The collection of complaints from consumers and crafting appropriate agency responses are the primary

functions of the CFPB under section 1021(c)(2) of the Dodd-Frank Act.

4

 The submission of company

information by companies and their representatives using the Boarding Form will be voluntary. If the 

proposed Boarding Form collections are not conducted, the CFPB will not be able to maximize the 

efficiency of complaint handling in partnership with proactive companies. The Bureau is directed by the 

Dodd-Frank Act to “establish . . . reasonable procedures to provide a timely response to [consumer

complaints] against, or inquiries concerning” companies.5

 

7. Circumstances Requiring Special Information Collection

There are no special circumstances. The collection of information is conducted in a manner consistent 

with the guidelines in 5 C.F.R. § 1320(5)(d)(2). 

8. Consultation Outside the Agency

In accordance with 5 C.F.R. § 1320.8(d)(1), the Bureau has published a notice in the Federal Register 

allowing the public 60 days to comment on this proposed new collection of information. Further and in 

accordance with 5 CFR § 1320.5(a)(1)(iv), the Bureau will publish a notice in the Federal Register 

allowing the public 30 days to comment on the submission of this information collection request to the 

Office of Management and Budget.

9. Payments or Gifts to Respondents

The proposed information collections do not provide any payment or gift to respondents. 

 4 Codified at 12 U.S.C. § 5511(c)(2).

5 12 U.S.C. § 5534(a).
5 | Page CFPB’s Consumer Complaint Intake System Company Boarding Form

10. Assurances of Confidentiality

All information collection activities will conform to the requirements for the protection of the 

confidentiality of nonpublic information and personally identifiable information and for data security 

and integrity set forth in federal privacy laws, including the CFPB’s rules (12 C.F.R. § 1070 et seq.) and

the Privacy Act (5 U.S.C § 552a).6

 At the point of information collection, individuals will be provided with 

the CFPB’s Privacy Act statement. The CFPB will implement the appropriate security measures to ensure 

data is safeguarded including the use of locked file storage, confidentiality stamping, restricted system 

access, data encryption, restricted print options and disposal by cross-cut shredding.7

 The Company 

Portal system will be fully compliant with the Federal Information Security Management Act of 2002 

with the security category of “Moderate, Moderate, Low.” 

11. Justification for Sensitive Questions

While the proposed Boarding Form seeks to gather commercial information generally available to the 

public, the proposed Boarding Form may request that companies and their representatives provide

sensitive information. For instance, some companies may use social security numbers as primary 

business entity identifiers (e.g., sole proprietorships). While it is likely social security numbers used as 

business identification numbers may be accessed by the public, company representatives’ SSNs will not 

be disclosed and will be held in an encrypted system for their protection.

12. Estimated Burden of Information Collection

Type of Information

Collection

Estimated 

Number of 

Respondents

Average Burden 

Hours per Intake

Estimated Total 

Annual Burden 

Hours 

Requested

Company Portal Boarding 

Form (Paper)

50,000 15 minutes 12,500

Respondents will include companies that are the subjects of consumer complaints and companies that 

are service providers of the companies that are the subjects of consumer complaints.

 6 For the related System of Record Notice (SORN), see https://www.federalregister.gov/articles/2014/04/16/2014-

08555/privacy-act-of-1974-as-amended. 

7 The E-Government Act of 2002, Section 208, establishes the requirement for agencies to conduct privacy impact 

assessments (PIAs) and demonstrate the agencies’ commitment to protect the privacy of any personal information 

collected, stored, retrieved, used and shared. For the PIA related to the Company Portal, see 

http://files.consumerfinance.gov/f/201303_CFPB_PIA-Consumer-Response-System.pdf.
6 | Page CFPB’s Consumer Complaint Intake System Company Boarding Form

13. Estimated Total Annual Cost Burden to Respondents

There will be no annualized capital or start-up costs for the respondents to collect and submit this 

information.

14. Estimated Cost to the Federal Government

Generally, companies will be provided a copy of the form electronically. Costs may be incurred for 

printing and mail distribution of the document for approximately 2,500 companies at a cost of $2.20 per 

document (i.e., 8 pages, copy costs at $0.15 per page, and postage is $1.00), for a total cost of $5,500.

15. Program Changes or Adjustments

This is a new form; therefore, all the burden associated with this information collection request is 

consider a program change.

16. Plans for Tabulation, Statistical Analysis, and Publication

Data collected through the Boarding Form will be analyzed and may be provided in annual reports to be 

issued by the CFPB to Congress. In particular, under Section 1013(b)(3)(c) of the Dodd-Frank Act, the 

CFPB provides reports to Congress containing information and analysis about complaint numbers, types, 

and where applicable, resolution. The CFPB may publish trend reports based on aggregate data in 

summaries, reports, and briefings. Presentations of analyses may include frequency, classification, and 

cross-tabulation across consumer financial products or services, demographic and economic 

characteristics, and financial management behavior. 

17. Display of Expiration Date

The expiration dates for OMB approval will be displayed or otherwise provided to respondents for all 

information collections proposed.

18. Exceptions to the Certification Requirement 

The Bureau certifies that this collection of information is consistent with the requirements of 5 C.F.R.

§ 1320.9, and the related provisions of 5 C.F.R. § 1320.8(b)(3) and is not seeking an exemption to these 

certification requirements.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This information collection does not employ statistical methods. Due to the limitations of the proposed 

voluntary information collections, most importantly the absence of randomized sample selections, the 

responses will not be representative of any larger group. Because any aggregate results of the proposed 

information collections will not be statistically valid representations of a larger group, and are not meant 

to be, statistical methods cannot reduce or improve the accuracy of results.