THE CONSUMER FINANCIAL PROTECTION BUREAU’S 

SEMI-ANNUAL REPORT TO CONGRESS 

S. HRG. 113–16 

THE CONSUMER FINANCIAL PROTECTION BUREAU’S SEMI-ANNUAL 

REPORT TO CONGRESS 

HEARING 

BEFORE THE

COMMITTEE ON 

BANKING, HOUSING, AND URBAN AFFAIRS 

UNITED STATES SENATE 

ONE HUNDRED THIRTEENTH CONGRESS 

FIRST SESSION 

ON 

A REVIEW OF THE CFPB SEMI-ANNUAL REPORT TO CONGRESS 

APRIL 23, 2013 

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S. HRG. 113–16 

THE CONSUMER FINANCIAL PROTECTION 

BUREAU’S SEMI-ANNUAL REPORT TO CONGRESS 

HEARING 

BEFORE THE

COMMITTEE ON 

BANKING, HOUSING, AND URBAN AFFAIRS 

UNITED STATES SENATE 

ONE HUNDRED THIRTEENTH CONGRESS 

FIRST SESSION 

ON 

A REVIEW OF THE CFPB SEMI-ANNUAL REPORT TO CONGRESS 

APRIL 23, 2013 

Printed for the use of the Committee on Banking, Housing, and Urban Affairs 

( 

Available at: http://www.fdsys.gov/ 

COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS 

TIM JOHNSON, South Dakota, Chairman 

JACK REED, Rhode Island 

CHARLES E. SCHUMER, New York 

ROBERT MENENDEZ, New Jersey 

SHERROD BROWN, Ohio 

JON TESTER, Montana 

MARK R. WARNER, Virginia 

JEFF MERKLEY, Oregon 

KAY HAGAN, North Carolina 

JOE MANCHIN III, West Virginia 

ELIZABETH WARREN, Massachusetts 

HEIDI HEITKAMP, North Dakota 

MIKE CRAPO, Idaho 

RICHARD C. SHELBY, Alabama 

BOB CORKER, Tennessee 

DAVID VITTER, Louisiana 

MIKE JOHANNS, Nebraska 

PATRICK J. TOOMEY, Pennsylvania 

MARK KIRK, Illinois 

JERRY MORAN, Kansas 

TOM COBURN, Oklahoma 

DEAN HELLER, Nevada 

CHARLES YI, Staff Director 

GREGG RICHARD, Republican Staff Director 

LAURA SWANSON, Deputy Staff Director 

JEANETTE QUICK, Counsel 

GLEN SEARS, Deputy Policy Director 

PHIL RUDD, Legislative Assistant 

JELENA MCWILLIAMS, Republican Senior Counsel 

GREG DEAN, Republican Counsel 

DAWN RATLIFF, Chief Clerk 

KELLY WISMER, Hearing Clerk 

SHELVIN SIMMONS, IT Director 

JIM CROWELL, Editor 

(II)

C O N T E N T S 

TUESDAY, APRIL 23, 2013 

Page 

Opening statement of Chairman Johnson ............................................................. 1 

Opening statements, comments, or prepared statements of: 

Senator Crapo ................................................................................................... 2 

WITNESS 

Richard Cordray, Director, Consumer Financial Protection Bureau ................... 4 

Prepared statement .......................................................................................... 32 

Responses to written questions of: 

Senator Crapo ............................................................................................ 33 

Senator Menendez ..................................................................................... 385 

Senator Hagan ........................................................................................... 390 

Senator Moran ........................................................................................... 392 

Senator Coburn ......................................................................................... 396 

ADDITIONAL MATERIAL SUPPLIED FOR THE RECORD

Semi-Annual Report of the Consumer Financial Protection Bureau .................. 408 

(III)

(1) 

THE CONSUMER FINANCIAL PROTECTION BUREAU’S SEMI-ANNUAL REPORT TO CONGRESS 

TUESDAY, APRIL 23, 2013 

U.S. SENATE, 

COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS, 

Washington, DC. 

The Committee met at 10:03 a.m., in room SD–538, Dirksen Senate Office Building, Hon. Tim Johnson, Chairman of the Committee, presiding. 

OPENING STATEMENT OF CHAIRMAN TIM JOHNSON 

Chairman JOHNSON. Good morning. I call this hearing to order. 

We have reviewed the CFPB’s Semi-Annual Report and are here 

today to conduct regular oversight of the CFPB. This includes making sure that the agency continues to fulfill its mission of protecting consumers and empowering them to make responsible financial decisions, promoting fair competition in industry, and ensuring full access to financial services for all Americans. 

Director Cordray, welcome back to the Committee. I know you 

share my commitment to transparency and accountability. In fact, 

this is the 32nd time that a CFPB official has appeared before Congress in just over 2 years and your 13th appearance. Rightly so, 

your agency’s outreach and engagement with both consumers and 

industry representatives has been widely praised. 

The CFPB has made significant progress in protecting consumers, including students, servicemembers, and older Americans. 

For example, the CFPB has developed a number of tools related to 

student lending, including the ‘‘Financial Aid Shopping Sheet’’, that 

will help students make the best choices as they pursue their 

dreams. 

And since the CFPB opened its doors, it has obtained $425 mil- lion of consumer refunds. That is $425 million back into the hands 

of harmed consumers and back into the economy. 

Earlier this year, the CFPB finalized rules to strengthen mortgage standards. This includes the Ability to Repay provision, which 

requires lenders to make a good-faith effort to determine whether 

a borrower can make his or her payments. These rules have been 

generally well received by consumer and industry groups alike, and 

I applaud the care the CFPB undertook in writing these rules. 

However, we must ensure that these rules do not have adverse impacts on lending in underserved areas, including rural areas. I look 

forward to hearing from Director Cordray on how this rule will imVerDate Nov 24 2008 11:00 Jun 14, 2013 Jkt 048080 PO 00000 Frm 00009 Fmt 6633 Sfmt 6633 L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-A
2 

pact rural lending, which is an important issue for many in South 

Dakota. 

Finally, Director Cordray, you have made comments about reducing regulatory burden on community banks and credit unions. I 

continue to be interested in your plans to make sure that rules 

strike the right balance, protecting consumers while addressing legitimate concerns smaller institutions may have. 

You have proven day in and day out that you are well qualified 

for your position. Even my colleagues across the aisle concede this 

point. I hope we can provide the market the certainty it needs and 

consumers the cop on the beat they deserve by confirming you 

quickly. Thank you for your service, and I look forward to our ongoing work with you. 

With that, I turn to Ranking Member Crapo. 

STATEMENT OF SENATOR MIKE CRAPO 

Senator CRAPO. Thank you, Mr. Chairman, and thank you, Mr. 

Cordray, for being here with us today. I appreciate it. 

Mr. Chairman, this semi-annual briefing by the Consumer Financial Protection Bureau is very important to us to gain insight 

into what the agency is doing. As I have consistently stated in past 

hearings, we still have concerns with the structural nature of the 

agency. We continue to seek a change from the sole directorship to 

a board-like structure. It is also essential that the agency be a part 

of the appropriations process. And, finally, we believe that the prudential banking regulators should have a formal input into the Bureau’s action where those actions affect safety and soundness. 

And with regard to the President’s recess appointment to the 

CFPB last year, my opinion has not changed. I continue to believe 

the recess appointment was unconstitutional. 

Recently, agency officials have pointed out that they have testified more than 30 times before Congress in the past few years. And 

while this does give Congress an opportunity to hear directly from 

agency officials and is appreciated, it does not necessarily facilitate 

the in-depth discussion of the specific issues and concerns that we 

need. 

Just last week, Bloomberg ran a lengthy article citing that the 

CFPB has allocated more than $20 million for collecting and tracking customer credit card and spending habits for more than 10 million Americans. The size of this data collection and the amount of 

money being spent by the agency are a cause of concern for me— 

and should be for those Americans whose credit cards, checking accounts, and other financial data are being sent monthly to the 

CFPB. 

Last month, I specifically asked the agency about this data collection, but the responses I received downplayed the nature and extent of it. 

For example, I asked how many consumer accounts the CFPB is 

monitoring, and the agency declined to provide that information. 

Now we learn from the press that it is 10 million accounts, and 

perhaps even more. 

This lack of candor and transparency of what the agency is doing 

and how it intends to use this personal financial data is troubling. 

3 

The Bureau was founded with a mission to watch out for American 

consumers, not to watch them. 

Given that the CFPB’s Inspector General has already identified 

data security issues at the Bureau, how can the consumer be assured that this information is indeed safe? 

With regard to its regulatory role, in the past 2 years the Bureau 

has issued numerous new rulemakings, resulting in significant cumulative burden for affected institutions, especially our small and 

community banks that often have just a handful of employees. 

In January alone, the Bureau finalized over 2,500 pages of new 

rules relating to mortgages through seven different rulemakings. I 

am concerned that, without strong cost/benefit analysis and input 

from small business panels in crafting rules, even well-intentioned 

rules could make consumer credit more expensive and less affordable. 

That is why at two separate hearings last year I encouraged the 

CFPB to conduct a small business panel on the proposed qualified 

mortgage proposal to try to minimize unintended consequences. 

Many community bankers now warn that, despite limited QM exemptions for smaller institutions, they will no longer offer any 

mortgages outside the QM criteria, which will restrict their ability 

to meet the mortgage needs of the communities they serve. 

Another issue concerning the agency has been identified by the 

agency’s own ombudsman who recommended the CFPB needed to 

review and clarify the role of enforcement attorneys who attend supervisory exams. I look forward to hearing from you, Mr. Cordray, 

about how you plan to address the community bank concerns with 

the QM rules and how the CFPB is implementing the overall ombudsman’s recommendations. 

Specifically, I would like to hear how the Bureau is handling the 

examination concern raised by the ombudsman as well as whether 

the Bureau is concerned about the effect that the sheer presence 

of the enforcement attorneys may have on the integrity of the examination process. 

I firmly believe that if the structure of the agency were changed, 

then it would become more open and transparent, and many of 

these issues would not need to be raised by Members of Congress. 

It is my hope that the Congress will move quickly to address and 

pass these reforms so that the Bureau can do what it was designed 

to do, and that is, to protect the American consumer. 

Thank you, Mr. Chairman. 

Chairman JOHNSON. Thank you, Senator Crapo. 

Are there any other Members who wish to make a brief opening 

statement? 

[No response.] 

Chairman JOHNSON. I want to remind my colleagues that the 

record will be open for the next 7 days for opening statements and 

any other materials you would like to submit. 

Mr. Richard Cordray is Director of the Consumer Financial Protection Bureau. Welcome back to the Committee, Director Cordray. 

You may begin your testimony. 

4 

STATEMENT OF RICHARD CORDRAY, DIRECTOR, CONSUMER 

FINANCIAL PROTECTION BUREAU 

Mr. CORDRAY. Thank you, Mr. Chairman, Ranking Member 

Crapo, and Members of the Committee. Thank you for inviting me 

to testify today about the Semi-Annual Report of the Consumer Financial Protection Bureau. My colleagues and I are always happy 

to testify before the Congress. Ranking Member, I would hope to 

have a chance to address each of the issues you raised in turn. If 

that requires several rounds of questioning, I am happy to do it. 

I think there are good answers to all of those issues that you 

raised. 

Born out of the worst financial crisis since the Great Depression, 

the Consumer Bureau is the Nation’s first Federal agency whose 

sole focus is protecting consumers in the financial marketplace. We 

are dedicated to improving the lives of everyday Americans and to 

restoring trust in consumer financial markets. The Semi-Annual 

Report we are discussing today embodies our work over the last 6 

months of 2012. 

The report illustrates the ways we are using the tools Congress 

has provided us to empower consumers and promote a fair, transparent, and competitive marketplace for consumer finance. We 

have taken steps to improve the workings of markets—particularly 

those in which consumers cannot choose their financial service providers. 

One such market is debt collection. Concerned about systemwide 

problems that pose risks to consumers, we gained authority at the 

beginning of the year to supervise debt collectors. The debt collectors covered by our supervisory authority account for over 60 percent of the industry’s annual receipts in that market. Bad actors 

in this market are a detriment to consumers and to every debt collector that operates lawfully. 

We also expanded our supervision program to include the larger 

credit reporting companies. Credit reports have a profound impact 

on people’s lives. Previously, these companies were not subject to 

any Federal supervision, and consumers often struggled to get errors resolved. In addition to our new supervision program, we 

began handling consumer credit reporting issues, all of which will 

open a clear window into the actual operations of these companies. 

As a result, the Bureau can now evaluate whether Federal consumer laws are being followed throughout the process, from credit 

origination to debt collection. By identifying problems and rooting 

them out early, we are working to try to minimize consumer harm. 

Our report also encompasses the Bureau’s first enforcement actions, which were against credit card companies that deceived and 

misled consumers. In some cases, the companies targeted economically vulnerable consumers with low credit scores and low credit 

limits. We were able to secure $425 million in relief for 6 million 

consumers, and we also imposed penalties on the companies to 

deter such activity in the future. These actions will serve as a 

warning signal for anyone who seeks to profit by deceiving or misleading consumers. 

In the second half of 2012, we also tackled issues in the market 

for private student loan debt, which currently totals about $150 billion outstanding. Our studies detailed the struggles students and 

5 

recent graduates are experiencing in that market. Together with 

Education Secretary Arne Duncan, we made recommendations to 

Congress on commonsense reforms to ensure that the risky underwriting practices of the past are not repeated. 

The work I am discussing here today is merely a snapshot of our 

efforts on behalf of consumers. We also are addressing consumer 

complaints on a growing number of financial products and services, 

totaling more than 130,000 to date. We have adopted comprehensive new mortgage regulations banning irresponsible lending practices that helped bring about the recent financial crisis. Our Ability-to-Repay rule, also known as the Qualified Mortgage rule, follows the simple principle that lenders should offer consumers mortgages they can actually afford to pay back. We have actively conducted outreach on various issues to older Americans, students, 

servicemembers, and others, and what we heard from them has 

guided the direction of our work. 

Each day, we take another step in pursuit of our vision to create 

a consumer financial marketplace where customers can see prices 

and risks up front and easily make product comparisons; in which 

no one can build a business model around unlawful practices; and 

that works well for individual consumers, responsible businesses, 

and the economy as a whole. We will continue to persist in this 

work, and we appreciate your oversight. As always, I will be glad 

to answer your questions. 

Thank you. 

Chairman JOHNSON. Thank you very much for your testimony. 

As we begin questions, I will ask the clerk to put 5 minutes on 

the clock for each Member. 

Director Cordray, in both the CFPB’s servicing rule and QM rule, 

you provide allowances for rural areas and community banks. I 

have heard from several constituents that the threshold for rural 

lending will limit lending by small banks and credit unions. How 

will those rules impact lending in rural or underserved areas? And 

what have you done to address these concerns? More specifically, 

why did you select a 5,000-loan threshold for defining small 

servicers? 

Mr. CORDRAY. Thank you, Mr. Chairman. One of the objectives 

Congress set for us and requires us to do with every new regulation, in addition to assessing costs and benefits, is to assess impacts on smaller providers and also rural areas. This is something 

that we paid close attention to with the Qualified Mortgage rule 

and the servicing rule, as you mentioned. 

That led us to write provisions into the rule that are specific and 

special to smaller providers and community banks that would recognize the role they play in some of the more challenging areas, 

such as rural areas and underserved areas, to underwrite loans. 

We provided a special provision for smaller institutions that has 

been reproposed, and will be finalized shortly, to recognize that if 

they are holding loans in portfolio and they are operating according 

to their traditional underwriting models, those are good loans. This 

is good lending, and it is sound lending that we want to encourage. 

We took the original proposal that was produced by the Federal 

Reserve, which had a narrow definition of rural, and would have 

covered about 2 percent of the population, and we expanded that 

6 

tremendously to almost 10 percent of the population. We have 

heard further comments since then to suggest that we could have 

written that even bigger. That is something that we are looking at 

and thinking about as we get more comments, even after the rule 

has been finalized. 

On the servicing rule, we originally proposed an exemption for 

smaller servicers, many of whom have very few foreclosures and a 

high-touch customer model, which is something we want to encourage, frankly, as a model to the larger servicers. We originally proposed an exemption for those that service 1,000 loans or fewer. 

After receiving comments from smaller providers—and we had 

SBREFA, a small business review panel, as Senator Crapo mentioned, on that rule—we ended up expanding that to those who 

service up to 5,000 mortgages. We estimate that this covers about 

98 percent of the smaller providers. They are exempt from significant portions of that rule. 

We are trying to be careful and sensitive to not having a onesize-fits-all approach and to recognizing that smaller lenders, particularly in rural areas, are of interest to Congress, they are of interest to the market, and they are of interest to consumers. 

Chairman JOHNSON. Director Cordray, as you know, outstanding student loan debt now exceeds $1 trillion. The CFPB recently 

asked for suggestions from the public on how to make student loan 

repayment more affordable. What does the Bureau plan to do next 

with regard to student lending? And what do you view as the biggest risks in this market? 

Mr. CORDRAY. Thank you for the question. It has been an active 

area for the Bureau and for our Ombudsman of Students, which is 

a position that Congress created in the Bureau. There are several 

things. I will try to move through them quickly and am happy to 

have you follow up as you wish. 

First of all, for those who are undertaking the decision whether 

to go to college and how to pay for higher education now, we have 

created new tools, such as the Financial Aid Shopping Sheet, which 

you mentioned. That has all been folded into a broader Paying for 

College module that is on our Web site. We are rolling this out to 

guidance counselors, teachers, parents, and young people themselves across the country right now as they are beginning to make 

these financial decisions for the coming school year. 

Second, we have just put out a rule to be able to supervise student loan servicers, many of whom may be suffering some of the 

same problems that mortgage servicers had suffered as we hear 

from consumers around the country. We will be actively and directly examining them to make sure they are complying with the 

law. 

On the proposal that you mentioned that we put out to gather 

thoughts and ideas from the public about what could be done about 

the existing student loan problem—which is burdening the economy, as the Federal Reserve has recognized in the past month, and 

is slowing down housing purchases and care purchases and other 

things—we have received a tremendous amount of interest. We had 

over 28,000 comments submitted on that proposal, which we are 

going through. We are working with a number of other entities, including Treasury and other parts of the Government and, of course, 

7 

the Department of Education to see what can be done to help address this problem. It is a work in progress. 

Chairman JOHNSON. Senator Crapo. 

Senator CRAPO. Thank you, Mr. Chairman. 

I want to talk, first of all, Mr. Cordray, about the data collection 

issue that I raised in my opening statement. As I indicated, it appears that the agency is collecting data on at least 10 million 

Americans. In the Gramm-Leach-Bliley Act, Congress allowed consumers to opt out of having their personal consumer financial information shared with third parties. Shouldn’t consumers be given the 

opportunity to opt out from having their financial information 

being shared with the Federal Government as a part of the CFPB’s 

data collection efforts? 

Mr. CORDRAY. Thank you for the question, Ranking Member 

Crapo. The story you adverted to in Bloomberg, which I also read, 

I think misunderstood a number of things about what the Bureau 

is doing, and I am happy to have the chance to clear that up. 

Senator CRAPO. Please do. 

Mr. CORDRAY. First of all, big data is the cutting edge of analysis 

and research right now in every field that involves analytics in this 

country. IBM, the big banks, and every company that deals with 

the public is gathering and crunching as much data as they can. 

I have seen figures that show that 90 percent of the data that exists in the world was created in the last 2 years. This is happening 

in the private sector. It is the way of the world. The big banks 

know more about you than you know about yourself, and me, too, 

as a consumer. The notion that the regulators would not keep up 

with them in trying to do our job of overseeing them I think would 

be quite misguided. 

Now, what are we doing in terms of gathering data? First of all, 

I want to stress that the data we are talking about are 

anonymized. It is not personal identifiable information about individuals, so the notion that we are tracking individual consumers or 

somehow invading their privacy I think, is quite wrong. 

Many of the data sources that we are accessing are commercial 

data sources, of which many entities are buying and selling the 

data in order to be able to analyze what it shows about the markets. For example, our credit card data comes from Argus, which 

is a source that is used by a number of other regulators, as well 

as by companies themselves. The National Mortgage Database that 

we are putting together is all about having the data to be able to 

do the things that Congress requires us to do and that you talk to 

me about frequently. You want us to do careful cost-benefit analysis. We cannot do that without good data. And, frankly, for the 

mortgage rules, we found that we need to develop a National Mortgage Database so that data is even better in the future. 

Congress asked us to write reports. We have a report due later 

this year on the CARD Act and what the effect of the CARD Act 

has been. We cannot write a report like that and have it be meaningful and helpful to the Congress unless we can analyze the data 

to be able to see what the actual consequences have been. 

This is the work we are doing and it is important for us to have 

data so that we can analyze it and we are not dependent on asking 

the financial institutions what they think. That is not the proper 

8 

role for a regulator. And, again, the data is typically anonymized. 

It does not go to you or me in particular, but it goes to consumers 

generally and is quite helpful and really essential to us to do our 

work. 

Senator CRAPO. Well, I appreciate that response. Let us talk 

about the anonymity issue first. Again, my understanding from the 

Bloomberg article is that the CFPB has let a number of different 

contracts to different private sector entities to collect and store the 

enormous amount of data that the agency is collecting. Even if the 

data collected is not personally identifiable to the agency, isn’t it 

possible for the CFPB to hire contractors to dig into this data and 

obtain personally identifiable information? 

Mr. CORDRAY. I do not know if that would be possible or not, 

Senator. I am not sure that it would be. It certainly is not what 

we are doing and not what we are going to be doing. We have no 

interest in—how did you phrase it?—watching consumers. We do 

have an interest in understanding how financial products and services are affecting consumers. We have an interest in being able to 

do the kind of very meticulous cost-benefit analysis you want us to 

do as we write rules so we can get them right. We have an interest 

in making sure that the studies and reports Congress is asking us 

to do to help inform your policy decisions, which is the law that we 

follow, are on sound grounds and that we can see over time whether the objectives you are trying to achieve are being achieved. That 

is the work that we are doing. 

Senator CRAPO. Well, I understand your point about the fact that 

collection of data is occurring at phenomenal rates in the private 

sector. I and I think many Americans are concerned about that as 

well. And the notion that the Government needs to keep up with 

the big data trend is one that I understand your point in terms of 

wanting to be able to regulate those in the private sector who are 

themselves collecting this data, but it seems to me that there is a 

huge issue here about whether the Federal Government should 

now be getting in a big way into the kind of data collection that 

you are talking about. 

I see my time is up. I will come back to this in another round, 

and we can discuss it further. 

Mr. CORDRAY. I look forward to that. Thank you. 

Chairman JOHNSON. Senator Merkley. 

Senator MERKLEY. Thank you very much, Mr. Chair. And thank 

you so much for your testimony and your leadership of the CFPB. 

I wanted to first ask, following up on the data question, specifically about the complaints database. Can you just share a little bit 

about—first, I believe that there are no names attached to it, like 

who complained about what, that it is anonymous, but that it gives 

you kind of a—it gives everyone a sense of what consumers are 

most concerned about. If that is correct, can you confirm that it is 

anonymous? And, second, what are the top three or four concerns 

that you see coming out of that database? 

Mr. CORDRAY. Thank you for the question, Senator. The database 

of consumer complaints, which is something that I think people are 

gradually getting used to, is analogous to what has been done for 

40 years by the National Highway Traffic Safety Administration. 

What they have done has led to tremendous improvements in auto 

9 

safety, and the auto companies now embrace it, although they did 

not at first. It is also analogous to what the Consumer Product 

Safety Commission is doing to make sure that the public is aware 

of hazards of lead in toys and other types of things that maybe we 

were not aware of for 20 years, but are probably better off now to 

know about and be able to protect our children. 

Similarly, what we are doing is, as we receive complaints, we 

scrub the complaints and remove any duplicates. We verify that 

there is a customer relationship between the complainant and the 

institution being complained about. We do anonymize that data. It 

does not reveal personally identifiable information. That is something we are very careful about, we are required by law to be careful about it, but also I frankly think it would bring the agency into 

disrepute if we were not careful about it. 

There is a growing amount of information that that yields. I 

think at this point our consumer complaint database, when we 

broadened it a month ago, had 90,000 cumulative complaints. They 

are added day by day now, so the number of complaints may be 

closer to 100,000. 

I will say this is nothing novel around the world. In the United 

Kingdom, their Financial Services Authority has been publishing 

complaint data about banks for years. In the most recent 6-month 

period, they published 3.4 million complaints about the banks. 

Senator MERKLEY. I am a little worried about running out of 

time, so what are the three or four top issues, insights that have 

come from the database? 

Mr. CORDRAY. First of all—and, frankly, your offices could probably tell us the same thing with the kind of inquiries you get from 

constituents—there is tremendous concern about mortgage servicing and a tremendous number of complaints and consumer harm 

in that area. 

Secondly, on credit card complaints, I would say what it has actually showed us—this is somewhat surprising to me because I remember before the CARD Act this was a very controversial area for 

the public—that the complaints are down, I believe. This is showing better work by the companies, more careful attention to what 

the CARD Act now requires, and I think our report later this year 

will show that there has been real progress made there. 

An interesting one for us, and fairly new and too preliminary to 

have much conclusions yet to draw, are credit reporting complaints. 

People generally are not aware of how significant an effect on their 

lives their credit reports have, but those that are have found a variety of errors. They are having trouble getting those errors corrected, and we are starting to hear about it as we started taking 

those complaints earlier this year. 

