## 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 3 XXX

- 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 com plaints 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 consu mer 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 for m, 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 fun ctions 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 operatio ns 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 companie s 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 inf ormation (PII) such as bank account numbers and telephone numbers with companies that are the subjects of complaints , it authenticate s company identity through its due diligence process

. By matching company

- provided information with

consumer
- provide d info rmation and comparing relevant data , Consumer Response provides for the secure routing of consumer complaints to the appropriate companies

. Consumers provide c ompany information that helps Consumer Response identify the companies that are the subject of t he ir complaint s 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 consumer

pro vided 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, 20 14, 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 t he increasing volume of complaints r eceived by Consumer Response, a similar form is requir ed to collect neede d 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 th e 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 u nder 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 o f 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 b y enrolling in the Company Portal proa ctively , 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 s ystem 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 informa tion 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, com panies are encouraged to voluntarily provide their logos to help consumers i dentify 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 pos ed to companies’ representatives through collections that will be primarily mail

- in (paper), facsimile, and web

- based. The form of qu estions will include open

- ended and closed

- ended (e.g., multiple choice ) along with free

- form text boxes.



### 3. Use of Info rmation Technology The CFPB has created, and will continue to improve, a system that provides co mpanie s 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 int egrate cutting

- edge technology to make the process efficient and user
- friendly for companies

.


### 5. Efforts to Minimize Burden s on Small Entities Some small businesses and other small entities may be involved in the proposed information collections. For in stance, 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 Ob stacles to Burden Reduction
The collection of complaints from consumers and crafting appropriate agency responses are the primary function s of the CFPB under section 1021(c)(2) of the Dodd

- Frank Act

. 4 The submission of company information by c ompanies and their representatives using the Boarding Form will be voluntary. I f the proposed Boarding Form collection s 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 c ollection 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 Gif ts 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. Assurance s 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 Pri vacy Act (5 U

. S

. C § 552a). 6 A t 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 fil e 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 informa tion 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) 5 0 ,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 a nnualized 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 ; ther efore, 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 t o Congress. In particular, under S ection 1013(b)(3)(c) of the Dodd

- Frank Act , the CFPB provides report s to Congress containing information and analysis about complaint numbers, types,

an d whe re 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 Expirat ion Date The expiration date s 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 INFOR MATION EMPLOYING STA TISTICAL METHODS This information collection does not employ statistical methods. Due to the limitations of the proposed voluntar y 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 re presentations of a larger group, and are not meant to be, statistical methods cannot reduce or improve the accuracy of results.