This is information that is illuminating to us as we go about 

doing our work. We think, as a result, it is illuminating to companies about how they can better improve their processes. And I 

think it is illuminating to the public, who has a right to know this 

information and to make assessments accordingly. I think it is good 

all around and we should have more information rather than less. 

Senator MERKLEY. Thank you. And since you mentioned it, the 

mortgage servicing is continuing to be an area of significant consumer concern, and certainly I still see that through our case 

10 

work—the calls our case work team gets. Some of the issues that 

have been raised in servicing are foreclosure mitigation discussions 

to try to make sure there is clear communication and all options 

have been pursued, and the dual track, which still exists to a degree. But any insights on the aspects of mortgage servicing that 

are particularly still troubling to consumers? 

Mr. CORDRAY. Senator, I think it is frustrating—it is frustrating 

to me, I am sure it is frustrating to you and your colleagues—that 

it is still the case—maybe less so and some servicers have clearly 

improved and others have yet to improve. There are still some fundamental issues—blocking and tackling, lost paperwork, people not 

answering the phone, not getting the single point of contact that 

has been promised. But I would say that the dual tracking is a 

great concern. The notion that somebody is working with you with 

the left hand and trying to get your loan modified while with the 

right hand, maybe unbeknownst to you, are proceeding to a foreclosure and undermining the work that you think you are accomplishing. That is very aggravating to people. 

The new rules that we have devised that are going to go into effect in January are going to make a significant difference in this 

respect, and they apply across the entire market, to both the 

servicers that are banks and the servicers that are nonbanks. That 

has never before been the case. We met face to face with the top 

executives from all of the large servicers, the top several dozen 

servicers, last year, to let them know this was coming. We also let 

them know the importance of this and to take this seriously and 

not to wait. And I would hope that over time your offices and our 

Bureau will hear less about these kind of complaints, but right now 

they remain very significant. 

Senator MERKLEY. Thank you very much. 

Chairman JOHNSON. Senator Johanns. 

Senator JOHANNS. Thank you, Mr. Chairman. 

Let me follow up on Senator Crapo’s questions about data collection. Where do you go to get the data? 

Mr. CORDRAY. I would focus on three different areas: credit card 

data, which is critical for us to have in order to do things like prepare the CARD Act study that Congress has required us to 

produce—— 

Senator JOHANNS. Right, but do you go to Visa or MasterCard? 

Mr. CORDRAY. Typically, on the credit card data—and it is a different answer for different categories, and I am reading from notes 

that my staff prepared for—we have been collecting this data 

through Argus, a known collector of data. It is used by any number 

of institutions and by other regulators, and so we are following 

very well plowed ground in assessing that data. 

Senator JOHANNS. So they go to Visa or MasterCard or whoever? 

Mr. CORDRAY. Or issuers themselves might be like Wells Fargo 

or Bank of America or JPMorgan Chase or any of those who issue 

cards. 

Senator JOHANNS. OK. You mentioned there are three. So there 

are two others. Where else would you go to get the data? 

Mr. CORDRAY. The second area, the National Mortgage Database 

that we are going to be creating together with the FHFA is essential, because what we have found as we were writing our mortgage 

11 

rules is that the mortgage data that is extant is not as good as it 

should be. Loan origination data is often decoupled from loan performance data, and there are holes in the data, so that it is not 

necessarily representative of the entire market. That made it somewhat challenging for us as went to write those rules, and we did 

a pause on the QM rule where we went and got more data—we 

were able to get more data from FHFA. They were very cooperative 

and collaborative with us and helped us on that. Then we put out 

for more comment because we were going to be using new data 

that did not surface before, so that we made sure that the process 

was full and complete. 

Going forward, that data is being gathered over time in real time 

on mortgages. This will provide a much more representative sample of what the mortgage market is doing so that we see the problems in real time, which we could not do very well over the last 

decade, and it helped lead to the crisis. 

Senator JOHANNS. And one more place you mentioned. 

Mr. CORDRAY. The third category has to do with credit records, 

and in that case, we have been buying the data from credit reporting agencies, as the Federal Reserve Bank of New York has done 

for a number of years. They have used that data for a number of 

years to publish their report, a quarterly report on household debit 

and credit that is widely quoted. 

Again, we are following their lead in terms of this is good data 

on credit reporting. It is going to help us have the insights to help 

protect consumers and understand whether laws are being followed 

as well as what the effect on consumers is of different practices. 

Senator JOHANNS. So individuals’ payment performance, whatever, is the basis upon which this mega data is created, obviously. 

So somehow, some way, the Government is getting control of information about how people pay their mortgage or their credit card 

bill or whatever. 

Mr. CORDRAY. I think this is an important difference, and I want 

to stress it. If by that you mean we are getting information about 

whether Richard Cordray is paying his mortgage and when and 

how, that is not the way the data works. What we are getting information about is consumers and how their mortgage performs 

over time. But it is anonymized. I do not have access to data about 

you or about myself. It is anonymized consumer data. But you have 

to have data about consumers if you are going to understand what 

is going on in the consumer marketplace. There is no two ways 

about it. You all want us to write rules where we have careful assessment of costs and benefits. If we do not have data and information about what the impacts in these markets are, we cannot do 

that. We cannot do our job. And I think you would be quite dissatisfied with us, and rightly so. 

Senator JOHANNS. I am out of time already, Mr. Cordray, but 

here is what I would say to you. To many people, this is going to 

sound downright creepy, to be honest with you. It is. And I just 

think people are going to be bothered by the fact that there is this 

Federal agency that is collecting data on the behavior of people like 

you and me and everybody else who is paying off a mortgage, who 

is paying credit card bills every month. I think it is a very uncomfortable situation for your agency. 

12 

Mr. CORDRAY. I think if people want to misunderstand that, that 

it is somehow following them individually and somehow invading 

their privacy and tracking into their personal lives, that is not 

what it is. We have to have information about what is going on in 

these markets. What goes on in the markets is an aggregate of consumer behavior, consumer performance, consumer harm, and consumer benefit. If you do not have any information to do this work, 

then basically you are a know-nothing and you are not going to be 

able to do the work well. And I think you would rightly be very 

critical of us if we just operated based on speculation and did not 

make an effort to ground our policy judgments in such information 

as is widely available and widely used and anonymized—very importantly, anonymized. 

Chairman JOHNSON. Senator Reed. 

Senator REED. Well, thank you very much, Mr. Chairman, and 

thank you, Director Cordray. 

Let me raise an issue that I think you and your colleagues that 

are looking after our military are aware of, and that is, there are 

military personnel who cannot immediately get on-post housing. 

They apply. It might take months as the list reaches them. In the 

meantime, they have entered into a rental contract, and in some 

States there is a severe penalty for breaking the contract. There 

are other States that I am aware of that actually have State laws 

that say if you are going on post, then the landlord cannot impose 

a penalty. 

Can you comment on how you are trying to deal with this? Because for many military personnel this is a real serious issue. 

Mr. CORDRAY. Thank you, Senator. I would say there are several 

different housing issues for servicemembers, both active duty and 

reservists, and their families, that we have encountered, as Holly 

Petraeus, our Assistant Director for Servicemember Affairs, has 

been around the country and talked to and brought back accounts 

from folks on the bases. 

One of the issues was the permanent change of station orders 

problem that I know you are very familiar with and that we 

worked with the Department of Defense and others, such as the 

Department of Treasury, to address last year was to qualify that 

as a hardship for the HAMP program. 

What you are raising is another great example of how there can 

be a general consumer problem, the issue of tenants who are renting and can be affected by some of these problems. A great example 

is when Congress dealt with the fact that tenants can be ousted 

from the place that they are living because the landlord is foreclosed upon even though the tenant may know nothing about that. 

It comes without warning, and they find their belongings on the 

street. 

For the military, again, this particular instance can do with 

change of station orders or it can do with, as you say, trying to improve your housing for lesser cost. If Congress is going to look at 

that issue, we would be happy to supply the experience that we 

have seen from around the country. That is, of course, a judgment 

for you all to make, but I would say it is another outstanding example of how you can have general consumer issues, and then you 

translate them into the military context. These still are general 

13 

consumer issues, but they often are sharpened or aggravated by 

the particular situation of servicemembers who often have limited 

choice because they have to obey orders, they have to go where 

they are told, and they have to be there when they are supposed 

to be there. 

Senator REED. Well, we would appreciate working with you. If it 

requires legislation, I think my sense is that we support this on 

both sides, because it has a huge impact on personnel. They could 

move from expensive rental quarters to on-post housing, more convenient, et cetera. And as you point out also another dimension, 

sometimes it is not just getting on-post housing. It is a complete 

change of station, and they have to go, and yet they pay a penalty. 

And we will do our—I would like to work with you on this. 

Let me turn to another subject, and that is, looking at the recent 

semi-annual report, I was disappointed to see your comments about 

the confusion that persists around the process and requirements 

for obtaining mortgage loan modifications. I do not have to tell you, 

because we spent a few sessions under the leadership of Chairman 

Johnson talking about this, the big deal, the modification deal, and 

now we have found out just recently that even some of the people 

who were owed checks, the checks bounced. 

So can you generally comment about what you are seeing and 

what you can do to help in this modification issue? 

Mr. CORDRAY. I think most importantly—and as Congress directed us to do—we have adopted new rules that are pretty comprehensive for the mortgage servicing market. They will take effect 

in January, and I think the companies—I know the companies are 

already at work implementing them now. Frankly, they should 

have come as no surprise. These problems have been surfaced and 

publicized not for months but for years. They are pretty common 

across the industry and yet they are galling because they affect individuals lead to bad results for individuals. They lead to people 

losing their homes, which is the most precious thing that people 

possess, and it upsets their personal finances tremendously, so I 

think that our rules will make a big difference. 

We are already also underway examining mortgage servicers onsite and looking at whether and how they are complying with the 

law. Some of them are doing a decent job. Many of them have problems, and for many of them, it is going to require corrections and 

compliance and perhaps enforcement actions as needed. 

Right now, we are now in a position, as this new Bureau that 

did not exist before, to examine the institutions directly, to ensure 

that they are complying with the new regulations—which went beyond what Congress required but was necessary to address the 

scope of the problems—and to enforce the law as needed to bring 

them into shape, which is long overdue. 

Senator REED. Now, going forward, you are going to have a much 

better process and procedure, but we have a whole category of 

Americans that are still caught up in the old system. 

Mr. CORDRAY. Yes. 

Senator REED. Let me ask a question, nonrhetorical. You are not 

involved with OCC and the Federal Reserve in this settlement that 

proposed to modify mortgages and compensate people for illegal 

foreclosures? Were you involved at all? 

14 

Mr. CORDRAY. No, we were not involved. I will say that at the 

time all of that began to unfold, I started as Attorney General of 

Ohio, and we did see the problems—the robo-signing and all the 

rest. I then joined the Bureau, and we had a transition period 

where we were not yet an independent agency. 

Our role in this is a going-forward role. It is not so much a looking-backward role, but I want to stress, when I say going forward, 

everybody who is caught up in this situation, as soon as our rules 

take effect, are governed by those rules. It does not matter that the 

mortgage was entered into 3 or 5 or 8 years ago. The examinations 

that we are in the process right now are examining the problems 

right now. The other processes that are looking back to things from 

several years ago is a different issue. But for us, the present and 

the future is very much the agenda Congress has given us, and we 

are going to be aggressive about trying to fix these problems. 

I also wanted to thank you for the efforts you and your colleagues have made on the changes in the Military Lending Act. I 

know you and your staff have been inquiring of us how it is coming 

to implement those. It is coming well. We are working with multiple agencies, including, of course, centrally the Department of Defense, and I think we will implement those changes in the law in 

the manner in which Congress intended. 

Senator REED. Thank you very much. 

Thank you, Mr. Chairman. 

Chairman JOHNSON. Senator Shelby. 

Senator SHELBY. Thank you. 

Mr. Cordray, good morning. 

Mr. CORDRAY. Good morning. 

Senator SHELBY. The Financial Stability Oversight Council, of 

which the CFPB Director is a member, was given broad authority 

to eliminate market expectations that any American financial firm 

is too big to fail. You are very familiar with this. 

Do you agree that as a member of FSOC, the CFPB director has 

a responsibility to contribute to these discussions and help identify 

threats to our financial system? 

Mr. CORDRAY. That is a responsibility Congress has given me by 

law, yes. 

Senator SHELBY. So you believe you have that responsibility? 

Mr. CORDRAY. I believe I do, yes. 

Senator SHELBY. Do you believe that all systemic risks have been 

contained and too-big-to-fail expectations that large institutions 

will not be allowed to fail have ended? Or still are there some 

threats out there? 

Mr. CORDRAY. Well, my perspective on this is sort of limited and 

more recent. I was not here in Washington and not directly involved in the events of the financial crisis. I was the treasurer of 

Ohio at the time overseeing billions of dollars in public finance. 

What I will say is what is clear to me from my work on the FSOC 

thus far. There is tremendous work in progress, tremendous strides 

have been made, and I think the framework is both there and 

being put in place more specifically to address those threats to the 

system. 

Senator SHELBY. Do you basically support limiting the size of 

banks as proposed by Senator Brown and Senator Vitter? 

15 

Mr. CORDRAY. I think that is a policy call for the Congress. My 

job under the law is to examine those banks for compliance with 

consumer protection laws, and that is what we are focused on 

doing. Whatever structure Congress would impose or influence in 

the banking industry, we will adapt to that and do our job. We do 

have $4 trillion dollar banking institutions that are challenging institutions. They are in multiple product lines, and we are pretty 

much continuous in our presence supervising them. 

But I would say that we are focused on doing our work, and I 

think those legislative debates will obviously proceed, and you all 

will make your judgments, and we will follow them. 

Senator SHELBY. Do you basically believe that we should and you 

should as an insider eliminate systemic risk as much as possible? 

Mr. CORDRAY. I think we should do our best to minimize systemic risk. I do not know that you can eliminate it entirely, but I 

think you can certainly, by being conscious of it and being more 

prepared. I think that minimizes the risk, and from there you do 

the best you can. 

I will say that the wisdom of Congress in the law of placing me 

as a representative of my Bureau on the FSOC, which is, of course, 

the body that could veto our regulations if they strongly disagreed 

with them, I think it has been very helpful to me both in understanding the perspective of that body and in having the chance to 

work together with my colleagues. This has helped me understand 

their point of view and they can see and understand the work we 

are trying to do that Congress has tasked us with. 

Senator SHELBY. Last Congress, I asked the Inspectors General 

of a number of financial regulators to review the economic analysis 

performed by the agencies under their supervision. The IGs reported back that, to the extent economic analysis is performed, it 

is often focused on compliance costs rather than looking at the effects the rules will have on economic growth and job creation. 

Determining compliance costs is critically important. We know 

that. But it is just one component of the overall economic impact. 

Do you believe it is important for regulators to understand the 

macroeconomic impact of rulemaking activities? 

Mr. CORDRAY. I do, and for us that has been in particular understanding the effects on access to credit and the effects on smaller 

providers and larger providers. But I would go back to my discussion with Senators Crapo and Johanns. We cannot have that understanding on data collection and we cannot do that work if we 

do not have the information on which to make those judgments, so 

I do think it is critical for us to do that, Senator, yes. 

Senator SHELBY. Dodd-Frank expressly requires the CFPB to 

evaluate the costs and benefits of any proposed rule. You are familiar with that. 

Mr. CORDRAY. Yes. 

Senator SHELBY. If your economic analysis determines that a 

rule’s costs outweigh its benefits, do you think the rule should still 

be implemented, rewritten, withdrawn, redebated, or what? 

Mr. CORDRAY. My sense of why Congress tells us to do analysis 

of things like benefits, costs, impacts on smaller providers, impacts 

on access to credit, and impacts on rural areas, is because Congress 

intends, and I think has made it very clear, that we should take 

16 

into account our judgments about deciding whether to proceed with 

a rule or how to write that rule. It may be that a rule in one form 

would have negative impacts there, but if you modify it a bit, then 

it improves. The specific provision is 1022 of Title 10 of DoddFrank, and it specifies how we are to go about this. We have been 

very faithful to that. It does, again, require information and data 

in order to do that work properly. I think that the dilemma we 

might find is if Congress has required us to do a particular rule 

and we found that the costs and benefits, you know, were troublesome, then we can try to write the rule somewhat differently, but 

obviously within the confines that Congress gave us. Or we could 

always come back and talk to you all about it. That would be a 

troublesome area. But where we have discretion, the costs and benefits are something that I think should definitely guide our policy 

judgments. 

Senator SHELBY. But in addition to analysis, for which you need 

data and everything, we understand that, to make a good judgment, you need objectivity of the whole situation, do you not? 

Mr. CORDRAY. You need to try to have that. I try to have that. 

I hope that we do. I think one way we can get there is by listening 

closely and being very accessible to all viewpoints, to using the 

processes that Congress gives us as much as Congress has done so, 

do the analysis, and do the notice and comment rulemaking where 

people have a lot of access to us—in our case, where appropriate, 

where the law requires to do the SBREFA panels, which we have 

found useful to us. All of those things—obviously the processes are 

provided, I assume—try to improve our rulemaking so we do not 

go off the rails and do something that is detrimental to the economy or detrimental to consumers. And I have no desire to do that. 

I want to carry out the tasks Congress has given us to the best of 

our ability. I want you all to feel, when you look and see what we 

have done, that you can be proud of what we have done and that 

our work reasonably reflects what your intentions were. And if it 

does not, I know I am going to hear from you. 

Senator SHELBY. Thank you. 

Thank you, Mr. Chairman. 

Chairman JOHNSON. Senator Brown. 

Senator BROWN. Thank you, Mr. Chairman. 

Mr. Cordray, it is nice to see you again. Welcome back in front 

of our Committee, your at-least-twice-a-year visit. We have talked 

about many of these things that never in our history has someone 

been in many ways held hostage a qualified nominee of the President because a significant number of Members of the Senate, pretty much all of one party, do not like the structure of the agency 

or wish the agency did not exist. I guess this is the second time 

in history—you were the first time in history a year or so ago. Senator McConnell said the other day, if he had his way, we would not 

have this agency at all. 

I want to talk about accountability, though, because they lay this 

all at the feet of the issue of accountability. Understanding that 

there is an FSOC veto over what you do, understanding, unlike 

most people in the agencies, that you come, you issue a report and 

come to this Congress at least twice a year, versus if you went 

through the normal Administrative Procedures Act, make that conVerDate Nov 24 2008 11:00 Jun 14, 2013 Jkt 048080 PO 00000 Frm 00024 Fmt 6633 Sfmt 6633 L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-A
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trast for me, your accountability as this agency is set up, as the 

CFPB is set up, versus that kind of accountability that other similar agencies might have. 

Mr. CORDRAY. Senator, I think we are all accountable in very 

fundamental respects. I think we are all accountable to the Congress, which can, of course, always change the law and has provided the law that we are required to implement faithfully. We are 

all subject to court oversight. If we adopt rules, there are specific 

processes we have to follow, and the courts can look over our shoulder and make sure we did that. They can also review the rules for 

substance. And, we are subject to oversight by the Congress directly as in hearings of this sort. 

Now, in that regard, the Bureau is special. There were special 

concerns about the Bureau, and it showed up in special structural 

constraints on the Bureau. 

Number one, we are unique among the Federal agencies in that 

our rules can be subject to a veto by other agencies, even aside 

from also potentially being reviewed and overturned, if appropriate, 

by the courts. 

We are subject to a GAO audit of our finances as opposed to, in 

general, most agencies and departments, the GAO audit is of the 

Federal Government as a whole, not specific to their finances. 

We are subject to an independent audit annually of our operations. That is, again, not something that is done at other agencies. 

I am happy to say that those audits have been clean audits to date 

even as we are building up and trying to build the agency as well 

as perform our duties. 

We are subject, unlike the other banking agencies, to a hard 

budget cap and then told that, if we need additional money, we can 

come to Congress for an appropriation. So we are sort of quasi-appropriated as it is. 

We are required to produce a semi-annual report and to testify, 

therefore, twice a year in front of the Senate Banking Committee 

and the House Financial Services Committee as an oversight on 

that report. 

I want the Senators not to underestimate yourselves. This is 

meaningful oversight. When I sit here and have to answer your 

questions, it is not just fun and games for me. I take it very seriously. I am accountable to you, and if I cannot answer your questions and respond to your concerns in a way that is persuasive to 

you, then I have a problem and an issue, and it is a meaningful 

issue for me. 

There are many ways in which the Bureau is specifically constrained beyond other agencies. We accept that. We are doing our 

best to do our work within that. And, frankly, I do not mind having 

strong oversight. It helps me make sure that I can sleep at night 

that we are, for the most part, I hope, doing the right things. 

Senator BROWN. Thanks. I do not think too many of us thought 

this was fun and games for you to come in front of these committees. 

[Laughter.] 

Senator BROWN. Not the first term or phrase that came to mind. 

I want to follow up a moment in my last minute or so on Senator 

Johnson’s questions about the private student loan market. The reVerDate Nov 24 2008 11:00 Jun 14, 2013 Jkt 048080 PO 00000 Frm 00025 Fmt 6633 Sfmt 6633 L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-A
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cent report by the student loan ombudsman has been important. 

My Subcommittee, as you know, held a hearing examining this 

issue last year. How will your new supervision of large private student loan servicers address some of the concerns described in these 

reports and these hearings? 

Mr. CORDRAY. I think, first of all, it is a meaningful change, Senator, to have an agency that goes in and examines very specifically 

for compliance with the law in an area. It means the institution 

has to be on their toes, and it means we have direct access to the 

information we need to assess whether the laws are being followed. 

That already changes attention and heightens the consciousness, 

and I believe changes behavior in these institutions and the examination function itself. 

On the private student loans, as I said, have put in place the 

mechanism to be able to now examine the student loan servicers, 

the ones who are actually dealing with the outstanding student 

loans and either getting the right information to people or not, either processing these loans properly or not. We hear a lot of complaints about that, so we will be aggressive about going in and 

making sure that things are being handled correctly, or if they are 

not, that they are put right. 

The whole student loan problem is a problem that should be of 

deep concern to this body. These are young people that we should 

care a great deal about. They are the ones with ambition, aspiration, and are getting saddled with debt that they do not understand, often. They tell us later that they wish they had known the 

difference between a private student loan and a Federal student 

loan. This is holding them back, and it is making them unable to 

rise and succeed and become leaders in our society, and it is a significant problem. We are going to be doing everything we can to address it at the Bureau. 

Chairman JOHNSON. Senator Warren. 

Senator WARREN. Thank you, Mr. Chairman. Thank you, Ranking Member. 

I just want to say this is my first full day back in the U.S. Senate since the attacks on Boston, and that many here, many of my 

colleagues, the staff, members of the press, members of the public, 

have held Boston in your prayers for the last week. And on behalf 

of myself, on behalf of the people of the city of Boston, I want to 

say thank you very much. You know, it has been a hard week, but 

the people of Boston are fighters, and we are strong, and we will 

get through this. But thank you all. 

Director Cordray, for more than a year now, a minority in the 

Senate has been trying to block your nomination, trying to reopen 

a debate that was resolved 3 years ago. For 3 years, they have 

tried to kill that agency, and they lost that vote 3 years ago. Then 

they fought to weaken the agency. They lost that fight because 

they did not have the votes. And today they know they still do not 

have the votes to undercut the agency, so they are determined to 

hold your nomination hostage. 

It seems pretty clear what is going on here. This is not about 

your qualifications or your performance. Your work has been 

praised by both consumer groups and by industry groups. This is 

19 

about a minority that does not want a watchdog that will keep an 

eye on big banks to make sure they do not cheat their customers. 

Now, why would big banks and their friends not like the consumer agency? You know, I take a look at a few of the things you 

have done in just the last couple of years. You have recovered nearly half a billion dollars for consumers who were tricked by big credit card companies. You created a complaint system that has handled 91,000 complaints last year alone. You built a tool to help students and their families compare the costs of college, what you 

were just talking about, so they have better information when they 

are making a big financial commitment. You have put together a 

tough-as-nails office to look out for servicemembers and military 

families and help protect them from financial predators, including 

helping servicemembers whose homes were illegally foreclosed 

upon. And you issued new mortgage rules that have been widely 

praised as balanced and fair and that are clamping down on the 

kinds of sleazy practices that cost millions of families their homes. 

Now, that is an extraordinary set of accomplishments for an 

agency that has only been around for a few years. And I think it 

explains why this agency is so important. I commend you in your 

work. 

I think that enforcement of the law, particularly the laws to protect consumers, to make sure that big banks follow the rules, I 

think that is really important. And, Director Cordray, you have already proven that the consumer agency is independent and effective, that you can be fair and be tough. But before your current position, you were the head of enforcement at the Consumer Financial Protection Bureau and before that the Attorney General for the 

State of Ohio. So you know more than just about anyone else about 

strong enforcement of the laws. 

So in your experience as head of enforcement at CFPB and as Attorney General for Ohio, in order to enforce the law effectively, how 

important is it that you have adequate resources, adequate funding, and adequate information? 

Mr. CORDRAY. I would say all of those things are essential. I 

think if you do not have the information, you do not know what to 

do. If you have the information but you do not have the resources, 

you know what to do but you cannot do it. I think you also have 

to have the will to understand and be motivated by the desired result, which is people need to understand that they have to obey the 

law. As I used to say when I was Attorney General of Ohio—and 

I feel the same way now—nobody is so high and mighty that they 

are above the law, and nobody is so undistinguished that the law 

does not apply to them equally with everyone else. That is a bedrock of our society. It has been the strength of the American society 

and American system for more than 200 years, and we have to 

make sure that we maintain it. That is part of my responsibilities 

at this Bureau and it is part of the Congress’ responsibility as well. 

You pass the laws; we are supposed to enforce the laws within our 

jurisdiction. I take it very seriously. To me it is a calling. I actually 

worked closely with criminal law enforcement, police, sheriffs, prosecutors as Attorney General of Ohio, and it is a very important responsibility to keep faith with the American people that we not 

20 

only have a democratic system, but we have a rule of law and it 

is maintained. 

Senator WARREN. Well, thank you very much, Director Cordray. 

I appreciate the work that you are doing and that you are out there 

to make sure that these large financial institutions do not just 

treat a fine as a cost of doing business, but that they actually 

change their behavior, and that consumers are entering a level 

playing field and they have a real chance in these markets. I appreciate that. 

Did you want to add something? We are out of time, but did you 

want to make a remark? 

Mr. CORDRAY. Yes, I would just say that when you are dealing 

with a particular situation where there has been a violation of law, 

there are sort of four pieces to it, as I see it from the standpoint 

of this Bureau. 

There is making sure that what is being done is not done in the 

future, stopping it, whether it is injunctive relief or banning someone from the marketplace for a period of time, both of which we 

have done. 

It means restitution to consumers so that they are as much as 

possible made whole for the harm that was done them, that should 

not have occurred and only occurred because of a violation of the 

law. 

There are penalties that can be imposed when restitution is not 

enough to sort of teach the lesson and see to it that people are deterred from doing this in the future, that they do not just feel like, 

‘‘I got caught this time, but when I get away with it, that does not 

cost me anything.’’ 

Finally there are cases where criminal referrals would be appropriate. We want to be very careful about that, but there are going 

to be cases of that sort. 

Senator WARREN. Good. Thank you very much, Director Cordray. 

I am glad you are out there fighting on behalf of consumers, and 

there will be those of us here who will be fighting on your behalf 

and on behalf of this little agency. Thank you. 

Mr. CORDRAY. I appreciate that. 

Chairman JOHNSON. We will go briefly to a second round of questions. 

Director Cordray, I understand that the CFPB is conducting 

exams of larger institutions in coordination with other Federal or 

State regulators. What steps does the CFPB take to ensure that 

the exams and information requests are well coordinated with 

other regulators and not duplicative? 

Mr. CORDRAY. Thank you, Mr. Chairman. This is an area where 

I think the Bureau has done very well, and I will just say that. I 

think it is in part because, as the Bureau got underway, there was 

a point made to bring some people in who came from a State government background. I myself came from a State government background, but here I am thinking not of someone like myself from an 

Attorney General office, although that is important and relevant, 

but people who came from a State banking background or a State 

financial services background. We have had terrific relationships 

with the CSBS, the Conference of State Banking Superintendents 

and we have collaborated closely with them. There have been matVerDate Nov 24 2008 11:00 Jun 14, 2013 Jkt 048080 PO 00000 Frm 00028 Fmt 6633 Sfmt 6633 L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-A
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ters where we worked directly with them and where there has been 

a process of coordination and information sharing with them. At 

last count, I believe we have agreements with 61 different banking 

and financial service agencies in 49 States. Some States have multiple agencies. I think that that relationship is good. We lean on 

them in some respects and they can now lean on us in some respects. We bring joint resources to the problems, and I have been 

really pleased at their attitude toward working with us and I think 

our attitude toward working with them. 

Chairman JOHNSON. With regard to community banks and credit 

unions that are not subject to the CFPB’s examination authority, 

what measures have you taken to ensure that your rules are clearly interpreted by the prudential regulators during their exams? 

Does the CFPB plan to continue releasing Small Entity Compliance 

Guides as has been done twice already? When might we expect to 

see more Small Entity Guides on the other mortgage rules? 

Mr. CORDRAY. Thank you, Mr. Chairman. I have got about three 

different answers to that question. I will try to go fast. 

On the Small Entity Compliance Guides, this is something we 

take very seriously, and we know it is important, and we have been 

told this over and over by both smaller institutions and the trade 

associations that represent them, like ICBA and NAFCU and 

CUNA. That means taking our rules—Senator Crapo initially mentioned 25,000 pages of rules issued in January. That is 25,000 

pages of text. A lot of that is preamble. A lot of that is cost-benefit 

analysis. I think when you actually translate it into the Federal 

Register, it was less than 100 pages of rules, and these were seven 

major mortgage rules that Congress directed us to do. 

Nonetheless, I do not think people enjoy reading the Federal Register. I do not, and I am a lawyer. We have been translating those 

into plain English and compliance guides—what you need to know, 

what you need to do. That is becoming a standard for us on every 

rule that we publish, and we are doing Web and video things. Some 

people like to get the information that way. 

In terms of making sure that our regulations are administered 

and examined around in the spirit in which they are intended, we 

work closely through a body that I had never heard of before I 

came to this Bureau called the FFIEC, the Federal Financial Institutions Examination Council. With them, we are taking the lead on 

writing a first draft of what the examination work would look like 

around these rules and then collaborating with the other agencies 

to get that in place and to publish it so it is transparent to institutions. I think it is only fair to them, and they have a right to expect 

that and demand it. 

I was surprised to hear the other day we are well on track to 

having the examination modules, or whatever you would call them, 

ready by June of this year, even though the rules do not take effect 

until next January. That is light warp speed for an interagency 

group like that, and it will help us make sure that we are on the 

same page. As we publish them, if institutions have reactions or 

think we are not getting something quite right, they will have a 

chance to kibitz in on that. 

Finally, since we do not actually examine the smaller credit 

unions and community banks, I made it a point to create a ComVerDate Nov 24 2008 11:00 Jun 14, 2013 Jkt 048080 PO 00000 Frm 00029 Fmt 6633 Sfmt 6633 L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-A
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munity Bank Advisory Council and a Credit Union Advisory Council so we do hear directly from them and fill in what otherwise is 

a gap in not having that day-to-day direct hands-on experience 

with them, and that has been very helpful to us. It has been very 

insightful for our work. 

Chairman JOHNSON. Senator Crapo. 

Senator CRAPO. Thank you very much, Mr. Chairman. 

Mr. Cordray, I want to go right back to the issues we were talking about before. I want to phrase or characterize the question I 

am asking with a bit of a statement first, because I do understand 

your point about needing to have data in order to make effective 

cost/benefit analysis and achieve the right balance in regulation. 

And I do understand that we have a dynamic developing in the 

world right now with regard to what has been called ‘‘big data’’ in 

terms of the phenomenal rate of collection of data about people 

going on in the private sector. 

Mr. CORDRAY. It appears to me, Senator, apparently it is the way 

of the world. 

Senator CRAPO. It is, and it is happening. That being said, I 

think there still are some very serious and real questions that need 

to be answered as well as perhaps dealt with in terms of the way 

that the Federal Government involves itself in this entire process, 

if at all. Just a couple of observations. 

Nobody in the private sector has the right or the power that the 

Federal Government has to force the release of information. My understanding is that you are not just purchasing the data we are 

talking about from private sector collectors, but that in the examination process and in other aspects of the collection, banks and 

other financial institutions are being required to provide data that 

they could not be required to provide by a private sector operator. 

So, in other words, the power of the Government is being put behind this data collection effort, as I understand it. 

Just let me go, and, in fact, I am going to ask something at the 

end here that will definitely go beyond this hearing, but hopefully 

get us to a much fuller explanation of how and where we are going 

here. 

In another context, under Gramm-Leach-Bliley, as I mentioned, 

and in many of the interactions between financial institutions and 

their customers, there is an opt-out right, which does not appear 

to exist in the functions that are currently being undertaken by the 

CFPB. And the bottom line here, as I see it, is that although I understand the need to collect data, I am very concerned about the 

heavy hand and the power of the Government being brought behind a phenomenally new, big data collection effort. 

In your response to one of my first questions on this, you indicated that you were not sure whether the CFPB or some other 

actor or some other contractor could go back into all of this data 

and reconstruct it in a way that it was not anonymized. I actually 

am very concerned about that, and now we have a Government 

agency that is potentially capable, I think, of getting that kind of 

information that is currently anonymized, but we just have to take 

the word of the agency, like consumers today have to take the word 

of private sector people that they are buying their cell phones from 

or working with on the Internet or what have you, that they are 

23 

not collecting this information in an individual-specific fashion. 

And, frankly, people do not have a high level of confidence that 

that is not happening. And I do not have a high level of confidence 

that it is not possible for the agency to get access to this information on a specific basis. 

So for all of these reasons about the data collection that is being 

undertaken, I simply ask you this question and then make this 

suggestion. Has the CFPB done an internal legal analysis about 

this whole data collection process? And what I am getting at here 

is that Dodd-Frank clearly prohibits the CFPB from collecting personally identifiable information, and if all of the pieces of information that the CFPB is collecting right now could be utilized to engage in personal identification, then perhaps that could violate the 

law. But more specifically, it would be helpful to know what 

steps—what potential is there. I am actually relying right now in 

this question on a Bloomberg article. That is the extent to which 

I know that we know as the public about what is happening. 

And so I think that it would be very helpful for us to know exactly how this data is being collected, not just who is being contracted to collect it or whether it is being collected in examination 

processes, but how it is being collected and how it might be used, 

and then I think the ultimate conclusion should be reached, and 

that is whether its collection is in violation of the Dodd-Frank prohibition. If you would like to comment, please. 

Mr. CORDRAY. I would, Senator. Thank you, Ranking Member 

Crapo. A long question, and I would like to give you only a medium-long answer, but there are a number of pieces in that question. 

First of all, it is not correct under the law that the Bureau cannot collect personally identifiable information. When somebody submits a consumer complaint to us, they put their name and address. 

The issue under the law is that we are not supposed to disclose 

personally identifiable information, and we have been very careful 

not to do that and not to violate people’s privacy in that regard. 

I want to go back to what you said, and I think frankly a lot of 

what you just laid out is a very fair line of inquiry, and I share 

your concern. If I were looking from the outside at Government, I 

would share the concern as well. 

First of all, in terms of forced collection of data, that is for the 

most part not what the Bureau is doing. As I mentioned, the credit 

card data that we are talking about we get from Argus. We buy 

that. Many people buy that data from Argus and it is a very common thing. There is nothing really special about that, no new 

ground that the Bureau is plowing on that. 

We are buying the credit reporting data from the same source 

that the Federal Reserve Bank of New York has been buying it 

from for years and using to develop their reports that have been 

very insightful on credit reporting and credit in the economy. 

There are times where, as we examine institutions, we have to 

begin by getting a baseline of data from the institution in order to 

then calibrate what exactly is going on there. Are they complying 

with the law? What are they doing? There clearly have been times 

where we think we need a certain amount of information to do our 

job, and the institution may feel like we are asking for more inforVerDate Nov 24 2008 11:00 Jun 14, 2013 Jkt 048080 PO 00000 Frm 00031 Fmt 6633 Sfmt 6633 L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-A
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mation than we need to do our job. I think those are reasonable 

differences of viewpoint that have to get worked out as we work together, and I think for the most part they do. 

But I would say this: I think that you have fair issues you are 

raising. I would want to have the chance to have our staff get you 

a very specific answer to your question about whether the 

anonymized data could be somehow reverse engineered in a way 

that affects somebody’s individual privacy. I do think that that is 

not an issue. If it were, it would have been an issue already with 

other agencies gathering that same information and using it, which 

they have been doing for years. It is new to the Bureau but not 

new to the process. 

I will have our staff spend time with your staff to dig into some 

of these issues, to try to understand in more detail what some of 

your concerns are. I am happy to do that with your colleagues as 

well or their staffs. I want to dispel any concern on this front. I 

think that what we are doing as an agency is we are trying to gather the kind of information we need to do our job the way you would 

expect us to do it, to be able to do careful cost-benefit analysis, 

which we cannot do without sufficient information, and to do the 

kind of reports to Congress that you expect from us that will be 

credible and that will give you a basis for going forward and making policy and making judgments about things like the CARD Act, 

which we are going to give you a report later this year on how that 

has been implemented and what some of the issues are with that, 

both factual and then perhaps normative. And I know you want 

that. You have required us to do that. We cannot do it without data 

and information. 

Again, all we are trying to do is to do our job. If there are concerns about some of the details of how that information is handled, 

our Inspector General looks at these things. The GAO audits look 

at our operations. You all are free to look at them. We want to be 

an open book, and if there are concerns, then we want to try to address them. 

Senator CRAPO. Well, thank you. My time is obviously up, and 

so I cannot continue with this here. But I would like to continue 

this with you, and I would like to ask you to take seriously the request that I make that there be an internal legal analysis that is 

shared with us about all the details of how this project is operating 

or this operation is being undertaken and how it fits with the requirements of Dodd-Frank. 

Mr. CORDRAY. You tell us what you want, sir, and we will get 

it to you. 

Senator CRAPO. Thank you. 

Chairman JOHNSON. Senator Hagan. 

Senator HAGAN. Thank you, Mr. Chairman. 

Director Cordray, as I said before the hearing, it is always a 

pleasure to see you, and I feel like we see you quite a bit. Thank 

you for the job that you are doing. 

I want to associate myself with Chairman Johnson’s question 

about the rural definition. I have heard questions and concerns 

about this definition. I was surprised to see in North Carolina several counties labeled ‘‘nonrural,’’ especially in the northeastern part 

25 

of our State, which is quite rural—for example, Camden County 

and Currituck County. I appreciate the CFPB looking at this issue. 

I want to talk to you about financial literacy. I have always been 

a huge supporter of teaching financial literacy to our students in 

grades 6 through 12. As we have discussed in the past, I will be 

introducing legislation on this topic later this week. When I was in 

the State Senate in North Carolina, we passed a mandatory requirement that schools teach financial literacy. I keep saying this 

is not rocket science. We just do not teach it. 

I also serve on the Health, Education, Labor, and Pensions Committee, and I chair the Subcommittee on Children and Families. 

We will be having a hearing titled, ‘‘The Economic Importance of 

Financial Literacy Education for Students’’ later this week. 

Can you talk about what the CFPB is doing to improve financial 

literacy through the Consumer Education and Engagement Division and the Office of Financial Education? What improvements do 

you see taking place. 

Mr. CORDRAY. Thank you for the question, Senator. This has also 

been a personal passion of mine. I think it is hard to come face to 

face with these issues and see how they affect individuals and 

households and not be passionate about this subject. 

When I was a local official in Ohio, I had to deal with folks who 

were delinquent on their real estate taxes, and, you know, there is 

a perception among the public that people who do not pay on time 

are deadbeats, and some of them are and some of them just do not 

want to take their responsibilities seriously. For the most part, 

that is not the case. People are victims of either bad luck or bad 

decisions or poor choices, but often just bad fortune. Every day people die in families across the United States. You always hope it is 

not your family, but it is somebody’s family. Or somebody gets injured where they cannot work or the marriage falls apart and there 

is a divorce, and now there are two households where there used 

to be one, and there may be expenses and arguing over the assets. 

All these things disrupt people’s lives. 

What I saw was that in all those instances issues were made 

worse by the fact that people really did not understand, and they 

knew they did not understand, a lot of the financial decisions they 

were making, and keenly felt the self-consciousness of not knowing 

what they were necessarily doing or recognizing a year later that 

they made a bad choice about that mortgage or about that student 

loan. 

I think that one of the things that we absolutely have to do as 

a Bureau—it is fundamental for us, and I am going to be much 

more aggressive in the coming year in using the bully pulpit and 

pushing on and collaborating with officials around the country—we 

have to teach people and make available to them the tools so that 

they can learn more about how to handle their personal finances. 

You cannot have a free market economy, which rests on individual 

decision making by millions and millions of Americans, in which 

they are not capable of making sound decisions for themselves. We 

do not want to have a society where people make decisions and several years later come to our Tell Your Story line, as they do every 

day, and talk about how they regret the decision they made, and 

if they had known the difference between a private student loan 

26 

and a Federal loan, they would not have done what they did, but 

now they are stuck with it. It is a tragedy in this country that we 

would not consciously teach young people how to handle themselves when they go out in the world. They may not listen, they 

may not do it, but the fact that we do not, as you say, we do not 

even teach it, is just a scandal. 

In Ohio, I worked for the same thing. We have now a requirement in Ohio that you have to have personal financial education 

before you graduate. That was a struggle. The next struggle, of 

course, is what you said. What does that actually mean and how 

much is it? I was told just yesterday, when we had visitors in on 

this subject, by a woman from the University of Cincinnati, that in 

many districts that is going to be just a 6-week thing folded into 

some other class, which is something. It is better than nothing, and 

6 weeks is certainly better than zero, but we have to take this seriously. We mandate teaching of history. We mandate teaching of 

Government so people can be good citizens. We also have to mandate a basic understanding of finance and a recognition that there 

are going to be certain decisions you will come across in your life 

that will be life-changing—what you do about that mortgage, what 

you do about trying to pay for education. Getting those right is 

really not a casual matter, and it is something we plan to be a 

trusted source for the resources for people to try to grapple with 

those decisions, as they are doing right now with our Paying for 

College module. 

I am sorry. I could talk for 20 minutes about this, and would if 

you did not stop me. But I think it is not a partisan issue. This 

was Home Economics in the old days, and it is just basics of being 

able to operate on your own. We all know, as I always like to put 

it, brothers and sisters, sons and daughters, cousins, nephews, and 

nieces that we know are not as well equipped as they should be 

and we have a responsibility for that. 

Senator HAGAN. I think you should take the bully pulpit and 

really use it. I can see your passion. I have it too. I have seen so 

many people that have gotten into so much trouble because they 

simply were not educated. And when I say they were not educated, 

they are very, very smart people, but they did not understand the 

dynamics, and primarily they do not understand debt. 

Mr. CORDRAY. It is complicated for people, let us face it. I used 

to say when I was the State treasurer of Ohio and I was responsible for billions of dollars of public funds, and I hoped I was doing 

a good job at making decisions about keeping them safe. This was 

in the throes of the crisis of 2007–08. I would go out and talk about 

this issue, and I would say, frankly, there are many things I do not 

know that I wish I knew more about. Am I saving the right balance 

of savings toward retirement? Do I have the right balance of insurance on my car or home or life? You know, am I getting that right? 

Do we understand enough about our credit reports? 

There are just a lot of things that are complicated for people, and 

for us at the Bureau, it is about reducing the complexity. That is 

a big part of what we are trying to do, Know Before You Owe, and 

the kind of simplification and transparency of these decisions; and 

then building more capability among people and giving them the 

ability to have tools. Of course, people will make their own deciVerDate Nov 24 2008 11:00 Jun 14, 2013 Jkt 048080 PO 00000 Frm 00034 Fmt 6633 Sfmt 6633 L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-A
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sions for themselves. It is not going to be some nanny State deciding what you do with your mortgage, but you are the one that is 

going to have to live with it. 

Senator HAGAN. I believe my time is up. Thank you. 

Chairman JOHNSON. Senator Moran. 

Senator MORAN. Mr. Chairman, thank you very much. 

Mr. Cordray, thank you for being here. About a month ago, the 

CFPB released a statement stating that U.S. lenders could face litigation if they fund loans made by auto dealers that are later found 

to be discriminatory. It is a huge component of our economy. I 

think the number is about $90 billion. I would be interested in 

knowing—I do not have an opinion at this point about whether the 

finding is right or not, but tell me about the analysis that was done 

to arrive at that conclusion. Do you have the methodology of this 

decision available? If so, what would you be able to share with that 

process, either today or later with me in my office? 

Mr. CORDRAY. Thank you, Senator, for the question. The issue of 

indirect auto lending is one that, at this point, we addressed in a 

very general way with a legal analysis that leads to a legal conclusion. It is not yet a factual conclusion about any particular instance, although there is a lot to be heard about this area as you 

go around the country and listen to people, both lenders and borrowers. 

The legal point we made, which I think is straightforward, is 

that if you are a lender and you set up a lending program, which 

involves third parties making some decisions in the program, but 

it is your program and you are the one lending the money, then 

you remain responsible for complying with the Federal law. It is 

the same in the mortgage field. If you set up a lending program 

as, say, a bank lender of mortgages and you set it up so that some 

of the loans are made directly by your employees and some are 

made indirectly by brokers or others, you remain responsible for 

your program, and you have to comply with the law. 

I think it was a fairly straightforward point, but we were hearing 

from some folks who did not think that was necessarily so, that 

somehow if there is a third party involved, that somehow it becomes entirely their responsibility and not the lender’s responsibility. I do not think that is right. We would be happy to share the 

legal analysis with your staff separately if you would like. 

Senator MORAN. So at this point, it was just the legal analysis—— 

Mr. CORDRAY. It was a bulletin that we put out, yes. 

Senator MORAN. And you indicated earlier about cost/benefit 

analysis, and that would come later in determining whether or not 

there are enforcement actions or regulations to be written? 

Mr. CORDRAY. Yes, if we were to write regulations—and that is 

a possibility—there would be cost-benefit as required by 1022 of 

our statute to have to do. If we are undertaking enforcement actions, that is a different issue. It is a matter of investigating the 

facts, setting them against the law, something I know you are very 

familiar with. 

Senator MORAN. OK. That answers my question. Thank you very 

much. 

Mr. CORDRAY. Thank you. 

28 

Senator MORAN. Thank you, Mr. Chairman. 

Chairman JOHNSON. Senator Warren. 

Senator WARREN. Thank you, Mr. Chairman. 

Director Cordray, I understand that the Consumer Financial Protection Bureau is required by Dodd-Frank to complete a study of 

mandator arbitration. Is that right? 

Mr. CORDRAY. It is, yes. 

Senator WARREN. When do you anticipate you are going to have 

that finished? 

Mr. CORDRAY. I do not know that I can give you a specific date, 

but it is one of the things that Congress has specifically required 

of us and a task Congress had given us, so when we set our priorities, tasks Congress has given us tend to take priority over tasks 

we give ourselves. 

I would say we are already in process in putting together that 

study. What Congress said in our statute is two things. They said 

that we were to do a study of arbitration as it affects consumer financial products and services, and there are arbitration clauses, as 

I know you know, in a number of different types of consumer lending contracts, and it is something that has spread in the last couple 

of decades, certainly. Then if we are going to adopt policy, regulations, or some provision about what to do about arbitration clauses 

of that sort affecting consumers, it should be based on the results 

of our study. 

You could argue this as the same kind of thing Congress says do 

a cost-benefit analysis. Here they were much more specific. They 

said do a full study, really look at this, really dig into it, really try 

to understand how arbitration proceedings differ from court proceedings, what kind of rights they give to consumers, what kind of 

rights they may take away, what kind of results are gotten there, 

is that a fair system, is it reflective of the merits of the issues, or 

are there systematic procedural biases that make it difficult for 

consumers to get through them, who pays for the arbitration, et 

cetera, and that can vary. 

All of those things, study that carefully, and then do policy. They 

wanted us to be very rigorous about this, and we are going to do 

that. 

I would estimate—and I hate to estimate dates because then people hold me to it, but I feel quite sure—that we are going to have 

some of this analysis out publicly this year. Whether it will all be 

out publicly this year, I am not sure, but we are trying to be very 

careful as to what we are doing. We know that there is a lot riding 

on it because then it will be consideration of policy following immediately after. 

Senator WARREN. I appreciate that you take this seriously, and 

I am looking forward to the study as soon as you can possibly get 

it out. 

I want to ask you about one other thing. I know that you have 

set up a consumer complaint process and that it has some quite innovative features, and you have also made it a quite transparent 

process. I wonder if you could tell us just a little bit about what 

you have set up at the Consumer Bureau and what you have 

found, what the response of the banks has been and how this information is being used. 

29 

Mr. CORDRAY. I actually think we are tracking a precedent that 

has existed now for about 40 years, which is the National Highway 

Traffic Safety Administration. They started publishing data on 

auto safety back in the early 1970s, and it was resisted strenuously 

by the auto companies at the time. The sky was going to fall if people actually knew how safe or unsafe their vehicles were. 

Fast forward almost 40 years later now, and that is standard. It 

is accepted. It has become the basis for consumers making decisions. It has been the basis for companies thinking and looking 

more carefully at their own operations and doing recalls of products 

that are questioned. And it has been, I think, a success. 

I have seen discussion in the last year or two, as we were focusing on our work here, that the auto companies now not only accept 

it but embrace it. They think it has made their products better, 

and it has minimized litigation risk for them, which is another way 

it can save companies money by paying attention to how their customers are being treated. So I think it is the same thing in the financial services area. 

We get complaints. We are taking them on a range of subjects 

now, which is increasing—mortgages, credit cards, auto loans, student loans, bank accounts, and now credit reports and remittance 

transfers. We are publishing that data. We find it valuable in our 

work. It is informative to us. So we think it will be informative to 

companies. They can look at their competitors. Who is doing better 

than I am? Who is doing worse? Why are they doing better? How 

can I improve? That is the kind of competitive dynamic we want 

to foster. 

And, third, for consumers to be able to have this information and 

look at it and potentially make decisions on it. Maybe somebody 

will use that database and start rating financial products, as is 

done with cars on auto safety, as I think likely will be done over 

time with the Consumer Product Safety Commission as they put 

out information on which toys and other household products—cribs, 

toasters, you name it—are safe. 

This is the kind of information that if I am a consumer and I am 

a member of the public—and the members of the public really are 

the ones who should and do run our Government, not us—I would 

want to have that information. I would not want my officials to 

hoard it. I would want them to share it with me. I might use it, 

I might not. But if I can find some benefit in it, then I would expect 

them to share it with me. 

Senator WARREN. And, Director Cordray, I know I am out of 

time, but let me just ask—you talk about the effects on the market 

overall, but for individual consumers who file complaints, those 

complaints are then forwarded to the financial institutions? 

Mr. CORDRAY. Yes. 

Senator WARREN. Have some people actually gotten money back? 

Mr. CORDRAY. Many. You know, by no means all. You know, a 

complaint is just that. It is a complaint. Sometimes it is valid. 

Sometimes it is not. Sometimes people think it is valid, but it is 

based on a misunderstanding of the facts or the law. But there 

have been many situations where consumers have received relief. 

Millions of dollars have been returned to consumers through our 

consumer response line. And notably, and more important—this is 

30 

something the companies wanted us to make a change, and we did 

to stress this—they often give nonmonetary relief. You cannot put 

a price tag on it, but if you get something cleared up in your credit 

report where you do not have to keep calling for another 3 months 

to get that thing fixed on your bank account, that is meaningful relief for people, and it is very satisfying to them. 

We have had many instances of both monetary and nonmonetary 

relief. We have had a lot of matters referred to us by Members of 

Congress and members of this panel that we have been able to resolve, and I think it has been very satisfactory. I know there are 

some that we have not been able to resolve, and I apologize for 

those. But we do our best, just as I know your staffs do their best, 

to help people, and that is part of what our job is. 

Senator WARREN. Good. Thank you. 

Thank you, Mr. Chairman. 

Chairman JOHNSON. I will turn to Senator Crapo for a brief 

statement. 

Senator CRAPO. Thank you, Mr. Chairman. I just wanted to follow up—Mr. Cordray, this is not going to be a question because we 

will get together with you afterwards on the issues that we said. 

Mr. CORDRAY. OK. 

Senator CRAPO. First of all, we did not get into a number of the 

questions that I raised in my opening statement, which we talked 

about, and so I will submit those questions to you, if you would respond to them. 

Mr. CORDRAY. I sure will. 

Senator CRAPO. But you and I, I think we may have a disagreement or a different understanding at least as to what the DoddFrank statute requires. As I read it—and I am reading the statute—it says, ‘‘The Bureau may not use its authorities under this 

paragraph to obtain records from covered persons and service providers participating in consumer financial services markets for purposes of gathering or analyzing the personally identifiable financial 

information of consumers.’’ 

So those were the exact words of the statute. By the way, in 

other parts of the statute leading up to that, it talks about voluntary information being provided by consumers, and so I again 

refer to my opt-out suggestion. But I would like to get with you— 

and we will do that—and urge you to provide the kind of information as well as legal analysis about the department’s processes here 

that can help us address some of these issues. 

Mr. CORDRAY. We will certainly do that. We would like to put 

your mind at ease on that. I do think what you read is part of the 

statute, absolutely. There are other ways in which the Bureau gets 

personally identifiable information such as, for example, when people file their consumer complaints. 

Senator CRAPO. But that is a voluntary action by the consumer. 

Mr. CORDRAY. Yes. We are not really interested in personally 

identifiable information. For us, it is just a hassle. It means we 

have to make sure that it is being properly handled, that it is not 

being disclosed, that we have to devote a lot of time and attention 

to guarding it carefully and making sure it is handled the way 

every other agency under Federal law has to handle it. 

31 

What is insightful to us is the anonymized information that tells 

us about consumer behavior, consumer harm, consumer benefit, 

and that is the information we need. We do not really want to 

know about you personally. We want to know about consumers in 

general. 

Senator CRAPO. Well, I understand that, and I trust that that is 

exactly what you are all about. But I do not think just the assurance of the agency that they are not interested in it is really what 

we are trying to achieve here. 

Mr. CORDRAY. Understood, yes, and we will be happy to work 

through that to your satisfaction. 

Chairman JOHNSON. Mr. Cordray, I thank you for your testimony 

today and for your leadership of this important agency. 

This hearing is adjourned. 

[Whereupon, at 11:42 a.m., the hearing was adjourned.] 

[Prepared statements, responses to written questions, and additional material supplied for the record follow:] 

32 

PREPARED STATEMENT OF RICHARD CORDRAY 

DIRECTOR, CONSUMER FINANCIAL PROTECTION BUREAU

APRIL 23, 2013 

Chairman Johnson, Ranking Member Crapo, and Members of the Committee, 

thank you for inviting me to testify today about the Semi-Annual Report of the Consumer Financial Protection Bureau. My colleagues and I are always happy to testify 

before the Congress, something we have done 32 times now. 

Born out of the worst financial crisis since the Great Depression, the Consumer 

Bureau is the Nation’s first Federal agency whose sole focus is protecting consumers 

in the financial marketplace. We are dedicated to improving the lives of everyday 

Americans and to restoring trust in consumer financial markets. The Semi-Annual 

Report we are discussing today embodies our work over the last 6 months of 2012. 

The report illustrates the ways we are using the tools Congress has provided us 

to empower consumers and promote a fair, transparent, and competitive marketplace for consumer finance. We have taken steps to improve the workings of markets—particularly those in which consumers cannot choose their financial service 

providers. 

One such market is debt collection. Concerned about systemwide problems that 

pose risks to consumers, we gained authority at the beginning of the year to supervise debt collectors. The debt collectors covered by our supervisory authority account 

for over 60 percent of the industry’s annual receipts in that market. Bad actors in 

this market are a detriment to consumers and to every debt collector that operates 

lawfully. 

We also expanded our supervision program to include the larger credit reporting 

companies. Credit reports have a profound impact on people’s lives. Previously, 

these companies were not subject to any Federal supervision, and consumers often 

struggled to get errors resolved. In addition to our new supervision program, we 

began handling consumer complaints about credit reporting issues, all of which will 

open a clear window into the actual operations of these companies. As a result, the 

Bureau can now evaluate whether Federal consumer laws are being followed 

throughout the process, from credit origination through debt collection. By identifying problems and rooting them out early, we are working to minimize consumer 

harm. 

Our report also encompasses the Bureau’s first enforcement actions, which were 

against credit card companies that deceived and misled consumers. In some cases, 

the companies targeted economically vulnerable consumers with low credit scores 

and low credit limits. We were able to secure $425 million in relief for 6 million 

consumers, and we also imposed penalties on the companies to deter such activity 

in the future. These actions will serve as a warning signal for anyone who seeks 

to profit by deceiving or misleading consumers. 

In the second half of 2012, we also tackled issues in the market for private student loan debt, which currently totals about $150 billion. Our studies detailed the 

struggles students and recent graduates are experiencing in that market. Together 

with Education Secretary Arne Duncan, we made recommendations to Congress on 

commonsense reforms to ensure that the risky underwriting practices of the past 

are not repeated. 

The work I have discussed here today is merely a snapshot of our efforts on behalf 

of consumers. We also are addressing consumer complaints on a growing number 

of financial products and services, totaling more than 130,000 to date. We have 

adopted comprehensive new mortgage regulations banning irresponsible lending 

practices that helped bring about the recent financial crisis. Our Ability-to-Repay 

rule follows the simple principle that lenders should offer consumers mortgages they 

can afford to pay back. We have actively conducted outreach on various issues to 

older Americans, students, servicemembers, and others, and what we heard from 

them has guided the direction of our work. 

Each day, we take another step in pursuit of our vision to create a consumer financial marketplace where customers can see prices and risks up front and easily 

make product comparisons; in which no one can build a business model around unlawful practices; and that works well for individual consumers, responsible businesses, and the economy as a whole. We will continue to persist in this work and 

we appreciate your oversight. As always, I will be glad to answer your questions. 

Thank you. 

33 

RESPONSES TO WRITTEN QUESTIONS OF SENATOR CRAPO 

FROM RICHARD CORDRAY 

Q.1. At the hearing, you testified that the CFPB has many different mechanisms for collection of lending and credit data including: (1) purchasing data from vendors, (2) collecting data pursuant 

to examination and supervisory authority, (3) collecting data from 

the CFPB’s National Mortgage Database, and (4) collecting data 

from consumers’ submissions to the CFPB’s Consumer Complaint 

Database. Are there other ways that the CFPB collects data to 

compile its Big Data? 

A.1. The phrase ‘‘Big Data’’ is generally used to refer to the vast 

amounts of personally identifiable information that is available 

with respect to individual consumers as the result of modern technology. The Bureau is not involved in such ‘‘Big Data’’ collection. 

To the contrary, except with respect to complaints (where consumers must provide their identity in order to allow the complaint 

to be investigated), the Bureau generally does not obtain any personally identifiable information. Rather, we secure anonymized 

data to enable us to assess compliance with Federal consumer financial laws and risks to consumers in consumer financial markets. 

To date, the Bureau has received data through each of the channels you mention: purchasing data from vendors, collecting data 

from supervised entities, and gathering data as part of the consumer complaint process. The Bureau also collects publicly available datasets, such as Census demographics, that are relevant to 

the Bureau’s work. 

In some contexts, firms have voluntarily submitted data that the 

Bureau requested. For example, in connection with the Private Student Loan Report required by section 1077 of the Dodd-Frank Wall 

Street Reform and Consumer Financial Protection Act (Dodd-Frank 

Act), the Bureau met with major participants in the private student loan industry and offered them the opportunity to provide 

data on several of the 16 questions that Congress required the Bureau to answer by July 21, 2011. Nine lenders volunteered to provide their existing datasets to a single vendor that they selected. 

This vendor combined those data into a single database that did 

not include the identities of borrowers or lenders. This mechanism 

was an efficient way for the lenders and the Bureau to develop answers to Congress’ questions. 

Congress also authorized the Bureau, in Section 1022(c)(4) of the 

Dodd-Frank Act, to collect information regarding the organization, 

business conduct, markets, and activities of covered persons and 

service providers. The Dodd-Frank Act authorizes the Bureau to 

gather this information from a variety of sources and using various 

methods including surveys. Information gathered in this way from 

covered persons would be subject to the protections that the Bureau affords to confidential supervisory information. 

Q.2. At the end of the hearing, you stated that you would supply 

me with the legal analysis about the CPFB’s process for Big Data? 

Please provide any and all legal analyses undertaken by CFPB 

staff and outside counsel hired by the agency regarding its Big 

Data collection. 

34 

A.2. As stated above, the Bureau is not engaged in ‘‘Big Data’’ collection. Rather, we are undertaking targeted collections of generally anonymized data to further our statutory purposes. 

The Bureau has not retained outside counsel to analyze the 

issues about which you inquire but, as explained below, the Bureau’s staff has determined that we have the authority and indeed 

the obligation to gather and utilize data in order to do the work 

that Congress has directed us to perform. 

With respect to the market-monitoring activities that I discussed 

at the hearing, we believe that such information is essential for the 

Bureau to have a deep and thorough understanding of the markets 

we regulate. Congress recognized this by explicitly directing the 

Bureau to ‘‘monitor for risks to consumers in the offering or provision of consumer financial products or services, including developments in markets for such products or services.’’ 12 U.S.C. 

5512(c)(1). To carry out this directive, Congress authorized the Bureau to ‘‘gather and compile information from a variety of sources’’ 

including, without limitation, information obtained in the course of 

our supervisory work, consumer complaints, surveys of consumers 

and market participants, and review of available databases. 12 

U.S.C. 5512(c)(4)(B)(i). Congress also authorized the Bureau to require covered persons and service providers to provide information 

‘‘necessary for the Bureau to fulfill the monitoring, assessment, and 

reporting responsibilities imposed by Congress[,]’’ subject to the 

limitation that the Bureau may not use this authority ‘‘for purposes 

of gathering or analyzing the personally identifiable financial information of consumers.’’ 12 U.S.C. 5512(c)(4)(B)(ii), (C). 

Pursuant to 12 U.S.C. 5512(c)(6), the Bureau has published rules 

regarding the confidential treatment of information it collects pursuant to its various authorities, including its market-monitoring 

authorities. Under these rules, ‘‘information provided to the [Bureau] by a financial institution to enable the [Bureau] to monitor 

for risks to consumers in the offering or provision of consumer financial products or services’’ is included within the definition of 

‘‘confidential supervisory information.’’ 12 CFR 1070.2(i)(1)(iv). As 

with all confidential information of the Bureau, the internal dissemination of confidential supervisory information is limited to 

those employees to whose duties the information is relevant, and 

the external dissemination is strictly limited to certain specified instances. 12 CFR 1070.41(a). The Bureau’s rules permit the disclosure of materials derived from confidential supervisory information 

(e.g., reports to Congress), but only ‘‘to the extent that such materials do not identify, either directly or indirectly, any particular 

person to whom the confidential information pertains.’’ 12 CFR 

1070.41(c). The Bureau believes this limitation is consistent with 

Congress’ direction to ‘‘take steps to ensure that proprietary, personal, or confidential consumer information’’ protected from disclosure by law is not made public. 12 U.S.C. 5522(c)(8). 

In addition, the Bureau is subject to generally applicable laws 

governing its collection, use, and dissemination of personally identifiable information, such as the Privacy Act, 5 U.S.C. 552a. Among 

other things, the Privacy Act requires the Bureau to ‘‘maintain in 

its records only such information about an individual as is relevant 

and necessary to accomplish a purpose of the agency required to be 

35 

accomplished by statute or by executive order of the President,’’ 

and generally prohibits the maintenance of records describing how 

an individual exercises his or her rights under the First Amendment to the Constitution. 5 U.S.C. 552a(e)(1), (7). Pursuant to the 

Privacy Act, the Bureau has issued a System of Records Notice 

(SORN) that governs its collection and treatment of records in support of its market-monitoring function. See, System of Records Notice for CFPB.022—Market and Consumer Research Records, 77 

Fed. Reg. 67802 (Nov. 14, 2012). In this SORN, the Bureau makes 

clear that ‘‘[i]n most cases,’’ the records subject to this SORN ‘‘will 

not contain personal identifiers,’’ and that research and analysis 

will only be performed on de-identified data. Id. 

Q.3. Does the CFPB differentiate data it obtains through its supervisory authority from data collected vis-a-vis different authority, 

and if so, how? Are there internal firewalls for storing and using 

consumer data CFPB collects for supervisory, enforcement, research, and regulatory purposes? Can the CFPB use the Big Data 

it collects for multiple purposes? 

A.3. The Dodd-Frank Act tasks the Bureau with various missions 

that are distinct and yet interrelated in that information which the 

Bureau generates or obtains in fulfilling one of its missions, such 

as responding to consumer complaints, may be relevant to and inform the Bureau’s work in fulfilling its other missions, such as supervision and law enforcement. Generally, Bureau employees may 

use information that the Bureau generates or obtains to the extent 

that such use is relevant to the performance of their duties. The 

Bureau manages its data in accordance with the authorities under 

which it is collected and in compliance with applicable law, including the Bureau’s regulations on handling of confidential information, 12 CFR Part 1070. 

The Bureau does distinguish between different categories of information that it may generate or obtain. The Dodd-Frank Act and 

other statutes impose certain restrictions on the Bureau’s use of information, and those restrictions may depend on the nature and 

sources of the information. Furthermore, the Bureau’s regulations, 

at 12 CFR §1070.40 et seq., restrict the circumstances in which the 

Bureau may disseminate internally, share with other agencies, or 

disclose to the public certain categories of confidential information, 

including confidential supervisory information, confidential investigatory information, and consumer complaint information. To the 

extent that the Bureau obtains confidential information from other 

agencies, the Bureau’s agreements with such agencies may also restrict the Bureau’s use of the information. 

Q.4. In your testimony, you mentioned that the CFPB needed to 

undertake a Big Data collection to help for economic and statistical 

analyses for rulemakings. Can data collected under CFPB’s supervisory authority be used for rulemaking purposes related to the 

practices of the institutions being examined? 

A.4. The Bureau is authorized to examine and require reports of 

supervised institutions for several purposes, including assessing 

risks to consumers in the consumer financial marketplace. 

Accordingly, the Bureau utilizes supervisory information both to 

assess compliance with Federal consumer financial law and, when 

36 

appropriate, to assist the Bureau in research 12 U.S.C. 5514(b)(1), 

5515(b)(1), 5512(c)(4)(B). 

Q.5. Does the CFPB inform institutions being examined for supervisory purposes when data are collected for purposes unrelated to 

the exam? 

A.5. The Bureau has informed industry and the public at large that 

it does have authority to use its supervisory requests to obtain information to assess compliance with consumer financial laws, about 

the activities and compliance systems or procedures of supervised 

entities, and detect and assess risks to consumers and markets for 

consumer financial products. See, Dodd-Frank Act §§1024(b)(1) and 

1025(b)(1). The Bureau does not collect data that is unrelated to 

these purposes. 

Q.6. How does the CFPB plan to utilize the Big Data it collects in 

each of the following areas: (i) research and analysis, (ii) supervision, (iii) enforcement, and (iv) regulation? 

A.6. Congress has provided the Bureau with several tools for gathering information, including through examinations, civil investigative demands, publicly available sources, consumer complaints, and 

through the Section 1022(c)(4) authority discussed above. Data collected using one of these tools may be relevant to both the function 

for which it was collected and another related function. 

For example, one of the Bureau’s primary functions is to collect, 

investigate, and respond to consumer complaints. Although the Bureau receives complaints in the course of performing this function, 

the complaints, and the data derived from them, also support other 

Bureau functions, including, for example, its consumer education 

function and its supervisory and enforcement functions. Similarly, 

data the Bureau gathers in examining institutions for purposes of 

detecting risks to consumers and to consumer financial markets 

will also often help the Bureau fulfill Congress’ directive that it 

monitor the markets for risks to consumers. 

The Bureau utilizes the data it possesses for empirical analyses 

such as those included in our reports on private student loans 

(which relied entirely on anonymized data provided voluntarily to 

the Bureau by a number of lenders) and payday lending and deposit advance (which relied principally on data collected through 

supervisory exams). These analyses may include descriptive tabulations in addition to more formal econometric modeling, which together, support the Bureau’s mission to understand consumer financial markets; to monitor for risks to consumers in the offering 

or provision of consumer financial products or services; and more 

generally to follow developments in markets for such products or 

services. These data and analyses also support policy development, 

including rulemaking and any related considerations of the benefits, costs, and impact of particular rules. 

The Bureau utilizes data—including data gathered during examinations, consumer complaints, and publicly available data—to 

prioritize its supervisory activities and to examine institutions’ 

compliance with Federal consumer financial law, their compliance 

programs, and the risks their activities pose to consumers. The Bureau also uses information for enforcement purposes, such as asVerDate Nov 24 2008 11:00 Jun 14, 2013 Jkt 048080 PO 00000 Frm 00044 Fmt 6602 Sfmt 6602 L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-A
37 

sessing possible violations, evaluating the scope of consumer harm 

from such violations, and determining enforcement strategies. 

Q.7. If consumer data is used in future rulemakings, will the CFPB 

explain in the rule what data it used and how such Big Data improved its analysis and the rulemaking process? Will CFPB provide 

sufficient information and necessary data in future rulemakings to 

allow the public to reach the same conclusions as the Bureau 

through independent analysis? 

A.7. As an evidence-based agency, the Bureau seeks to gather data 

to inform the rulemaking process. Pursuant to the Administrative 

Procedure Act, the Bureau generally provides notice to the public 

regarding such data when it considers using them in notice-andcomment rulemaking. In some cases, confidential data are the best 

source of information on a given topic. In such cases, CFPB works 

to provide as much information to the public as possible, consistent 

with its obligations to maintain confidentiality. 

An example of our approach is the rulemaking to implement 

Dodd-Frank Act requirements concerning assessment of consumers’ 

ability to repay mortgage loans, where the Bureau received additional loan-level data including, debt-to-income ratio information, 

from the Federal Housing Finance Agency in the course of the rulemaking regarding performance of loans purchased or guaranteed 

by Freddie Mac and Fannie Mae. The Bureau then reopened the 

comment period to provide notice to the public of the new data, to 

seek comment on its use, and to seek additional data particularly 

regarding performance of loans held in portfolio. In the preamble 

to the final rule, the Bureau then explained the results of the data 

analysis and how it impacted the Bureau’s thinking about key 

issues in the rulemaking. 

Q.8. Will the Bureau make its consumer Big Data collection available to researchers, consumers or others, as it has with the information in the Consumer Complaint Database? What information 

regarding its Big Data, if any, will the CFPB make public, and 

when? 

A.8. The Dodd-Frank Act in some instances requires and in other 

instances authorizes the Bureau to make information public, to report it to Congress, or to share it with other agencies. Whenever 

the Bureau makes information public, reports it, or shares it with 

other agencies, the Bureau takes appropriate steps, consistent with 

applicable statutes, regulations, policies, and agreements, to protect any confidential information, including personally identifiable 

information in those rare instances in which the Bureau collects 

such information, confidential commercial information, supervisory 

information, law enforcement information, or confidential information that the Bureau has obtained from other agencies. 

Q.9. How many financial institutions have been asked to provide 

consumer data to the CFPB, and how many of them are currently 

doing so? How many customer accounts is the CFPB following on 

a monthly basis with respect to Big Data it collects from data purchased from vendors, data collect from supervisory requests and examinations, from the CFPB’s National Mortgage Database and 

38 

from the data furnished by consumers to the CFPB’s Consumer 

Complaint Database? 

A.9. Most of the data that the Bureau has gathered directly from 

institutions has been as part of the supervisory process. Information about the number of institutions from which the Bureau receives data through the exercise of its supervisory authority is confidential supervisory information. Information about the number of 

accounts about which the Bureau receives data through exercise of 

its supervisory authority is also confidential supervisory information. For the Bureau’s report on student loans, nine lenders voluntarily submitted data. The Bureau is not tracking individuals’ 

loans. 

Regarding ongoing data efforts, the National Mortgage Database 

is based upon a de-identified sample of 5 percent of mortgages in 

the United States. Similarly, the Bureau’s purchase of de-identified 

credit report data includes a sample of roughly 4 percent of consumers. These data are renewed monthly so changes in the market 

can be considered for research and policymaking and each update 

of the data is anonymous. 

Regarding data furnished by consumers when submitting complaints to the Bureau, the Bureau received approximately 91,000 

consumer complaints between January 1, 2012, and December 31, 

2012. In total since beginning to accept complaints on July 21, 

2011, the Bureau has received approximately 156,000 consumer 

complaints. A summary of the Bureau complaint process and related data can be found in the Bureau’s most recent Semi-Annual 

Report to Congress (available at http:// 

www.ConsumerFinance.gov/reports/semi-annual-report-2/). 

Q.10. At the hearing, you mentioned that the CFPB purchases data 

from Argus. Please name all of the outside, third-party vendors and 

contractors and their subcontractors used for the collection of Big 

Data. 

A.10. The Bureau does not purchase data from Argus but rather 

contracts with Argus to maintain data collected by the Bureau 

through its supervisory processes. 

The following other contractors (and subcontractors) are used for 

the collection of data by the Bureau: 

• Argus Information and Advisory Services LLC (Transunion is 

a subcontractor) 

• Blackbox Logic LLC (no subcontractors) 

• Clarity Services Inc. (Experian is a subcontractor) 

• Corelogic Information Solutions Inc. (no subcontractors) 

• Experian (no subcontractors) 

Q.11. How many pieces of information (data points) has the CFPB 

collected to date? How many pieces of information (data points) is 

the CFPB collecting on a monthly basis? 

A.11. The Bureau has purchased two commercially available 

datasets, widely used by regulators, investors, and other private 

entities, regarding mortgage loan performance. Those datasets contain fields that describe some of the basic characteristics of the 

39 

loan, and on a monthly basis, the performance of the loan. These 

data do not contain personally identifiable information. 

As part of the National Mortgage Database and the credit record 

procurement, the Bureau is obtaining all of the data elements collected by the credit bureaus with respect to the records in the 

panel other than elements that reveal PII such as name or address 

or social security number. Additional data elements will be appended to the NMDB from other data sources such as HMDA; the 

number of such data elements is still being developed. 

For the credit card database collected under our supervisory authority, we are collecting a subset of the data elements maintained 

by the participating issuers. These data do not contain personally 

identifiable information. 

Q.12. Currently, we are aware that the CFPB is collecting data on 

mortgages, home equity lines of credit, credit cards, checking accounts, overdrafts, student lending (private), student lending (Government), and deposit advances. What other areas does the CFPB 

collect, or plan to collect, consumer data? 

A.12. As noted, the CFPB collects data on mortgages and credit 

records; we have done one-time data collection with respect to other 

products (student loans, payday, and checking accounts). As part of 

our ongoing supervisory work, we will, in the normal course of examinations, collect data from individual institutions in order to assess compliance with consumer financial laws, obtain information 

about the activities and compliance systems or procedures, and detect and assess risks to consumers and markets for consumer financial products. 

Q.13. Is the data collected in the course of CFPB’s supervision duplicative or overlapping with data collected by the institutions’ prudential regulators. 

A.13. Sections 1024 and 1025 of the Dodd-Frank Act directs the 

Bureau to coordinate its supervisory activities with those conducted 

by the prudential regulators and the State bank regulatory authorities in order to minimize regulatory burden. The Dodd-Frank 

Act also requires the Bureau to use, to the extent possible, reports 

that have been provided or required to have been provided to a 

Federal or State agency and information that has been reported 

publicly (see, Section 1024(b); 1025(b)). 

The Bureau and the prudential regulators entered into a Memorandum of Understanding on Supervisory Coordination (MOU) on 

May 16, 2012, in order to facilitate this coordination of supervisory 

activities (available at http://files.ConsumerFinance.gov/f/ 

201206lCFPBlMOUlSupervisorylCoordination.pdf). Section 

IV of the MOU commits the Bureau and the prudential regulators, 

as part of the requirement that examination be conducted simultaneously; to sharing with each other any information requests sent 

to covered institutions relating to covered examinations. Section V 

reiterates the requirement of Section 1025 of the Dodd-Frank Act 

that the Bureau will, to the fullest extent possible, use reports pertaining to a covered institution that has been provided or required 

to have been provided to a Federal or State agency, and information that has been publicly reported. 

40 

The CFPB’s Supervision and Examination Manual (available at 

http://files.ConsumerFinance.gov/f/201210lcfpblsupervisionand-examination-manual-v2.pdf) explains how examiners are to 

scope examinations. In accordance with the requirements of the 

Dodd-Frank Act, the Manual directs examiners to gather as much 

information as possible from within the Bureau, other regulatory 

agencies, and third-party public sources. 

Q.14. Please provide copies of all contracts that the CFPB has with 

outside, third-party vendors and contractors and their subcontractors engaged in or involved in any capacity with the Bureau’s Big 

Data collection of consumer information. 

A.14. Attached are contract copies (and modifications) for the prime 

contractors identified in the response to Question 10. Copies of subcontracts are not available since those agreements are between the 

prime contractor and their subcontractor. 

• Argus Information and Advisory Services LLC (5 attachments) 

• Blackbox Logic LLC (7 attachments) 

• Clarity Services Inc. (4 attachments) 

• Corelogic Information Solutions Inc. (3 attachments) 

• Experian (4 attachments) 

Please be aware that the documents provided are contractual 

documents that may contain trade secrets and/or proprietary or 

confidential information of private entities. The companies should 

be consulted before any of this information is released publicly to 

avoid possible competitive harm to these private parties. 

41 

Argus Information and Advisory Services LLC 


AMENDMENT OF SOUClTATlONIMODIFICATION OF CONTRACT II. CONTRACT 10 COOf r~E ,PAGES 2 

2. AMENDMENTh.4OO1FICATIQN NO .1~.EFFECTtVEDATE 4. REOUlSITIONIPURCHASE REO. NO IS. PROJECT NO. (lfappic;ab/eJ 

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6. ISSUED BY CODE leFP 7. ADMINISTERED BY {ffotMr/han It9m 6) COOE leFPB 

CONSUMER FIN PROTECTION BUREAU CONSUMER FINAN PROTECTION BURE.A 

OFFICE OF PROCUREMENT OFFICE OF PROCUREMENT 

1700 G STREET, NW 1700 G STREET, NW 

WASHINGTON DC 20006- 4702 WASHINGTON DC 20552 

8. t(AME AND ADDRESS OF CONTRACTOR (No. ~. QlIIII/y, Slat. tOO ZlP Code) (x) 9A.AMENDMENT OF SOlICITATION NO. 

ARGUS INFORMATION AND ADVSY SRS LLC 

50 MAIN STREET 98. DATED (SEE fTEM 11) 

SUITE 1175 

WHITE PLAINS NY 10606- 1920 x lOA MOO\FICATlON OFCONTRACTIOROER NO. CFP- 12-C-0000I _ 

100. DATEO (SEE fTEM 13) 

COOE 078531295 I F ACIUTY CooE 03/13/2012 

11. TliIS ITEM ONLY APPUES TO AMENDMENTS Of SOUCITATlONS 

D Theaboverurbered solicitation IS amended as set foith m Item 14. The hour arxI date spetified for receipt ofOlfers D lSextended. D lSnDlel:lended 

Offers I!VJstac:knOYlledge receipl of this amendmenl priorlo Ihe hour and date specified il the solicitation or as amended,byone ofthefolowing melhod$: 8)8ycornpleWl~ 

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separate letter orielellrarll \\otich indudes a reierencelo Ihe soicitaijan and amendment ollTilers. FAILURE OF YOUR ACKNO'MEDGEMENT TO BE RECEIVED AT 

THE PlACE DESIGNATED FOR mE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESUlT IN REJECTION OF YOUR OFFER. Ifby 

lIi!\leofthls~youdesire\o ch!J1ge~cffetaireadysubmitted ,such changemay bemadebylelegramorletter ,JTO-Medeadltdegtllmorlet1ermakes 

refereoce 10 the scicitation and this ameodment. 8nd is received pria !othe opening h<:u and date speci!ied 

12. ACCOUNTING ANO APPROPRIATION DATA I" r8Q1Jired) 

See Schedule 

13. THIS ITEM ONLY APPUES TO MOOIFICATION OF CONTRACTSIOROERS. IT MODIfIES mE CONTRACTIORDER NO. AS DESCRIBED IN ITEM 14. 

~ A. ~8~~1~ ?::~: ISSUED PURSUANT TO: (SpocifyalllllorityJ THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT 

8. THE ABO\IE NUMBERED CONTRACT/OROER IS ~OOIFIED TO REFLECT THE ADMINISTRATIVE CHANGES(SiJdr as cliangesin payingoll'ice, ilpproptialKmdale, etc.) SET FORTH IN ITEM 14,PURSUANTTOTHEAUTHQRlTYOFFAR 43.103(b). 

C. THIS SUPPl.E~ENT AI. AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY Of 

D. OmER (Spedfytypeofmodificationandaulhority) 

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I •. DESCRIPTION OF AMENOMENTIMOOIRCATlQN (Orr}aniZfld by UCF secIion fINdings, ioclvding soIidtationlr:ontract subject malterwfttlll! feasible.) 

RMR Collection and Analysis of Credit Card Data 

1. The purpose of this modification is to change the COR identified within paragraph 7 , 1 

of this contract . Mr . O'Mealia is replacing Ms , Xiaoling Ang (who replaced Mark Egerman) . 

Attachment 1 to this modification provides a replacement page for page 19 of the contract , 

2 , Note : Modification 0002 exercised CLINs 1001 through 1010 , funded by line 0002 under 

Block 19 of the award SFl449. 

3 . No other term or condition is changed. 

Continued . 

158. CONTRACTORfQFFEROR 

NSN7540-01-1 52-8070 

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16C.OATE SIGNEO 

03/20/2013 
42 


REFERENCE NO OF OOCUlolEHI 8ErIG COIfIWEO 

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7.1 The ConirnclinS Officer'l Rcpru.rnl;l!i,e for Ibi! COOlracl is Mr. Scan O'Mca!ia, and 

em be reached ;l! 201435.7118. ~I _ Xiading Ang i! the ACOR, and can be TtOCM 81 

202,435.7686. 

7,2 PerlOnr.ancc of",,,,llr.I>01 be , u*ClIo lhc ""hnical dircrlioo of!be (OR idcnl ifled. 

or • '''f'<I'<cnlali,t dq;ignalcd m ",riling. The lerm "1Ccllnical di rrcli(:ll~ i!\Clod"" 

v.ithoull~il;l!ion. diroclion 10 tile Contrxlor lh;l! dirccl> or m.tircc1; Ibe 1300. eITort. 

>hills Ibe worl. bct",ccn v."<lrl. area! or Iocalion!, filk in delaik, and'or ()(/le .... is/: !CT>c.; 

10 m.ure Ihal ta;l.; ootlincd in lhe eon\f3C( an: accomp(i;1icd ;ali;faclOrily 

7.3 To: hnical dircclion IT ... 'I be ~' lbin the ~ Oflhc oonlllloCl. Technical dircclionlT.ay 

be 01111 01 in writing, The COR -<Mil oonfirm 0l1Il direclion in .. Tiling wilhin fi'e 

v.oo.dllyS, The COR docs IIOl M\C 8ulborily lO i!.sue technical dirccliOll Iba!: 

Cmolilulc.; I ellange or a<.~rnl 01 addilional "orl ool!idc lhe 

"C!I"" '-'; 

(on.lilulc.; a change a, defi ..,d in the d.I>Oe enlidcd "'Chang"""; 

C3U.\C.\ 3 c~se in tile Cootrxl price 0I1he lilT.c required forpcrlOnr.allCC: 

ChanS"" .ny of It.: lrnr.>, cMd ilioll';. or req";mr.rnll oflhe conlracl: 

(nlcrfcro; wilh It.: COOtrac\Ol'. riglt 10 pcrfonn undcr tile lenT., and cMdilion! 

ofthe c01llracl; OI 

Direct..., !'4"'"i!<'S, 01 OIhcrwi", oontrol. lhc ocliml or the Contrxlor'> 

crr.pIoyoo.. 

1.4 Th~ COIIII\leII)! >IIaI1 pro.'I'l'd ~plly ~' it h p!'I"f(ll1l'.lIIICe H'l'IJlling &om lhe I"dmi[!(ll 

dilCo:lion i~wed by iIle COR. If. in the opiniOll orille Cootractor. ally diroclion Oflbc 

COR. 01 designee, fa lls ",iill in tile lill'.ilalioo, in rmsrap/11.3 herein. It.: COOIraciOJ 

!IIa II immediately Jdify lbc OO!1 lll1oCling o/T,cer 1](} lale. iIlan II>:: bcgiroing of lhc nnl 

Go,c-mtr.cn l ,"-oil day 

7,5 h il"", M lhc CootrackM' and lhe conlracling om"", lo .gn:e lhal k'dlnic.1 dircc1ion i. 

within !be ~ or lhe conlraet .hall be '"~Co:I lO lhe 1(Tll'~ of the cia""" enlidcd 

"/Ji'put",." 
44 


AMENDMENT OF SOLICITATlONIMODlFICATION OF CONTRACT II. CONTRACT 10 CODE IP~E I PAGES 

1 2. AMEtDMENTlMOOlFICATlON NO. I~' EFFECTIVE DATE 4. REQU1SITIONIPURCHASE REO. NO 15. PROJECT NO. (Wapplicable) 

0004 See Block 16C 

6. ISSUED BY CODE Icrp 7. ADMINISTERED BY (ffotherlhafillem 6) CODE IcrPB 

CONSUMER FIN PRO'l'ECTION BUREAU CONSUMER FINAN PROTECTION BUREA 

OFF'rCE OF PROCURF..MENT OFFICE OF PROCUREMENT 

1700 G STREET, NW 1700 G STREET , NW 

WASHINGTON DC 20006-4702 WASHINGTON DC 20552 

8. ~E AND AOORESS OF CONTRACTOR (No.,.stm/, ooullfy, 51l1taand ZJPOJd!) (x) 9A. AMENDMENT OF SOUCIT AllON NO. 

ARGUS INFORMATION AND ADVSY SRS LLC 

50 MAIN STREET 98. DATED (SEE fTEM 11) 

SUITE 1175 

WHITE PLAINS NY 10606-1920 H)A MODIFICATION OF CONTRACTiORDER NO. 

X CFP-12-C-0000I 

108. DATED (SEE fTEM 13) 

COOE 078531295 I F ACIUTY CODE 03/1312012 

11. TH ITE .Ie:; Tu AMENDMtI'I...:! ~':It ::KJLK;1 , ... " u N::; 

D The above nulTbered soIici1aoon IS amended as set forth 1Il1iem 14. lhehoura!lddatespedfiedforrec:e.ploiOlfers D lSextenoe.:t D isnatexlended. 

OfferslTlJslackrowledQereceiptoithisamer'l:htlef1lpr'atothehou"a!ld4a1espedfiedin Itoesolidlation or as amended,by one of the following methods: (a)Byco~1"9 

Items 8 and 15, and relt,rning ___ copies of1he amendment (b) By aclmoY.1edging receipt rJlhis amendmenl on each COW of the otfer smmilted: or (e) By 

separate letter or lelegram v.tlid'I hdudes a re!erence to the solicitation alld amendment numbers. FAILURE Of YOUR ACKNQv.tEDGEMENT TO BE RECEMD AT 

THE PlACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER Ifby 

IIlrtue rllhis amendmen1l'Ou desire 10 chllf'lll!! an Offet already subrritted. $IJch charge may be made by1elegram orlet\ef, pro'<'ide<! each telegram Of IetIer makes reference 

to the solicitatiOn a"'Id this amendment. and is received prior 10 1he opening tlour and dale spedfied. 

12. ACCOUNTING AND APPROPRIATION DATA(lfrtquiffld) 

See Schedule 

13. THIS ITEM ONLY APPUES TO MODIFICAT1ON OF CONTRACTS/OfiDERS, IT MODiAES THE CONTRACT/ORDER NO. AS DESCRIBED IN IT£M 14. 

~ A ~g~~~ ~~E~~ ISSUED PURSUNfTTQ: (SpecifyaulhorilyJ THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT 

B. THE ASOVE NUMBERED CONTRACTK>RDER IS MODIFIEO TO REFLECT THE ADMINISTRATIVE CIWffiES(svch as c:JJangesin paying offlce, approprialion date, f!~} SET FORTH IN ITEM 14, PURSUANT TO THE A\JTHORiTY OF FAR 43.103(b). 

C. THIS SUPPlEMENTAl AGREEMENT IS ENTERED INTO URSUANT TO AUTHORI Y OF: 

E. IMPORTANT: Conlrador I!hsroi. O lSreqWredtoSlgflthlSdlXumenta"'ldretum oop!eStolhelSSUlr.golb. 

14. DESCRIPTION OF AA4ENDMENTIMQD1FICAT!0N (Organized by UCF section heacPngs, indu~ng so/ialalioM:onlfactsubjectmatter..mere feasble.) 

R."l.R Collection and Analysis of Credit Card Data 

1. The purpose of this modification is to change the COR identified within paragraph 7.1 

of this contract. Ms. Kirsten Ling is replacing Mr . 0' Mealia, Attactunent 1 to this 

modification provides a replacement page for page 19 of the contract. 

2. No other tern or candi bon is changed. 

Credit Card Vendor: NO 

Period of Performance: 03/15/2012 to 03/14/2017 

Exrept as pro.;ded herein, all lem1sa"'ld conditions ofthedoaJmerrt referenced in Ilem9AorlOA,asheretolorecltanged,remainsurx:halgeda"'ldinMlforc:ea ndelled. 

15A NAME AND TITLE OF SIGNER (Type or pfiflQ TinE OF CO 

158_ CONTRACTORIOFFEROR 
45 


CFr·'U4>JI' . .... ~""'( .... ~"'..J~s...-w;) 

~ 7'_'_ ~"""'~"'",,*"'(CN./OC»i_ 

!iI!_.A-.lO'-"";eow. .. ,.,... 

1,0 CONTRACTING OHICH'S npR~S~NTATlV~ (COR) I)~S GNATION AND 

AUTHORITY 

7.1 The Coolracting OlflCCT'! Rcprc!Cnlali,'e f'" Ih~ COO lracl is Mi. KiTSlcn Ling, and CM 

be ",ached 81 202.43'.7201 ~K Xiaoiing (Ling ling) Ang ~ Ihe ACOR, and can be 

readied 31201.435.1686. 

7,2 Pcrm03n<:C of,..",llr.I>01 be .\ubjcclro Ihc I«hnica l direrl"'" ofl(w, (OR idcnl if,ed. 

'" • rcprc<eruali,t dq;ignalcd m ,..riling. The lerm "1Ccllnical din:cli oo~ inclod"" 

",ithoull~ilation. diroclion 10 !be Contrxl'" lhal. direcl> <lr m.iirtt1! Ihe 1300. eITort. 

>hills Ihe worl. bct",<Cn ","<lrl. area! or location!, filk in delaik, and'or OOlerwisc !m':'; 

10 mourl' Ihal ta;l.; oollincd in Ihe eonlf3Cl an: occOll".pli;hc<J ;ali,faclOrily 

7.3 To:hnical direclion IT ... 'I be ""ilhin the ~ oflhe oonllllCl., Technical direction Ir.ay 

be oral 01 in ",Til,ng, The COR -<Mil oonfirm 0l1Il din:clion in .. Tiling within fi'e 

",oo.dllyS, The COR Qoo. not M,e 8ulborily 10 i!.iue lechnical din:clionlhat 

Cmoliwl':'; I change or a<.~rnl <lr addilional ""'. ool!idc 11K: 

"crr.cn'-'; 

(on,liwl.:.; a change", defi..,d in lhe oI ... ,e enlilled "Chang"'"; 

Cau.\C.\ 3 chMge in !be Coolf3Cl price '" lhe lilJ".c ~"ircd f",JlCTIOnr.allCC: 

Changes .ny oflhe lrnr.s. cMd itioll';. or n:qu imr.rnll oflhe Contracl: 

Inlerfero; ",ilh III: COOtradOl'. riglt 10 perform undcr !be lenT., and eMdilion; 

oflhecOIIlrac~ OI 

Din:ct.\ !up""i~ 01 or!J;:n.i", control' !he aclioo.l or lhe Con!nIClor\ 

crr.pioyoo.. 

1.4 Th~ COIlIr\lelI)! >I!aI1 pro.'I'l'd ~plly ""ilh p!'I"f(ll1l'.lIIICC H'l'IJltirog &om Ihc k'chni[!(ll 

direclion i~wed by the COR. If. in lhe opinion of the C001racl0f. ally diroclion Oflhc 

COR. '" designee, fall! ..-ithin!be lill'.ilalioo, in rmsrapil1J herein. III: COOIraclOl 

!hall immediately Jdify tbc con lracting off,cer JI(} lalcr Ihan II>:: beginning of the nnl 

Go,crnll'.cnl ,"'oil day 

7.5 hil"", M!he ContrackY and l(w, controcting om"", 10 agn:c lhal k'dlnical din:clion i, 

willl,n 11K: >C~ of lhe eonlraet .hall be 'u~cel 10 I(w, 1(Tll'~ of the cia""" entided 

"/Ji'put"" '" 
46 


SOUCIT.OOIiICOfjl1l.OCl1OltDf.l; __ II"" ,-- _ """ .. _a-.,," ........ CI1'-IG1GG-11-G~1 r: - no ,-- , .. Crf-ll"'-;"OOOQl F''''''''''''''''- ~~ I~I~J , ... 12_R_OQOGI ., 

1111/1011 

, -"""""- ~ ~--;;~ r""-- ~-- r"""'''''''''''''''' -".,"'" , .. - - " 

.. __ . """"""" .. .,- "" 0 __ 

W<S'Jt!E!< rlN l'flOTICTICII _ O_a-...-

---.. _ 

OITlCE or ~W!E."" 

0 __ 

--- _SUllO 

IJOO ~ snnr, , ... - 0"-"' __ 

~~.$lI~GmI oc 11)(l(l~-I1Gl 0_ .- --- - ... ,_$1\.0 

-- ,. 

"-"'-""-r-"'"" ""- "" ..... """. [J •• """",_ •• 

- ...... _- 0-- ........... ,.. --~ ~ o. ._. - S~, ~l~ _ 0 •• - • m 

SIZ Kr.Ii.l:lN m ~~L'!<U rllWl P""","!OII !o ..... 

:"" HUl<IN F?lCIl O~ PRro.!~"T 

1100 G mm .... 

rs-':~<)I"QO oc lell! 

,,- - 'mll'~ , .. """" .... _ .. -:IIoro/CrP 

- - AAG\IS 1"""""'-jO' A.." ~"'SY SR$ tLC E;I.Sll'CfP \.0 ""'" Sf ,n: 111~ b~I.SDICf' .• vtfl! )C 

WItt 'lA!~S If1 100100-1110 1'0 1m 1118 

CrnS<Il.Ti<U.S.GO'I' 

.~ W'I :mo6-lJ13 

...,.."""._._"" -- .. , .... _.- .. __ ,. __ .0.«< ....... """_ 

--- ~-

- • • • • • .- _.- - ~- - ~_COll.ct10n ".(j /,.,.11"''' of Cmit co'" ~.u 

to_~<!"9 I.fo, i'1'llllSro;M_1Oll_i)OOOI+{I1'IOlOOOO_1\ll_OGUOOO 

m-u-:m:xm<~ '=ux-x= 

,,04 of hrlo<N""' : Olll~17011 to Ol/lIn;>!} 

0,01 ••••• ,. 01 $.,,100 •. !ttl. lI .. «oo .• I,n 1,'CO.OO~.OO 

",,"i,,~ ",l,. ~ PO"~";>h. 1.0 10' ,ho .ch<dulo 

! ~;;Pl'11 .. "' !"vIO", , ... Pci .... 

o,.,i.,oI1 . 

.. 1«aIIIINI __ 

.... ------- "",,,.,, 

"''''''''''''...,..' .... ''''''''''* 

b""",:,,,,,,,_,,,,,,,,,,,,,,,,,,,,,,,~t..,.., .... ,,,,,,.>".N""'~''''_'"'''''''' _... [I_ ["I .... NOT"''''"'' 

O .... """""......"".,."""..-"'., ............ ''''~.N''.''''~= •• _ _"" a ... iJ."INOT_ 

b.OOI<_""' ... UUW_"'''''''''''''''''',,_ CI>'IE'w.....,""""-"""'""""_."'_"" ....... ........ M"' ..... ...,"""''''''''*--_ ""' ... _..., __ .... ''''''''.,.., ..... 

I 

• 

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- r~:"''' ''''- ' .... ·'''''''''''' .. ~'''''_: ... ""...,..,~g,-.-.. .... " ..... _.«Ur.UI .... romo. 

--""~ ..... 

""-"'''''',..." .......... ".". .... liE ~l""! 

- .. -.... "''''''''" 
47 


• --

ow, 

0 .. 

.. " 

_.-• 

.. ,tod 0: .. '/0 ...... """' OJ/II/lOU to ~llll/IOll 

PiU< optlo,. , .. , ~f CroOit Ca,d M . $trvl< ... 

""I< lino "",_.t." f.fI<il'9 ooly_ :.. ",,,grop.~ 

1.0:0: tn. Se!lo<t.ll. 01 kWH • • 0' .. "'1 ..... "~ 

Pd~ •. 

...., .. ,,: .l.!5~.COO_o.::ICp';,," 1.1"" 1\. 1 

_ "",1"" Y ... o[ Cre,lit Co,. )0.<0 50 ..... « •. 

Thi ' Hoc "" .. f." fuMing ""ly. ! •• pong"p' 

l.~ 10[ t.'lo !c,,"<lolo of ~H •• 0' .. ;viou . Ot>d 

Prj"" •. 

""" .. t: !l. OOO.OOCi.001CpUOIl .. I"" "",I 

"rlod o. 1'O:!0"",,",.: 03/1512011 to ~lfllllO!! 

T~"" Optlo" roo> <)! C,"~I' Cot'1l :.." S.",;ou . 

11.,. li"t trl"r ... fUlldlllq ""l~ . 50. J'I "9r>,,' 

1.0 10< tho ~' O<lo lo o. SuWI,o, 0' Sorvl ...... d 

P.,iod 01 1'Orlo,,",",,: Ol/llll ll <0 011111201< 

tou,""h Qp<lv,. , .. ' of Crtdit C<t'1l Do •• SC l V! .... 

Th!. ll"" "."1.,, fUM!oq only. So. por. ,<, pl'. 

1.0 lor ,h. s, . of !UfVli •• 0' So<oio ... &0<1 

"",,,1"004 . 

0- 0-'"' O~ 

"'-__ I"' 'm"":l"~_'-"'" 

~ ... "~ ... -

D-

" 

. ,,-..., .... "'''"'''"''''' ... I·· .. 

• --

O- 0-1 

Z of 116 

• -

,--, .. 

0. 

0 .. 

0.00 

.. 
48 


CQtlTllW.lIOH tHEE r I"'- r:-...... ll-C-O"'--~ (l(lO\ 

-"''''-''- NlGlJS lNIW ..... r'" I<:iD AilVSI '''' 1M: " - _. - '" ,("" .. '" 

/'-o""t, Il, 10~ ,O OO. OOI0!>'1w> !.In" It ... ) 

.,locl o! l',,!o=r.oo; ~lIHnOl> \0 ~)/l\llO!l 

~.''''l """""" of ... rd, SJj. OOO OO~.OD. 11>0 Hg" i,r, for !.hi. ,vm! is .hOlOll i n t.o.< 21 . 

---

, 

-~ -- '" " '" 

I 

, 

• 1m 

-

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""""'_ 

_.-.. ,... -,.""' ... '. 
49 


CI "I~~_"'~_u.t') 

~_'_"""''''''' __ '''''''o.IIc./Dlit 

.I&OI._-'~" 

1lliS 'AGE r.o.'TE.\11OSAlL Y LEFT BUNK 

'IO;M;IIII---
50 


m.!l~~_0001-''''",W) 

......... -.r_..._ ................... "CIoIOc..-ta_ sr IOll; __ ~,. 

TABLfOFOO~'iTS 

111 SOI£ru.!~Sl.Itl'Ul'SOItSUI'lC'£S,AIIlIhICE$ 

2.0 SU!owy~I'II:H3 .. 'i()OBuaATIII\S 

JlI PWwOfl'!JKaW.lU 

4.0 PAnm<rSClQu..i 

loG I!M:Us 

9.0 TlA.'\SPAIOCV 

6.0 (a.1"lACretGOmcD.(OO) IlesioNAl1O:' AND Al/IOOltTY 

1.0 COt-'TMrnS<l omw.', Rm£w,TAn'~(CO!l.) Df.sIa>Al1O!<AKl AtmIOm'r. 

8.0 COo'rucroI.!'IoJlcTM .. '1M8 

911 ~Alf.\l:f 

10.0 DocI.'I<l.'<T'S ND.IolAnD 

1.0 1IAc~ 

3.0 " ""'" Scaot: 

4.0 !J!.T41ll.ac1"1 

10 ,= 

6..11 (io'."El.'<lIt."f FL~'®IEDOO'aIxA1"J(l,', 1'lIlftm, .. 'oID 5a\'lCU 

7.0 S«wn" .. ~COSIlDElmWTT 

1..0 Pwo:Pw. [te.1m' VWt1o.llQI~Ca;n.ACTOlI'f.J.Q."loU 

9.0 COOrn!tflll(lMTII01"IIUO!tOllNILI1lCN 

10.0 R&.$SI(l6IE.'O" A~l) ~Tor OJmUC"TOJ PF.a$O!\.'"&. 

11.0 Cl"w-sB:IJlIT"IIITSI!ctImY 

12.0 M!U!fO!.l:S"'DDFu.UAL'iS 

lJ1I 1'm«lI .. ..a:~SulDwy 

1.0 f"'R,..m.~,QAlMS1~ .. m.llll'l R-.""D.&I(F"n 1995) 

2.0 FAR S1.212.S, C(I<IU(T TillIS "~ll COODITn.-$ REQI.Ilml TO ~T 

SrAI\ilUOIt EnamvtClltDos- ecw..VoOA\.ITOOi (IA.~ 2(12) 

H FAR S1117--9. OrnI:iNTO EnmIlmTml()"Tlc!Ct»nw:1 ~W: 200» 
51 


CfN~!/oIJo 

____ __ -""""'1J..Q ...... ..... "'" ...... _""-r-"" 

I: SMA!L-BuSlNFSS SU8('( .... rUCllNG Pw.II 

2: DATA M.I.IIAOO!E.\'fl'uN 

,: OATAQw.urlM.l.'IAOEI0!I'1'I..uI 

': fltlllDur«niN 

S: DATA IlIcrTotw.v 

6: ~uE,PlOm.l.'lJLCdSSTAlDIE''T 

1: 1df.Ast'W.~"~D~ 

I: REran Ev..t.!rw 

9; 1'fJ./rruI;.~1lJ;Q!.rIw(E.'Il1S\NlWY'tAiU 

II): 0l0A.'IZA\1OKAl.(;(:r;rUCT0I1~1rusro.!iC1.O:IUW brwM.\Tm SrATDI!:<f 

11: KFf~Llm/.l:l 
52 


O~_l l.c=I(N",""""' ooI _,_UCl 

c.a, ... _ r.-..,..... ...... ~ ... AooI)W"r-c./Doot 

1f"'~. ""_~l"P 

1.0 SCilEDULE Of SUPl'UES OR SERVICES, AND PRICES. 

" 

" 

I T01Al BASE?ERlOiI I 
53 


(7r·I~I(Atpo_"'~Ioo""LIQ 

~_r_ ............... IIont< ........ ,,(>o/Mr..I"'" 1fIUO, __ t'IIoIiIIrNM!..-
54 


m.1~,"". __ -''''''u.o c-. __ ..................... _ ...... ~CW/lolo 

5F1tIt, __ ~,.. 

, 

, 

" 

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55 


O?~""",_ .. -._\U') r __ ' ___ -... ...... .....,.I(o..c..tD.o 

.14<I, __ 1'P 

, 

, 
56 


m.I1C«J1I(A.... _ ... ~_1.I.C) 

........ _. __ .................... o:uN," .... ',"', ..... _C_ .... 

" 

II I C<tIUaIl:WiCW.rt.m<t>:>< ........ 
57 


m.~"""_ ~_ _ ............... "' ''"''''''''''1lQ ooI_"'~C..I_ 

Iil'lOO!; __ ~ .. 

,., 

, 

,., 

nl_ ........ -...... ..... 
58 


(JO.~"","_""'-_LI.Q """""'_r_.--.......... _.."...0.11~"'" ....... __ C-.. 

I TOTAlOm01HEllODJ I I~O$O,~I.O I 
59 


CJt.u.e-__ ... -,_\1Q ___ ........................ "00*c...11000 

.I .... __ ~"'" 
60 


m.>~

__ (.Oopo __ ~_1.1Q r __ ........................ ~~_ 

.. Iut, __ c-_ 
61 


ap.J~~-... -,-UQ c..-._r_.__ ........... -AooII*<fOI6t-t-.. "1 .. ,.~..,,""-~1'fI 

I TOTALornoN PDJOIH I U,loo,ooI.OO I 
62 


aN IAoJ-_"'-"_1I.t') 

~_~_"-_"",,"''''''f(C>.Itc.l,,,* If""' __ ~" 

""'"~ _~ro 

~ ro" ...... ~n 

. ,''''''"' ._. ~ ...... 0!'!l0N PUIOO I ~-. ,. CimO!I rulOD 2 --- ,- -""'" ...... ~ 

-....,. l>,ItO,eOo).(I(I ~ 

roM SlI,(OO,OOOtIO t.l,9Ol.(OO..OO 

1.0 P"..IOOOOF I'£lf()R.\lANCE. ik coann lii0i1 ..... ol.1IIIII>..-h __ jI<rioI! pol 

..... , singi<-ynropilll periods, to:\I;1IJ.CfI of 1211lO111ho .1cl, u fon""" 

e.,,....., 

..... 0pIia0 I'triot 

Soc:aod Option Period: 

full IJrtioo Paicd; 

f<W 0pIiDa Period: 

w .... ", 1011 _ Wardl14.101l 

Morel U, 2Gl l _ Mri I~ :111 4 

MmIIlS,lOI4 _M.dll4, 1015 

Mi:dllS, 2<115 - Maret 14. 2016 

~1S,!G16 ~IU0 7 

4.0 PAYMEh'SCHEDUU.l'lj--"obaU k....x;,,~wi'Ilm. ~ P.1 ..... An. 

(31 U,SC. J\IOl ~1Od Otf""ofMm>pr.allIlld Blllil'l(OMB) pt'OnptJllj-~ 

.SCFR I'Irt 1m. 

S,O INVOICES 1:r.'oi<u";11 bt h.oM!<d io~ willi 1Il.1'ror!ipI 1'0)- ACI (ll u.s.e. 

lllOJ) I0Il OC'IU of M~ n! BudB<I (OMB) IfOIIIIII JIIpnml"~ II 5 en I'IdlJ1S ik~""''''IIIi1'''''~JDm.lllU",~~ 

~,.... wiIIo a copy sut._ II) 11K: COlI. -.I ~ 0fIiRr I'll <-aaiI 

, Ed irtYoic< II.IbrUIed Ihall be ~ by '1'1"",,",'1< r!ornwnI~'M 

inrUdirw: 

I\a!Dr -.I ~ ofdlo c-..-. 

Lrvoi .. "':t 0IId number, 

4...,.,.,..~,lWiIaIo""""!>tra!..I;1Plaw..twCall_\ler; 

~ qalily, all oflllmQ, 1M ;:ncr • .,; meDded pm of Ibr 
63 


.-~"""_""""'Ja""'Ll.Cl r_f _____ ~-........ o(""'rn"'"' 

__ 

~. " ·Of Pm! oIt!ivmd; 

Sh.'pp:", ~urrt.r .00 rla!c ~ sNpmeol. i~h:dillllt;e biU of I ..... ,ombet IIId 

~ of IhipIIIW if oIIippod 01 Go.trnrr.d IIlI .c IAI!4 

T ..... of ..,c!iocoal.jlarpRllllpl poy.-o!IimI; 

Name nI am. of .retial .. ~'bo:a poymml illO be IaJ:; 

Ii ...... lide.1IId phcnc!llllllb!ro{ JI'I1OO" occify in ","-..,t 0{ &~ v..-oo«; 

TlIlIIYU likr::irx.a.. IUD: (I'DI). II.- OIly it ~ dIctrk1: .. tio 

' ......... 

EIe.."f!OI\ic fu1l4l II>!Iir ... (J:!T) bonbIl ;,uQl"..ttiOll: 

A. 110: c-.u IbaII iaclu& EfT IIIWc ~ 01 '" ~ 

oo/yit~""""'in!llilApnent 

B. If EFT Oaokir., itfC<lnaliOll if IIQII'tQ\Iftd 10 be OIl lK ht,-oi<e, ra: Iho 

"''''"'' 10 be • propa ia.o:o.. !he C«Iln<Ior d:lIJ .. , .. sub::oillll! 

am<I f.fT IIrarti!.: ~ II ItC<IIIIa:o .,jfI ~ ~ 

ICIticiGtiDI prIII __ dMe (..,_ Jlm.lJ, """" b)o 

EI«uoM FIIlW T~~", Cootnrror R.,~ "'1l.l)Z. 

,., " •• _ b)o Ei«:tNtac Fab ~ 7b CauwJ 

C_~~ ... ~.....,.~ 

C. EfT briiq ir.1ilm1liOll if IIQI rtqUiral itd',t f_ .. oi>«l .... 

'..,.....". ..... 10 pi)' by f.fT. 

6.11 OOHTRACTOOJ 0fFlCER (('0) ~""l1Clti A..'\D AlJTlIO!UTY. Tbo ~ 

0fIKc! fa" lilt mma iI Ms. F1io F. S\o'6~ ~bo.., be radocd ",. dtarooic mil: 

1'.lle.SIo_-.@;lj:hp. InII by ClIIIIIIItrciaI Idqol:<ne .: 101m.141l Tbo I 

0Ili0a, ill ~ wi1!o I'wt J"l1llK F«IenI ~ RqulO;e.. dltooly pmao 

~<O"""'If'II"I'I'".y 

~ 

........ ..,oflllo'-"''''.....a,ad .. y cl&-.o o:aUr.od dlCll"bett ill h COIIlrXI, 'lie aoid tlA:rily ....... 

lOkI)' "'Ill tho c~ OfF.ur. In !he rvtIl1 dot Contrao:lOI ...m III)' cN.llpI' at !he 

<I."IaitIo of,",! p<nOII .. IbIlbo ~ O/fut, die .:hqo 1II11l bt o;o;nidercd III 

"l"_I:IIo.ic~IIIIhIriIyIllli .. ~""be""io"_lDo:Ml-r 

ma-;., «*....,od •• rtroII domot. 
64 


(JI'-lX ____ _,-_ ... -._lI.CJ ....... 

...... r ... _o. 

!iI["" __ ... 

7.0 CONnAcrnIG OfFkl'.l'S KJ:PRE.SENTATM tcORJ D£SIO~TI<»I AI>D 

AUTHORITY. 

7.1. Tht~oou..'l ~ forlb_ is WI. Mm qa-."" 

c.. be!"flldlal by.1ecIr\Ini< mill!: MU\: ~p' .ad by ~ 

1e!e;.t..., :OH)). 1m. 

7.2. J>nfmnonco of..en "L* be ru&;ca 10 tho ",*.ical directicrI of1ll< COR idotti(ici 

Of. ~-IIM ~ ill lITiI'" Tho Ie!D ~ diroctioo" D:luo\os, 

... Iie ..... dftc1ioo.lII Ibo ~ ""' ...... IX Jtdioctu dx Iob."l tfbI, 

;~I!he won ~.m: .... 1111«.sions, filii io cl<u:'h.1IIdI1X <II!Imrioe_ 

:0 <min WI tQbtllllliMd iIIthr CaIlIft~ ..wf-nly. 

7J, 1rdmia1 diro::too ..... be 'I'ilhiI1ioo ""'PO of tho Ql;£troct. TooIo!licoI ~ l1li, 

be on! Of ;a 1I'ritio~ The COR WIt WJ1!I onl dirutioo .. "'"'"" ";1lIiD fi", 

....tdays. ThtCOR.4ca IlOl bl" • .uiIIOy lOiIIut IIdwiaoldietOcz:loa:: 

C~ I ~ of.~ Of~ WIl!l<o-.llicIotllo 

-

Consti:ut<! I dlqt. «fan ia Ibo ct.. eoIided~; 

CaIIfCI. dIonp ;. tho Call Jrior or !be IiMt requirtd for ptflomu.:t; 

a...",.,of ..... ....u-.or~ ........ of_CoI; 

lok::l"ifra tritb Iho Cowa:u:t-'I r',JlII III porlorm onder Ibo __ ~ 

oflhoCdl;1II' 

oncu. ""'""'" III' <dIonia «dI1III _ oaiooo of $!I< ~I 

.. -

1.4. TheC-.ur ... prouod p<aIO(IIIy WIo ~ ~ I'tan"*'-I 

~ iwcd bylho COR. If, III u.. opittifIl ollbo COIltrlOtOf,.IOY <irec:iOIl oft.f 

COR, ... desip«, fall/; .ifA !he ~.woo.. ia ~ 9.J I...-oi&, IK a..a-. 

"~:o>IifyIbo_~otr_"",""~~offl<oaI. 

C''''''.",....t.....tay. 

U. ~ai.~ oflhtC __ do: -..:a:.,offx:uIll .... U.1i!C:facal direau iI 

.

f1ithi. _. die JI:t"l'" of m. -.alhall be wbjoa to Ilw tmm of 1M d/.\I>O entitle;! 
65 


()r.~ __ "'_""",,,Ut:') 

"""-___ .... ~ ........ o..c..tllo<l 

Sl'l"" __ ~,,", 

I I The 0la1n<lol'J desipatd I'roje<I II'..I:IIlpI'IA«<:m! Rqnl"" ... h~ fro' lIoi,_ 

• 

Ale>; SWkaW;i 

3OUMaSmc!,sm: 1J7S 

WWI'!aa. ",.,. 10606. 

wIIo <.III 110 rett:hed by e!oarnoic: mail., 1IU~1cnnati0ll1XC. aod by 

<a:DIIfciaI ~., 91'-)01·; In. 

1.2 Tho Projccl M""""IAtalUN R<pJOItnwlve Wll bt mplll'ibt< fro' ttw ovenn 

~ aM c:ocrdiaIIioo of tb _ mol IbllI ad • 1U __ poiot of 

..... .;do t.:c.o-._ 1k I'!oj<ct~ ....... r.n...,..,.'" ad u 

!be Cootn<!\If ill die poriorrtwII:e of .... ~ .. ..mea. T1!t I'Io;.a ............. or • 

&e:cipalld ~ ... WlI ..... willi tlIc aJII. to diadw fn'b1enl1lUl .. Wy 

"",",.n.PR;ocI ~"",,,,-,~or~~WII 

l"fIOCIdll'itlia fourlloonll'lofui6<lra oflho<l~ of. ~ Tho Pn>;oa 

Mw,p' IlIaIi be.we 10 flll'lllly rud, Milt, ond ......... &afis/lllmgaage. 

9.0 111.ANSPARENCY. 111 CFi'II ;. dIdcM to -..,....:y IDII p-1ll1IIIliosl\'lila/:lo to Iho poabIic ofIe:....w. ttKk<1td for .. nd, 'Jt1« r.,. 'Irill ~ '" daiI, 

mil 1m l>Jsi!lClll doyI LUll Ihf dale tho BPA ond o&eb ClII is ... Ildod (txcl.li .. of 

~ s.adoys. aM f<dtnI WidoyI;~ • -.,ef a.-(or"'_) oflhf fully c:ua;:IId SPA 

IIIId C&lI-.iIb.1f'lI'ORd. """"""1' ~ ~ ~ ofq~'" _<3 or 

110)' CCIIlIIIl<l'tio or (......,;.1 informllion thll iI belic>'<O 10 be !liYi ieg«l or COIlfodtnful 

....... ilfor:Da:ioD, u w ... .- of public: ~ n. CdICIDI ~ 1O)<Orido • 

de!Iilnt.me. __ ~ Iho tu:. r.. CIdI of. JIfII90Ifd ~~h 

appI;;~1e uempIion IIrlO!cr Iho fm60m or w.. ..... Act (FO!A,~ S U.s.c. t 512, n. ill 

tio ~ of FOIA Emr.pa.. 4. l U.S.C. JlS2{bX.~ IIItIJ kmor.lllllo .... y II:< iofoln •• Uo.Ii, 

0II0Ii0IemI1O be • IlD _ or -..:ill III fllllD:ial iafOlll\lliol ~ is JWi>iltfcd III 

"",rlil«tioI.~~br""C_ia.....-"'doiI~OIIf~ 

be Il:bj«:l to ~ UIIda !he FOIA. The CFPIl ~,n oortfWIy <mIider all pIOpOS<d 

I«IKtiets 1rIIl..a...l pmds u ~ prior '" ..u:ioc I ral dmnaiOllioa. to 

..... iri:maIioo ;. dao I'u!lyfl«\OlOd do=Ieo& ....,. .. 1f"POIIy ~ 

-1------
66 


cor-'~(,lopo_"_$ooOoo;ua 

c-.'-_.....-~ __ ...... "c..c.a. ., .... .-_.c-... 

10.0 DOCt.i".l!ENTS &Okf'ORATID . .",. ~ ~ n hortIIr iao:apcnIcd icto, 

ood. NClo l pan Qr,l!li$ cor.l:lOlll:he AtlaCIwDen!I iccIict1od: 

ATTAOND'TS 

I: Sluu.-B<.ISI!>lSS~PIA~ 

2: D.u~MA.~'/'VJ! 

l" DATAQuAUrY~fA.'tOCfY.P..'<!Pu..'( 

II: K£Yf'wo:t;Hu.Um.~ 
67 


(7p.~IAqoo_ ... ....,._UC) c..-_,_ ..... 

"-

............ "o...on"'" ."",--~ .. 

nus PAGe OOS.vnONALL v tm BLANK 

l~ 

___ _ 
68 


~_""",_OOII-'_UQ 

CoIrioo, _ ___ ~"'"_~t:MItwo 

- ... -«~ 

1.0 B.ACKGRotND. 

1.1 0. My 21, lOin; ~ ca:.na oip;llbe Dodd,Front WOU :\hI1Um...or..! 

C __ I'rotcction Ad {Ad~ "hith crOIIe<l w Couwnor . 1DIIlriaI Pr..-.ioo 

8m... (mil). TIoc CFI'8 is mpXIIiblt b" ia:~ _ ~ fodm! 

_prQItcti<:ot_ TIocCFP8 .... ~Iqo~1IIIII ~ 

,",tit";",," 10 ...... _pIi .... wilh fodml """"""'"' \OW. 

Il ~ atd.'1 aid dM.o if....w by !be crPR "'....ua.c IIIIIbI_JIir 

KlIlfII Ibt <ttdiI <Ul! DUny, By atiti:zina • IU:Idn J<I of ua dtuonIo ai 

Wrnitior.l. -.l ~ can be dra~'I\ rtpI<ii:lg!be (tfdil ~ iBd\IsIty. nil 

d:Ila is ~ .or..! mp:r..! to "'I'\Q\ CfJ'B'1 ~ ...".._ 10 ___ 

_ prc!ldioaIm .. ~ 

IJ lIIodoJ lbt Ad IDd • ftdml_ r-.ciaIlawJ, w O PB illUI!oori:ad to 

c:oIIo:t. rautel ai ....... ~ m....10 lilt ~~.-bu I« 

~ rlllJl!lCiol ~ Tho,...n JI'Ipot<" oIl\1do nseardo O<timto is '" 

iolnrify hoIIo ,m to __ ...:l to ... r .... !he pmpor IunctioninJ 0(_ 

fiIID:irI ....t.u.. no.,. -m oaivUI will .... """"" doc 01'11', pnI 

.... .duy..pu., ........ lIIoI.,~.,-Urtflotl .. ~oflhl: 

",,!UtI. Fl.01btr, 11 die Aet a!Io mrJim 1M CfJ>B 10 iwc r<ptdl on "';0\11: 

~ ~....." ~ ~ plIICd ~ aa-a. .1U.t.o "1fP"'I 

-~reporU. 

1.4 t.oa&-lr\'.1 dill i$1iJt (rilical tnibllf in !he CfPB'1 elf"", 10 ~ 0IId ...!enllod 

__ bW_ >rJd lbo erN. god ~ ~d ~ 

prtr'ideo .... _&hi .... '""""""'" dqos in .. cmIi. cR ....ta. 1k 

iIlfOllllllion """ be .sed II> JJpp:Irl r....m. no r.... dIIr!t'..,f&, OIl< incm!d, IIId 

~ SID ;"fOllllllion ~ i., rWbut c.. be.., to<r<1lt bo>:!I ,"",",",' 

"'~"'~_d.ob""''''!ho ()1'8 ~b<Ollol __ 

u:dhoww W6U ... ruHmd~""""""", "'~pdlriobmKigorribloie 

bgb ~ • er .. \>3se ~;U ~ tht CF!'lIIO diaguoplO tbt dna ia order II> i0oi< 

.II mrli! .. 'Iilahiity ""..-P<f19. 
69 


aP-1)l:_"",,_.-._LLC) .... ___ ........ __ "....0.._""" _01.-.- 2.0 I'UlU'Osr,- Tho CFPB $Ods II> ~ Si..IppOIl \CIW:e:I f« !he ~1fcIiaI. ~, 

validlllio:t. &m.goILon, reporIio:1g. r.or~" 1M aaaI)"Si$ of I dislin.:l $tI ~I <mliI Of(! aU 

a:lwdti<ol poriodiAlly by IIld coIJ<dtd /rom r.iDo (9) cmam fedmlly rt~ bci;. 

(~y..Jared 11> .... "BakI"). The 1' ___ dllliuffi:fl is to.opplfl ill< 0111', 

-.lysirollhe mdit cord ioobIry. 

11 Tho C(IIIIIC'I<Jr ",11 be "'JIIind II> pI'7'iIie II!!Vi<fo b .... <OIIoaica, lra:il!Liaion. 

vdidalioli. onrtPIion. "";01. II«IF- om! w/)',il of =1 can! diu. m m. bWH' of tho 

aPR Cord Morkd Tua. The (."PB rcquiIn CcruncIof ul"Ilile iII...omllt .jlb luge 

-rJa bozII: .....,.... ill ropn!o 10 ,ilk J:.se"j wi)'IiI, be.~ .,(! riIII tqmin& 

iIr ~ <::l!dit ani 0IjIL!IInI. '!be <teM ani ... '"" .,11 c:oqlI:-s1I!ady ~ 

__ ameIIy c:oIlcaed by llIir6-pIIrIy ogrq;m for Iloo DIpnoaI 01 "'" T.'-i' 

Of!ico oflloo ComprroIIef III W CImrq (Ot'q. Tho ooc --.dy '*" ..... .u.. 

mdiI CII'd _from ... (9)01Il00 bqaI cndiI Old ... , 0IIl000I bd:IlIuccI .. a.ImI 

diu. tad dof.mti<n ... 1DOaIhly ItW. Tho a..w IboI provide IIw CFPB willi mdilconi taLa 

~ diffmnl fro:n Ihc bulb IhII comnlly pWVirlt aLa II> IIw occ. ThoI<rVic.;nckde, \I0Il 

"" ILQIlimitet 10: 

~ oIirecI ___ 10 lilt Ba!b 10 moi'oe daa ...,. _ ud .... 

.....-.vAo ..... 10 Lt.e0'l'll for frio< ~ dua opliIy: 

~ .. lObt-.l .. Cf1'II"""'""'IIIId.~II>I!Ic~ 

ol"f'Ol"lOD:lwlr.i<al~ 

u..u:.g tilt IedmiclI ~liIy b Ibe <bca ooIltcteJ from Ibe Sanb II> o.lbI.."td 

wi'" tho oa:.llId b lIitU'1inJ bD: daq Ihat ill p!OI'idId by Ibe OCC I""""'" 

\I) "" OX"""' M~ of ~ (MOO) btl ..... ilIo OCC ad 

0", 

~..,..a.iII .. IIF¢oaIDd ...... 1M 

pII>Oidiq • __ ...w...o ,mol _ IIfIQ ___ IpIq' ..,. "'I' 

JlI'II'f* ~ .x!iMI ~ <:lOCIIO ad·_ ...... eo! rltliac ...... 

LknrttINd. daq _ .... prt'iousIy u...iIwd dal. . _mi!:lJle~,., 

It.. -.b--bued JIIW!Il win b< xtUSo:d by ~ JltI:l'Y LI!C1 \I) "...dlx:I 

oogcing ~ ODd risk baMd wl,U 

,.1-'..-_ ...... 
70 


Of..".c-'V"P'--''''-._ ''C) r_f __ -'-_ "' .Cnitc.o"",, 

-.. -.-II Tb< eo._1bI!! ~ .. eIocIr<:ocio; i:lll!faoo ret fiJi .. <11 r,o!oooi<l of porioI.i;: 

rqlOIt. Itt credi! cord data. Tho ""IiI)' ond ",:iabilit1 of the duo l1l&I1 bo dIotUd .. 

pol! " ~ CoaInoIor'. aadtbe Olll'" data vaIidatioo p«x:cIMI. 

)J lk eoa ...... ...,. bo ~ by" Cl?B ...... cftdiI cord c!a coIlockd rlho 80nb wido 1diiIiomI......- co:a.. • diR<Iod by !lie ~ Oll"lm', 

R"I'f<I"'IMi~ (COlI} No otlMr ptnIIQtaI."trues wi Ul'llhe 'uIl:oriIy 10 rtqII'II 

...,.;c.., Of deli ....... :rndcr the_II> bo ...... '1Icd. 

).4 ........ crPB', ~ (lOt Of ... 01 lito ....me. Uc ........ Brio, .. 

a.rmal mM. 1lIIY bo rtpbtod by ..:<be< bank. I. ado QSo$, ~ dora 

coJ~ionl ""I' be ~ for lOJIOIIiq ~ods arlitt oJo/.., the _ ,ward dolo 

I"rotn Ihar. boob. 

)j AD efta Ce.racI«" • ..n ~ IdlleclIO ebo _ ....w Iri! \IdoIc ..... 

CffR All _~ nit, 0IId ..n paformod lor. _ O'PII .iD ...... 

coolidttlliol .. .II "' ooIy be dit:1oIod .iIh pri(M" wriuor: pamUsicn from the CfPB. 

Th< ec.- will pafi;n.olJ wort .. ill OQ f&ciOtios. 

4.1 Tho «edi, CIfd duo elt:r.em ddh,,~ons .... ~"btd ill ~ 4. A W 

dkIiooury~ tbedala I)'pn <l1be ,~, II .......:11 ~ if..-.ilJble it 

Al!Io:/II:ItS S. ~1tvoI.a-ia will K atbMtd III dIo CFi'B by ... apbIcoI 

~ .,.. .. IIICII:3Iy .......... r..x. i!to "'"""" ....6 CId (Ibt 

"AI <I 0...'"), 0. • OIOd!".Iy tow. lhertl,"',1lto a.ms 1to .. .",.;J !he bill <II)' of .... 

om IOOllI!t a!Ier Iho I""YiwlIlIOIlIlt" md III submit the <lilli- a. "Repatiq OMI." 

The BIIlb 011)" ~Ie Ihe diu r.. lito pmiouo t:lilIlIIt .., Iiat dmio& lito ~ 

..... AI Dl<ded.1hr s.b.,.,. ___ .. filios, ~ oflhcit _...,.;rd Of • 

.... ~oflheO'PB. 

4 2 The fM!rXIDIlhllliUbmi! p<l!folio-lcwI doI.I to !he CfP8 q\W!crty by tho montb 

..u... foIlo-aittt! tk c..c of 1M p.:hIit ttl.... ri dto 1I#.b' ~erly eartIlI:JI 

.-1M <Id":IiIioM .-I _ of ~ IIdricI .. <b:ribtd in 

Alrldt:tJmIs 4 !lid '" lk Catnaor .till dtIri, ,.mas. doll _ .. 01 .... 

cod forQ;!! IIXIIIIIt il lit qIII<I«. 

"1'"""'"-__ """"""'_ 
71 


,---_._----------, m-"-("_~_ _-.r __ ... _"'_U£) ~_ .. _.OoII(;M ... 

-.... -.-

S.O TASk$. Tho ~ ...-.&:\rg iii< ......." ,."p...I .-. 10 eo:ka, 

'WOP!<, ,.aIidate, 1tM, ,dn.\,UIlc! "'pori (10 dora .. 1in cIio:ussed ,.. .. iIl, Tho CouIr_', 

I) .... .a:J ... II'Iilal>k at rady .. ooIIoa, ~ nlido:o, .:m. mn... mil '<pOll 

eM <Old ..... ~ widoll:r ~ hcRm. .... _"'*" ...,.~.,. 

lfIa _ .. , .wU The COIItrIOtOt .. \OG ¢Icr tIId IIO:f data ........, idattifiod .. 

~ ~ IDd ~. 1Io1m IIpIII<piaIo. &lid "'D lhe ,no. app<I'a1 of !be COR. lilt 

c.n.::.:. IIIOJ" derM cnio iIcmI ;. .... 10 ....an _ 0di0iIi0u lad ....:-y 

OCIllA !be IWQ (e.I- ...... daily bolJoco, Tho: map;rin:a cJ m.i1 _" 10 I """" ..,:11. COIIInOa doEoilicc). AU _ ~ ":.11 k rtpOII<d by IboIIIIIIb -= wtiJ III aD 

"""-~'O'\Itioi!le~"'"""..."" .... ~.........,~ 

... dtIoud, Jddili<:nal au ........,. Of j>CtIfoIio IypCI .. y be oddeoil<l "" xopc: oi dIIIo 

<XII.Icniao III!! ,..t0ltti0n. A"'f Iddilioaal data ei_1Dd porJo:io !)'pel adGtd 10 IlK obtJ 

coIIenio:Jootd~.,.Ibo~oiIbtOOR. .. lI ... ~"_I!ot...,.oi .. "'l~ &lid i"dtdo.:! iQ ~ ~ fiud .m jfices. III ft< "'"'" .. OUt dofG_ 

IIItd '" be cUnt<d Of doll ,m-. need 10 be oddt<I, Ill< CFPB !III)' a>nsUlt with tbt 

CaIncIor, Ira fin&I oIctioio.. tie IIlf d<f.:iIa ~ .... ..u Il1o tll'B. As JIll' oiIM 

~ ~ !be Cr.tIInaoIIhatl (iIO'ido Tho: ~1l1llu i~ tho ,~ 

ICW.tIt ~ prO>'idtd (A1IXIIao:nI 6~ The em_ IiWl f(lliow lilt """"'11 • 

dQcriIIed II !M dolo dtfiIiIicaI and ""~. Tho COOL ...... *all pwvido or pcrfcnI 

-*>ollbr tI!b li!:cd below. 

HI ()l I OIClIIhIy It,,io. cal ltrt Ioon-IfflI ODd portfolio m<lit CIId 

..ma..cdoa. MIbo a..u """" .. .,;rior .......... 

5.1.2 Be "';Wl~ md r.acI)o to rmiw cilia ..",;n, 110 lat<I' iIwl <hilly 

~ ~ iIfIa' _ ..... Tho C-'. 1)0l<OI mo.lI! 

oeppIO ....... wifI die ... _ ... ;nMkd 10 .. oa: by .... 

boW. 'n.. do'.-Ihouk! be ,bI. to .... r;repttd u.d _«I '" • 

.... • t.a. noedod. 

HJ Rooeiw lIIODlhly ~h"" from 1hI: Borb !qin.mc Ihr firll" t\'<l)' 

-u h Ib< pmiou!-'>", d.:a. 

j. t.. DrI~k,:> cd U#)nblc tho IAA<:!W'td fOOl'l1I1 (q. rltlitnlltd 1<>1 ro"-l 

NrMllbelllililfdh ... ~_~m..m.1lIIIb 

"'Ien..------
72 


(:fP ~ ·~~_0011""-t_UCl ____ ............. __ "o..t;"Ir., 

-.. -,,~ 

H1 IlmIvo Illy 'oW ~ iIDeI of d=Ia haM ... fur.NI, 

MUmR. ~1DII qua/ityof .. dIIa rn.!he a..bbosod .. 

Iho 0l'B ~ III!! dIa 6dioiIioDI. 

5.1.1 Work ... illo dx IIriIlD adlieve data .. bmiaiuo~;" bolt<! .. 

..,. odCi!i<u, ~otaiow, lid dIrifJ;aioos to 1bc .............. 

~Of~"""'r"""""'hoylhoa.. 

n9 Wan: ,.;(, lht 11mb 10 f."i\J1It dill ruppq « II1nIfOfr:ll;Iion of 

t~!_liftc\t~"~to~oriir"" 

c-.-', daIa o;oDectioo ..... ad,...,...... 

5.J.!0 CoIkcI Cftdi om! dill !Mrn .... lIIII:or dispante iDforlJlllion 

oymr. bDr.! (00 Ib: Boob' iofc,r=-io:r J)'>ftIl 

lJ,llotuioOOR'f'IIIO"l! I(I,,,.rtIII\r:oissionof duahoy' zj,m 

bti, ad ~ dxlp;l!Ol'rir.e ""P~ ~ 1(1 ~fy 

Ill< = f:r lit rm:brroiAiolL 

nil AuisI ~ Brit wrdr d:e ~ .,.t .-moo m fi"" 

iII!mo.btely ""'" _ ... "ITd. 

nil wort ...... Barrb 10 oIoodop -1nte!I' 1Id]llla rL I<Iioo if 

ooIl~ nq'Jlled daIa ,Icr.<ra tb ... ,."........,. milIhIo b ... 

8m' <)"I'''', ThtCoou&Cll:t wiIJ Q(lt \It """,,~d« drul"""", 

IIlOdifJ'iol « rw.c >IlY do ~ nola! ia tho BW:s' I)'JICIIIl. 

1Iown .... Iho C-- l1:li JID6!y _ Cf1'9 rL A:Io f:.tiocI 

lhrw;l-rr,xwu oiaMS<d ia S«io:a ~.9. . 

5.1.14 Coli«! lid Io\-..qt ....,....10\'\1 cro:!il ""'"'" IIl:'itIWs b 

u)IAW d4lI....t,W ~ nt c.o.-n:w IIooI! bt """""" ... 
73 


ar-ac_ ..... _ .. -.-...UCI ~_,_ .......... ~ ..... _ ..... <f~~""" 

--,,-,,~ 

fa"~" ~ ~orlCOlll:ll Womauoa 10 .... ~ ... 

"",ill ,..,.-'1), mrnbers, I\.lI:'IU, ~ baol _1 rMl:bcn « 

0llIu ~ idomifi ..... ~ ",u be ~ UIIdof 1M 

Coan1ct. (Gioa: !he ~,~ __ 0( dIU -""";""_-kwI 

m.liI Io:rou 1It1l""'" 10 be co/IO<'Itd b\' 1ht C<n:ram WI be 

proMo:! ti JO'_~f","ishe<! ;"fCflNtioo .II ., .... of {OIIt".o<I 

-

5.2.1 TIlt eo-- 1lioii c...toa. ~ wri5aIioa pm:<U..,......:I_ 

be"'" 1Obnini ....... 10 tIot (''fPB. Tho: c..r_ ... aohcI tOo 

_ YalidaIiM promo r.ilhin ~ bo$,- OIY' 0( Iho reputjnl dMe. Tho 

eo--.dull nIidIIo !It ... ~ froaIlhe 80nb io _ 01 da:a 

.Iommi ~ ......... It!ti 01 ... ..... mol drfinil.- io 

AnathrnmlS 4 IrId ! mol ~ fodd ~ r.:I cmsninll. The 

C",*_ !NIl !ill III ... ~ """ dof.ni!ioDJ (~ 4 oad 5~ 

~ fidII,.;r- mol __ &d..,my,..;.. ___ 

\lldlll"" toIbwi",g;"r .. b"1ho l<1>li_ 0I1ile VIli<brioo Iq'OI1I: 

FoUI.fI*ik .... ~""* .... _ Ad ~ 

o( .. .;a nIid du; 

Idcruir.<I\ign of dlta!hac iI..,. rnilabJe f« ~g ~ <3=. 

"' OI!I ........... «ooIltewd; 

Edit doodr I<fIII'II 0I00ri1'yiq '" bHI"d ad porIfoIio ... tboI 

if """"pi 1M'« foiled; 

DIll !raid '"?'fIS 10. iftro>-ia.u.:. _In:i<<rI; ad 

DoIa~ity~IOfIYb s.l:~ 

5.2.2 The CoolS~ WI pWI'ido 1ht edil ad <lata twiY ftpMIlO tbo CFPB 

....... "'*-tIy$ oM .. rqronir:&"" n...a.., ;npas IIpCIIU 

<II .. r<mediaioo " odI mol dill. qQ/ity ..... NIl be ... _ ....tIr. 

\Ibm no r,~ 1>1 .. bco:a .. \Imi ~, the rtp<III slWl .. nect !!Iii foe:!. The 

~1ha!I; 
74 


(7I·I~""'_"AIooo!!_ua __ r ___ ~"_<lt;uIt(Jol""" 

-.. -.---

bc:x2.P ..o!yIiI-.ic$. 

1.~ til illirialill of edilW Uta q~lil)' rule! butd .. 1M 

eo.-', ~ or.:! ~ rho ..... 1il>!1 bo 

ioWopc:Iblo ";111 pRICCiiICS amIII!y in II< wid: aioIiac CJedit <:n 

o!.utolk<:rial ~ 

Mike r~ .. III rho CFPB for !bt ~ or 

~ c-..d odiC or.l <!ala qouJiIy l1li<$ booocI "" 1M 

C:--',UfICI1iIt MiI"'-1ocDod &-.... die s.b. 

• Sr:pp:rr It. .!diiim of ... -.r.td o6t II:d .... qua!iy NIls .. 

.. til .. 1M modifoioo. 0< ddttiQn of nUti.'Ig Nic:o. 

~ Illy -.lditicNI <dO: .-I 4u qmIi!y naIe$ )'II'(/"idcd by dIo 

CfJ1I "" ....... -. AllIWilo:mI raIa oItaI1 bo ~ 

ixo rho CaIncw', .,.-..;m. ......... " aflwlllo mp:Il 

OIIIII:eCfPB . 

......... Ul'J aiIIiq <diI rod '*' q'.oaIity me r- kilt ~', 

IJ'1IaII wiI:'>ioo .. u.... Nys.~. '"""* b:wrm'll 

froG !be m'I:\. 

I'rovidt • quarterly rqI(tIli$tin, 011 edillild data q~ilY IlIk$, ~Uido 

loa", bee; ~ dr...t (If ~ rror.w Qoah:Ior'. 

1IV111 .. wdI .. rho dao III kr iat;lk ........ .,.&5cMioo « 

"""" 

U) Tho Coon:IcI: au ",baIil:M lira ".wrIy rq:a1 of aU odi nI dill quIIily 

rdu 00'" rba Dry ~.,.....,.. _ Jtrri ~,!!Io 

~Iy rq:a1 sI'..aII be ... 01 II:c bo~ 0( tult ~ qIIWI'. n. 

Co:mcttr shall oti~", uy lft .... isUns boa ..... reillimstlipi 'illo rho &lib 

.. ordor 10 fxili:::IIt <!ala ~~. Tk ~ Ibal be 

....... fi:r ~ w COR <III)' oocaary .-diIIIoa <I r.iW 

~ «dill qa:ity rv!a. 

S.2.4 Tho Cormcttt .... 0 ""lII: "';:10 W. O'PB 10 01<1* !he dlII roIloctioro ..t 

*'II)u:aI doIU f« ..... oM ~ Itt aediI en -a baod .. 

dIo .f..ro. ,.....;.IaI by rho CFPB. no. Coan<:w .rba.'I ...... ..,.:n,. 

l-.nflCIIlioa IOId ...m ...-idI .. y I<qUI:ed , ... b:ni1liMo ill OIlIer 10 .... rho data 

,...ry f« Ibc g..-.eraPoo of ooaIyI1<II fq)(IfII or .w _ ...;n,in ~ 

"""-' .,.. Utc:c II< ... dole. t10r Ccu:X\OI" !WI ... r<p(IIr 
75 


t]'t.<K_IOI.o_IOII-, _LlQ 

_-._--. ......... _ ......... ~0.10""''''''' S..O...\._~_ 

~ ltaiwd .. ~ a. ,. drfad IIy Do.iIlra 4IDikd ..... ) 

-..i!hio fuW' I:uIi!icsI days if rer .. bmi.ions om.. ,ftcr me inm.l leD ;...;. ... 

.... n s Tho ~ WJI proviok. Da:l Qu.lity M~ P!Jn...tOm-..in 

~ 1he """","",!If Mich lh<...--fer Ilw. V~ al<I 

VaiIico!ioe ..... -'- o..rit tho -*'IoIocr fcr ......... qoMry 

...,.;~~ pro<m. Tho Dab QuaIii)' M~ I'll!! WlI dNcribt tilt 

iqI!cmm:,;jop InII ...u.:..-:. of IWIaIa:td vtIidoIiGn 0( the: AiL Tho 

c_.n dIo~"'''-bJ'..wcIo .. ~ .. o... VtIlduion !Cd Vtrlf"*",,,.on be mol iMo~,. Dab Qgt!"..,. M .......... 

PIa. T100 Ilw. ()IWiIy M..,....,t shill tho i"dlldc !be ~ nidi 

.;a ... a«'MdIO@lo~data......,..1Od IO_~ 

quality dInIIOI In'fII fer ,Jl *:i~ ~ ....... 10 tIC Dab 

q...Wy ~ PIao IhtIIIIc ",bmltliCllO tho OOR fer ~ JRr 10 

................ 

l.l.! Tho COllft:lcr Iho!! """"" tnd rnairto:. tile ~....w 10 """"""'" 

t!oo !lib • sa fIInh by .... I'trfomuate Wid Stacmall (PW ~ whirlI ~ 

COlfJIIioeolit doiI So:Iioo It.. ,. C_1t.IIl tdd bI:Q Ibo ~ CftOfl 

card <Ia!:a ... !lot bi!rJ::,rkai <tedit bI:ro.rJ 1t:'11ue! 10 Ibt OPB's J)1t0fll 

r<pOIitory "" !II<r thm tlUrty QIendor dlyI tfttr _ .ward. This 

pro;o.Iy aIIloctaI .. .."..pIN ok& (iIiIIooiaI atdiI CWII .. IIi\I cndit 

..... aIlMIa).,l be Jlftl"idal1O tU Coaru<tt!lf till COR...;u l1li 

QIm;!jr~)'I of (W'.tJCI lwald . Oov.nut:m:·fW'ltiJ/le(l tar""", ..... Tho 

eor.tr.:u IiIIII iI<:uporw ., __ tIIii hisIcrieoI ~ <d dati _ 

t!oo 0"PIr. oywa:J ~. Tht IIi!t<ri<II \!.Ill ir" IIh1m dtocdoed .. 

!be mil·, liM of <lola dtmw, ( ... At!aobrnw. 4 IIId '1 dmoS (rem I 

ItpIWIiq paiod ti Io&ry 2(I(l8 10 !ho ~ Tho ~ oediIl7.naol 

.. IIIriIcIa q frnco lilt m. ~ of ZG09 10 * j:ftOOd -..ill be 

pn!'1ded .. 00vcm!r,ml.!'wnW>ed 1Lf<n:OOon. The ..... hio:orical dolo 10 

~ by'" 8&bfer _-kod -.I ~-.J dol:! ~ 

~1_of~J11~of~~1pIICt 

IICfItt. Histori~ rnuilrnittod &II. reqllll<l an ~1011l! ~ ~ of 

~ disk ... -.. Tho pII'Ih .. of till mr Al«II!oly dati 
76 


CfP.'l<"_"""'_"'~_u.q 

~r_,-..-,."..,....,..... .............. "r..o.o""" -.. -.-

IIIIwrioed 10)' lie 8anb .eor.Ii:a ... SOl Wl>l .... cr! ~ ... 

II*" 1lQl1iO· ThoI)"lkIllIin:I,ooatJ:y dewLbld by all "'i'.."f ~ ill 

I!Ir 1'\\'5 .. 'Ril' 10 1M -...nc..l o;ndiI an obu. .. IIia<ricaI cndiI 

b.>r=1IC~itwt "' Wl."'Y"""" weo&.""ttd iI!bofut_ TbCcrm:tor 

IIl>II ..uia Ll "'.......,.. ao.d taII~ of tb< IJ.W;, f« td"t.'mOt 

.-

SJJ AI "-Ind IIIIiI ~-.J Ua • lid 10 all au ~ 

(;';h:sive of hillOrit&l d.~ dWt \.t 10 J...ary 2OCJ6, !I#'mt:Ul d&ta 

po"O'I"idod by "" CFf'B, !lid data pr<n"i6od by die BI:Us) .-• :cIIMI "'" 

the CcoIn<:Ior t«!l:o lif. oft!:e O(IOU3\I, All ",",,·IMI rod ;lOI1folio-itl-.1 daIa 

IDd.III doll ~ st.d IIoIniIIIIIt I"c:rlbo fit of"" -. ... "' .. io 

r'fIO"S, lid It« QIII!fioI ~ nlnctl • _n"be.! ~ IlIc I'WS. r....-

Ic>d ..... IIIIl biIIorio:aI brHoYd 11m from IpUiflC ItplIIilf ;oaiodI 

(tuhmisDocM ~ .......... ) cdlened..x. !be _ -...." .... 

quc:ies 0IId Wl"0CIl, 10 desI:ribtd lhrwPo-.II "" pws, lilly 110 arclIival, .. " 

WlI..c 110 ~ ... prior ""1M 1RfOI"I_1bc COL 

ill Tk c-..... ... ,..,.-idt ltJc ens nil. MIChel of III oIoIa(loc-leool 

IUbmissioao aad mubmis>iIQ, portfof .... lowI, 0:>;1 JQ.-qMns~ m~ of 

IIisI<ri:II daodWt; \.tloJa.y m,~"'""",~1I)'1Ioc 

am, IItId daIa r-illcd II)' Iht 8anb 01 "" md 01 !be ~ pcrlomua 

pcnod. no 01lO<I WlI 110 I'owido:d .. Ih: an io I ftIc for...r IIOIIIIIIy 

Ipl<d IIp3II "'" boIh Iht CooIncI« I'd .. CfP8. The ec..m.w All !Ie 

I"UpIIIibIt I'« ~ lOSiroinB W ~ 10 !lit Bri:>' poiDII of 

_(l\Ib ...... «IDf,...ao."II('j...n-.~f~.--. 

DI trUSllliu<ao. 

H4 Tho Co:!tI1o«or ,!un p<ovide I Da::o N"'a-:m l'iioi ([»!p) tboI d_ 

oli fa'C$ (Sf" CorIIrar;Ior', pIO<"<ISirIa II1II -. of a:J'8 d.oIa. T1w 1M' 

Wll ~hG: til< IIInf!! ociIcma ICId 6M:s ol !Ioc ksicaI ..cI jI/IyIlcoI 

Whooo IIIII<ItI, ~ til< so.. _ (or .... -..n b lbelOWolocl' 

lII0<I) 10 crnlC Iht 1IbIe.-vt. of Ebo c-xtof·,ln!aI"... oImbasc(,) 

f,.., lhiI.yIICtm. Tho c.mtta.:t:w IbaIJ .,.;"w" l1l<I Ff"O'"ido "I'l*< 10 >he o).tp 

..... ......,.."....''''-aae,.n.- dIqo. My ...... .... 

III Ibe D).tJI IbaII • Ilbmi:ud .. the CfPII ..;t/ti, It>.., bwi ... da)'l .titr 

IlIoCorllrar;lor~.I$~_""""""'«II<nF'--" 

Jllc...- ---
77 


CJ'P.!IC_ ..... _ .. -._,J.Q OO5ooIoo, ___ ~,.._ ..... ~r~"'" -,,-......... 

as If -.ltd u ~ P"'JII*&, ... 01'8 _ Ibo ... II> JIfOrido 

odditioaal <lag lIIihc CortInao< for II<nfO Ind indn10ll io ~ s..:h <III. 

JboIl bo IrmIItiIllod ill .I'onr:JI.ond -1I¥'l.."j by .. enB. 

5.16 nc ~ .bll oI>\oi:, cndit c.ro doto aoIlec1«1 ~ IIIr OCC &ocr. .. 

bWs IJI:! "-J>orolt iMo Iht r.fPB ')'>1m rQ:III'lriI)' .. y of tho _ 

ddiotd .. M a=ra', list ~ dou ~ (tee ~ ~ Ind Sj .. ....u 

.. ",",~.-.I.....!it Na.. ..... onrilMt.oo ffOll!" paicd btt-ma 

"' m."",)' 2008, This daIa IIIaII be oddtd 10 Iht CFPB', 1)1Wn rquilory '" 

1M .. any ..... doyI after _1WIrII mII.w be .. 1ilabIr, ... 

.-M .. aoIIecIIoIlIy tho~, forl* ill. ct'!a ~ irJcWod 

i/ltbePws. 

Ul Dolo ~~IndIJPPliq~ ~...tposlfoliooloto 

IIoIed OIl Ibo CfI'II Cndi Clod McIrica dolo oIc( .... _ .. lisa of da 

tltlnuts (A!IJCbmant 4 md j~ 

"..2 hffcnil\l ~ bad "" \!Ie Cll'8 CrtdiI Clod MmtI Dolo 

~~. 

14J 1I·..tq..nb IIIr ~ book ....... <laC riM Bri> u IIIr 

'3IIcpiClO ond "Ilid.atioo of <lata m.n IioP IIIlili<:K.up.I:C I)'s:l:nI. 

SA.4 ~1IId~1~_CIIbt(.jot~_· 

t.v.! cbtI coIlocIt.l from Ibo s.w. 

l.U The O"PS.., pnrridc ~~ "'" wIIido .... bf;-d 101l<_ 

Ind dlI> for "'1. ;'11>0 dar.o cobo(.~ ". doto <IIbt IiaIl iI>cIude (hd 001 

be lioIibIlOjlll <ima:siooI1IId ......... Iio.'t<l ill Ac.dmtt.t 1 ODd ~ 

prW.IC!ioII iUd1oo" ... Iliny ....... ".,.., -.:I a...t. The 

C«iIn<l<w s.ha]1_ ihI:I tbo du cobt(Ij .. l"odut;ti(o).lQdy '" k .. ibII 

tbi/I)' oalmdordo)'lU!rr«llll!1d .... n. 

H,6 0.. """,,"lybto.il, _,,"'ti dalaWU bfloldnl OQOihoollU ... bc(.)wiru 

lIOI-....iIoyI&ftcJIk~"'~. 

"10.-. __ • .... 
78 


m~ ___ .. -,_'\,(J ____ ............ _.o.IIlc..Dooo 

-,, -<{~ 

S.4.1 "!be Conua<Io< IIIalI be ~ ... ~ ... do co\Io(') "''' 

,esubmiUed looo-lt><l« ",wi_tal daiL P.odi", 'ffilmiu«! dina W!l \Ie 

Ioodcd iIII<Ilbt ..... aobc(.) by a dt.dir.e ~I)' 'lfl"'i ...... by bor.'I1!Ie 

CFr8 _:X~,!of; .... a.:ecd ........... r-..... of 

lfCOipIoflh! daa ffOll"" s.aa or Iht CFI'II. 

s.u Tbo t.o.uI::Icf sbII k ~ ... ....tif)-....... aD ~ atiotI « 

~."., ....... « .1Io< .... dIbtCl1S-.d 

7MdifiCll.KJnlIll&lI \Ie 'W1i<d in ' ..... f..". ",,,,,,,,II)' apd upon by bor.'IlIlt 

CFPB iii die CmIr_. Said !led;'" stall net 0l0CCIIl1llm IDIIIIIhI r_ 

.... dllr.ollb: ... ~ 1hoCOR. 

H.9 n. Cw\OOOr sbIll be ~ ... do=:.cnIi", Ind ''';'!llioi~ I ... of 

~-..-.:I~ .. iodIIde,_ .. I""Ie,-

mace.. .. 1bt lis!: of...tlcatd obIa daxao, ~ mil ....... ...., 

IOdon .. OIciIittm. ReponOtii",1i<q; f(O"J1I<Urrml.,...........:Idi ........ 

sbIll \Ie ,QilObIO ('I Ibt ~ 1"""'1 (Re oo:Iioa S.il) wiIhio th.:.ty 

ClkeoiII da.ys" _ ft"ri 

SJ TI.SK) ~. The Contractor """ FfOvide a 6of...moo <If I ,",-Ie!tpXI 

iIIqUI<. J\it ddirrJioo L'IooId. \Ie '*-'r ~ ill .. ~ OITatt·, 

..-

UI.I Thec....:.:wlballp;u'O"i60_ ......... _ .. I~ 

p.WI for ~ pnlli\l\l!ly dof....J repom, ., .d.t.:.: <rJ<I)' 

~ ani bu; cmaa.. T1oo...ta:" br prod:ICIioo-rudy .., 

...... "" _y ~.)"I afIp _...-ari Tho ~ lid 

be:....-aiblc .. CfPfI.~ pe:5OtL~ 110 ilia tbon lhiny cak:ndat 

ds)1 afI(! _.ward. 

B.lJ T.,. ~ ani ito ~ ~ o!IoIl" toqlUIc wi:h 

loIio:tooofI __ &pbu 1 a.I........ Tho wdac ....... 

JIIOCil!«I fIMiooaliy IiIIIl \Ie S«tiao SOl ~ •• tift" 

Jl lo... __ _ 
79 


(».u.c_,""",_".-y_w:) 

........ ~_"""""" ........ IOoNo< .. _"r..., .. """ -.. -.... --- ~~of_ ... ri 

S,jJ IlEi>onI«l CfPB SclcwJU E. .. ..o STM1IJ.IIPIZW REIuTI. {l.aP:II f.aQ\Ct 

I« ".. dcaab: !boll bo ¥ClIOII by, .m:I dIqcd >I 1110 "'fI'St .... !be rna. Tho 

~~_lhaIIbe~h .. """,~..,.,.,..) 

llJ.1 Tho c:o.ur- oIWI,..,.... doe r<pt'f(.)!tascd .. !be crPB CrrdiI 

c.~ ~~ O#t D<I'IruIicN. 

S.5.2.2 The CamrlCIIlI" shall )'IIIl"i<Lo SdriJle E (Alt&dI=:I6) 10 tilt 0'P8 

wiIIrio ..... __ <Ioy$ nib: ~ 00II for d" qoIIO!lf 

illto. SclIodod< E n:uII bo ~ inIo. MS I!1coI hal ba!e:I 

01 1110 crJ'II .-;. ~ ..! ,............ dqi<ud i:I 

~6for!be~0("'1IilIyQI;s.pi\ .... IaSt_-' _ daipd,.,.m. 

S.5.23 CFPS ~ E Wli bo ~mdy .., ial .. lhIII iiiTIl' 

~ dt)'J L'II:r _.-..d. Thr ...... oWl be '"""* 10. 

pinI .. dor-l(l\Ihe ..... '.1oc.I ~ 

lJ.2.4 The ~(J( shill bo ftSlIOO'ibio fer -"iq"idt 1h: CffllIO 

doI_ lip 10 .r.,. ~ rmrnq """" wnoplaec. fotmoI!cd 

• 6ef1tlal by doe CfPB. ~ r.....m.s roponir .. WII itcbII 

cndiI ani meIricL This ~ ~" WII irAiIido II • 

oma-: 

)- Pn!oiobc -' -...mi:Is doe ok6Mioa 0( I ..",.. ........ 

~ • I rUlimum, all IonnubI uotd to ~:t ..",.. 

__ doe dtf.Uoaooflho !aDJ( ) r<pMII:I<d; 

)- Idmtifying IIOd (\IIm;tirl.i poriodic (rnDIIlhly .. ~) rtpOII 

)-

-

P"roIiIi", lip \0 <!lin)' JqIOI'I templalOI 01 • """'""' buiI tor 

crtdiI ani db. ~ ~ ~ oID..,,:niq_the 

"'~ ~ _ • .o! ~ iItmplMo:I l1li)' be: 

aabsIiwd b IOCIdxr WIw~ rqoortS;.wI 

)- Ddi .. r~ perioIk.!ftd'« .... "" ... meordIo...t-,a. 
80 


m..u_"-_",,.....,_u.q 

___ .............. ~IoI_.o:>ooloCoolC- -.. -,,~ 

.. ~ JIONI (I« I«Iioa 'J.I)..-." ..... ~o! 

00:.II1(1 ron 

1.$2.6 TIle c--. IIIalI be ... ",""il* r.... dooilJllit.c, ~ IIId 

d~ Ibt <TMdrimJ "I""'t. W1tm. lei ~ ~ of 

roaivit4l ~ f«~ 0Iid1tpOrlJ r- ~ CfPB. 

SJ.21 00 I monIIIJ, -. ~ deployed. ~ ropons-.n be 

If''';,;cd 10 tho 01'8 ,,1thi::I lei buI:ocIs c.yo • ~ ~ 

o.:..~ ... curtP<s rL .. hI'IIII}' .... 1epo;! ~ lO t.. 

~ ~ &ad posItd CIa I lIIOahlylloo.io .. prO'rided ill 

~ l)AO ~ rq«I1 ~ by IhilCaWa!Ml be 

pruobcUoo md7 .. brcr ilia IE1)' dl;l Iller _ ... 'IId. A 

""",,", .. Jill of CIII'mI roporU ad dosipIwill Ie "",ido:d 01" tiI!IO 

ci _ I~-atd 1$ IO'tfDIr.<!ll·lIniIbed ;,,!or.natioo, 

S.H a.r MAL1'Sl'I 1l.ulc1, Tho c..m.:u abIII dndop lid dmOt I GAt 

1i\Il)'Sio rtpUI dtpktmg the .!tmoo:s Q!I !be ~ frOfII oodI 0{ Ihe 

&lib 110 IIIor .. tine Ir.oIiDcoo c.yo .. Ibo ~ ddt. no. Itp;r! 

sM!I ifo:hIde,. iI""'lUcilod IOtho f~ ..mo.; 

OAI icfomIoIioo r:I .. daIta ~ lid .... pr<I'riitooIloy I 

zj_ 8anI:; 

h!.ua,r of tIo! ..... r-idod by &/I afl!o: BriI boIh ilIdivD&lly 

... 

C«if<:nllity 

-

of "" 011\1 I<bInintd boial on 1110 CFPB Mm 

~1IId 

QualityIlf!!Oll ~ 10 tho ........ ufille ad:allril. 

~.S 4.1 Tho Qrmc\oo' sbII oM! ltId ~ ~ wille CfPa 

.. ala:!maI ~ """"" boial ... Ihoir e31~ ill !!OIl 

.. ,... ad ..Jj1R Tho crPB ........ 1110 ~ 10 haw :bo 

Contrxt« -.!aIU<ZO 1'- "JIIl'IS, .,..d ""ludo Of t<phct, "'iIIiIa 

IIIDd:rirc ~ ~ a da<ribed i:o So:uoo lJl, ~ 
81 


"""~(I.oroo_ooI""""'_lIt) 

c:.oo.._'--'-'~""'''"",,,,o.r..._ -"'-"',."... 

5-S .• .2 Tho c-.a.r IIIaIl ~.., daUIId >I!.II)'IiI ancl .....,. .. hut 

...- brCOR. 1\e ec..uam IbU x ~ for .... ~ 

~I orA dt;IJ~ Ndi~ ~ ~ die d<0W>d 

1III11)1is""" r<pIWII. ..e;" 1m ..... cbys ol...a.;., I reqont b 

<!MinI:.aid r<pC<Is fMn\ho COR, 

B.s.1 Thtt'ooD:la".!boIl 110 mpDIIDYo r.. ~ ............... ~ query c:apabil;\y via ~ .... ~ t.d pcrtJl &piDsI _Icvri arA 

JMXIfolio cruIil CIfII ........ """ diIpIIy • query redls bMd 011 .. 

",-...,ul$l io tbo '11"')', 

liD Tk 1IOi-IIo< quIIy tooIlIIoIl .......... llIli11crata i:'Ilht <lubaOI 

...:eordiog \0 ." nur.:brr of ptnmIlm., /Old 10 ..,1ec1 ""'" ,jota 

tl_ r-lht daI>bote t> iII:lcIk ill • mull OIl ..... ..-

for dill eI<:Dera u..II be .-fIItd i»' tbo OOR, "'" ~ 01 .. 

RqIIIOI of Ibt COR. Tho!og:al. (<< ~!tuoiooa IWDtIJ IhaII be 

rcqoim:I b _ .. fa acar.q oo!«1c qaerics. 

5-S-SJ Tho 1IOi-IIo< ~ i0oi Willlloor b ... 10 .w. tile raW of" 

..a. ..,.my ooJi,or. Tho od-f1ot 'I\II'l' IOdI obtl IllIw b' Ib 

do.1IIood ollb ........ it! 111 Iho """. local "'""'"'" io varioos ftle 

__ (t.&-l dolillil;Qd 1\10, Mict'*I!I f=t« $AS). 

S.li' 1'« I>rp """IS -.bitt ~ "" Jtoob lit 1111 .... __ 

_ 101 be pmOlllllllC< pIQI1i1ili.., lht c.:.- WII pnMdo 

thtn!IIi>'t mtdIodo for fI1l11krrm& Ibo <bIt..",.my III !be CFPD r<." 

':!iIq __ r.~Ji'«l'<OI.~ bft .m.~ 

s.s.s.s The o.rxa:r. .... NimIIf)' """ Idha .. MInCtiooa ~ .. ill 

..mca..Mrtpld IO~""";" 

5.$J.6111o »11« qutlYlDOI f~ lI:aII lot ~~ Ioott 

than lbinyuletldar 01<)1 aller _, oW>;Ji 
82 


m~ ...... _ .. _-.U,Q ~ __ .............................. "o.c_"", -,,-,,-

S.i6.1 T\oC_.a.Jlhe:'"'P'*IOk 1or~ _ ...... <IIIa 

II!aIysj$ fOol • I en." md ioIa&ct to fl,. ~ dolo 

<Ubo(,~ The wi) ... tool II1&!! .no.. !he • ..,.\0 <rut. pi"" 1I\l~ 

!oaod 011 all e-..ioaI -' IIIWII/U ... ..w, Ilol o.J: _"" Ie, 

Ibooe SIIed " ArIdnI«.I1. Tht.."..10<11 1bII ....... _1O 

cIoWDloo4!be 1m lilt 10 UIa"', local ......... ill .. If I ",ioi"""", 

Wicroooft Emf ror- n.. oaI)>il1OOI rbJIllWOft, II ......... 

~.-.I (JIll! ~ lIMn, -' "*' obo ..... b 

&CdiriorII1 uom ....... ltdbydlcCOR, 

~.6.11k C_ shall he: ~ IiII r.a., 1bo...t)U \I:d IIIIIh: 

WIderI)iq dill. tubo(l) 10 IU<l Jnell of filrIctionI.l perfonr.ar.u 

doemrd ~ b)'1bo 0'PiI. Tho .... >ysio I0OI fDaiowlI, okail 

he: ~ "*'r 10 ...... lUll rhirfy <IIcaIa:- .,..* «ancI 

.",vi!. 

M,l Thc c...n:ur oW. he: ItS;ICQIibIc b- omoaina 1M cS.!i..n" __ 1M! ODd 

~ lM>I< du by _III • ....-.prirk ftIo f<n:II! ( ..... doIirrita:eoI flo 

type, MicrnsofI &\:CI, SAS) 10 lhe CFPB. Tho woo s.'IIll il2d'Jd< .. Iid.a:ed 

cmliIard mtVQ 1o&IoYd -Vor pMfclic dIIo. 

l.6,1 Thc Contrxvx Wli won: r.'iIIlbo CFPB 10 cS.r,x Ih: prrlomol_1IfIIIod 

b do~WfY III doe dct ( .... ~ ........ (,10 ttWftt prococoI, f/lt<)1*d 

lr.d.m..~ 

S,6j TbC_WlIhe:'~(or .. tr.ocUnt:lhecmbM!CClIhtIP«ir.: 

OIl ....... dtIa 'I""Y:.qotI!I by cb< Cfl'B. (i.t., '""*" ~ or 

f'OIII"oIic>"'trotticrM~ 

s.6.4 Thc Codntt:n '>~ ., 10M ta 01III:I ...... 10 IlIOOI Iboc 

I.q"u~ "" lew IIla:J I!!irtyulcrrdc 6/yI dkr_ P1Irll 
83 


--------------, 

tnl~ ___ """_ ... ~_LU.l .................. _ ..... ~Cft _ 

_ 1.,_ ... ......-

ill The C __ "'-'lll">'* filii or pGaI" t>:1nI:I$ of ~_ 

"II"" r<qIIOSI &"'" 0)1 t .. CFP\I, 

5.6.6 ~ dat& \'111""' IbaIl Ix It .. 00 w. ooe 1o.:I.i..,. day Jfw I rtqI>!II 

;,y9w01'B. 

H.7 Dau. wnm..n:tl mlO be fM<t:1ed ao l ..mlyklilWllbtplll'l"idld II 

!he CfJ'9"-twd", lI=Iea a)$afu:r" hponiltc IUo. 

5.7.1 Tht a...-1ioaI1 be ~0Ie M proridi:f: 1oQ:icrI_ ~ 

~ MoDdays ~ Ifil&ys, &.., - 5p111 ESl". The Caon:torsNJl be 

rnr-o)k kr ~ ........mrK.1D Ibt CfI'8.;e;"llmIIy '-'-' iii 

Ibt IIIitioI ~ call (,.., dIr CFl'B to 1be CooItlCt«, 

5.71 1\0 c.n.w: .wi p!OriIIo Ibt ~ _ mca...u.. Iilr Caottac1or 

SJ.3 

--

n.. C ...... _ shall lit prtpir.o!<) ~ ~ ao:l anaI)lica1 WppOI1 

~lbtdlyof_-.d. 

l!1 ThoCoou..:wlUllbe r<SpJQ>ible ro. J!K"idilll .ltllerr.i_tlOper[<UI 

~~ forlbt<ml.- rderao:od iI dois,.,.... iJ 

n1ito~ 

SJJ n.. CaIIr-. DIll dr-'Ckp,'" Maoit 10 d>c CfPB for IWO> .... Teu 

PI .. , "I~ dotaik lilt procq for, lad fadlilalioo iii II:UpIIO« """" " 

Gl'B ._ .. fmooed~. ToriaWll:.dude, ...... 1iamed 

10, ta""' and IIXfPIIDC< of l'" ioll...'"" ....s Ik:q ..nt. I ~ 

odIotIdt fot fd. 1I,1IQ ~ W fet! Plat ~ IOIi<:i: Ibt 

~ IIICFPB ~ io lht ~ ItSIiolpro<eM ( .... 1<11;,,( 

of~"P""'~F<I"CfP8"'-' .. r.muiJ-.IolI: 
84 


m.11 

___ __ (.\.t>I_ .. ~_1.I.C) .--.~ ___ «~r~""" 

-.,-"..--

Gap"", roporI .. do$cn1lod .. Sectiao BJ; 

M-hoc: quaies Ind ~ .. d_ibed ill SecIico'I,IJ.l: 

AwPt<d DIII.o ~.;.;., s..:ttao 5J.6;..cI 

o.._ .. <In<IiIcd it Su:tioa 16. 

n. C<rnttw sbolI r.a!Ur ......... lCIII:Il.tn..p I!Io ~ 

ofdxloslplla. 

s.u 1\0 c...ncu IhI!l r.dop ..... ~ ~ f« Iho <)'IIOIIL Tho 

Clicltacto" rIIall b< Iap(IIIlbk: '" ddivery of I 1)1ICm usa IIIIuaI Ind 

~ "'"'-_ ...abiItOOyQlealar "",of _ ... tnI. 

s.u 1110 Ca!nacr IIIa!I prvridt nil .. GIl .... __ ao!ioo: ~ _ 

que!)'ioIc ca9'bilirMi ill ~ trlh !he ttmq pion. Up 10 1tI1 ~ 

...... oW: b< pcrlO:m<d. two 01 __ of I!Io cmI TIlioiot: r-n 

k:alIII io W~ DC. TIe c..n:a IhaU be IftfIDd 10 boP 

~S uUri",1tSIiooa lID IoII-r Wn m!yUyi"""_ D'IrII. E.uct 

docnfcr iniW aesa.:,) IIIoil b< If'IW"<d "" .. Cl'PB ma Qll1rlCl...n. 

5.9.1 Rt~.,;m!be ~ Tbo c-lIIoJl:ob. <lIiIab<ncM 

~ _iIII d.. CFPB lad the BaI ill ~ dill ........... 

oailUQ;e. Tbo ~ !hall ~ die 0'l'8 won.;"r-..! of ~ 

oai ..... tioodioa __ 10 .fadIUt- npid ......aioII" Illy JRblao< ... 

i_lhllmay_ist. ThoComn.crorIbllb< ~ r..~.!os 

of my --. lope! MOl clooed) Uic:h ... w... .. -iIII c:do ol1be Boob. Tho 

CO!IIrIlClOl" l1l1I1 prmridt tht CfPB ~ • UfI<bt«I C<Ip)' of !Ix 10, II !tOIl 

.. ..,., ....t. n. c:..r.r.a.r .. ~ -' ~. d/J_ 

"",iomoc:t <l1li •• liM --''1 ~ bee_...., !he COIIIrI<lor IDllIbo 

CFl'8 III ~ JIIIltmi oflbt petf<nDm:t ~ >:IMir..d, Iho 6:11 

of .t.idl .!hall tie Iorlil "" !oIa- m.. "'"C!I .... .;.yo .tIOt Ibo .. of 

_ ,WIld. The 0l'Il , ....... tlIt riglll to <IIqo .... ~ _ 

oca:mxt ofw. 0!IIIfam<r <Ill n. (.U -il_fr'" Coonct:r- • leal 

to."M)' ElM w. ;., ..tva.« of IDY do:. chID&< and "'""" (11<00 .. dIys ill 

od> .. ol..y<brgft .. . 
85 


<»'IC_ 

_____ .... _ ... ~"--'lJ.Cl ............... ~c.o_ 

...... ,,-,,-

H.2 ~ n.c..-lWlplO'lldllhtoteeU)'_lOtlToW.tIr 

.:ctpe clata Il1nifm f,OID Ihc BInb; pmid. ~ to .... 8Irlb II'llI r.pj)QI'T 

~ ..,... .. rt;w:niq: >IMm .. bdIaIf of Ibo CFPB • ~ 

.. !be PWs. 

S-9J DtclI;ioo M.U:iQg, The ~ .... mall obWo CFPB "1"'1 lad II'PfOI~1 "" 

pro;.tt acIl,m.oallimelQs. The eon.:- ~ I'fV"dc .. CfPB .1lll 

,00 ' .... - ODd oi!uiro CI'I'IIlf'P<O'"al prior to ,wq ttqIlO!b of !be 

,"" 

5.~.~ M~ Rop«Il. on. c~ obo~1 bo ,tSPJrIIibIt b .....u". 

............. .-I1<Iia ho.M .. 0IfCiDp Wd .... 1M ~ 

!>I.nkilc illUuiou ~ 10 daIa '!""lily, ~ "';ficoIion .. 

~ .. 4*ifi<d b7 lbo CTP9 """,..,.a 1M mtcnr.Iioo to doe 

CfPB.~ of .. wcftJy 1<p:WI. ThU rtpOI1 oboIl irId..:lo I brief-rof 

!be mctIin&. pWcipoMo, ~ IIId daI< n. oflht 1IICOIio. 

S.9.\ Frojea pic. The Coattxtor ohatI proYidc I ~ PI. idco:i~ k<y 

~_~ .... fa-eodon:quiraDM. lklloal ........... 

",,!IIOf1hao1tl! bo:si_doj'lJJltr_","",-

H.6 SIItUI Rcpora. The Coaznc:w obo.lI proYidc ...uy "1i!!al ..... repom <0 

!bc COR. Tho! rtpor!" 1..mu......lhIIl 0II0Iist of: 

UpUtrs tothe I'ro;ut PI.; 

P«f--. ........ ocmpIrIot 

Prir.r=cc~ ",Joe aditt!oooI_lhe..., poriod; 

laoo ... risb MllNllldi"l performaoce ttqui.~ .".J OliO"",", 

SIIaqieI per ~ bMk; 

J-. ~cm IIIiaact; 

Crilieal dtflciencia di"",·md to &" ~, eacI> of Ihc s.m.. MOl if 

prtlinmily--.l: 

Ptcjcdot!ima; 

T"".clion; ond 

SiotIII 0('" dill w"tCJil,." iolhe r:acWoo ofdill_ 
86 


""l~""", ____ ~ 

_ __ ..... _~ __ "o.aCW'"" 

-.. -,,-

7.0 SECVRm' ANDCONFIDfN11AUTY. 

7.! ~l.O'" The C-~ t., .. pe:bmief ... ~ !Ie 

(.-...or !III)" o!Juio _ 10 ............, ~ ~ !'as<Iull,o 

Jdenti("b\o Infwmatioo (PH). or ~ w.....m.a. n.. ~ ..-1iIa! i, 

i!I~"~"'iIo""'~IICI~ ... willOOIdUdooolc_r 

It~ psrty . .. othaWIIC \ISO Illy ;,fonDa1ica j( obIznI or I"\*ft ;, !!Ie _ « 

~«_yc.lt """" lilt IIPA wiIhoooI (n Tf<>IMor~ ~ rtho: CFPB. ltlfmllMion ""';nd b)' tho Cultractor ~( 10 tilt ~ «11:1 

ColI'" lilt 81A oW ... lot diIdoac! b)' lilt Coon<Irf I> Glhon 0IIIIiIk lbo 

oppI<I>lol CO'IUIC!Of , .... ...",.,.,. &rod tbe O'I'U~!hI stall" wiItou! pMr .1i:teo 

~to,-lIItCOl. 

1.2.1 All ComI<!Of pcn<aId or Jff/ ~ "lht CouxIor poiormi:rc 

.......... A~..,<:lIt!irc~~r.:ilil)' ...... _ t·[....,j 

fJcility. or p;JtIiD- or '"""'" iIoIibiIioo Jbo!I D.io b)' all ....,.,. tqIIIaiaoI 

.., be llllljeQ I> Ib< ..alIUy dxds ofll:at fElitylimiMioll. All i.,(mlI>lioo 

~ .oh .. Arr=t="! !NIl \Ic ~ ~ .......... 

~ lUll" ~ 1:1\111 bel..lrail<d Srlla ciriI:<III or poo_ oIi<fI iUlU$ 

;. ..... UniIt<I ~GI"' ..... "'I*" C_~ 

~..q.Daro. ilroqcir<d. to,- .. CfPB. 

I~---"'" 
87 


m.'~~_"""'""r_1,l.Q _____ .................. <fo.II""'O' 

_ ... -,.....-

1.21 fr~ ~ perf_,,,,, of 1M 81". kmI ., fllCil jli .. I .. Cor_ 

~_~ be ,,-.I. """"'"4.-y by Iho ~ All 

c..m.:w ~ ..tat .u.. ..o.r "'" BP" RqIIIf .. pmmoo 

II My CFPB f,",,",,", Wli be cI",,'1y iolc:w&ble by I dii!i1J01j" 

IIq<.W:<pIaoL r..aw:l. r:n;,w ~:IIo: 00wm0:00L 

11J Corpcnr< icln:tir.:.ioo boWp I!uII bewotllCl'_"'-_ all 1' __ 11 

io Iho .... ....-.:bolily of .. C'eabtw I> ;roride IIIiI ""J"d' 

i6eatir.c.tio:1. An ~Io< ~ man all .. by Iho.-il) ftS"'..IIiooI 

.oppIioaNt I> tt.o ~""..,.;.e, ... bcioa;nwid<d. 

11.4 ~ COR may di:«! "'"' n. pmoottellbJl may be ttpolfll 1ll"Sms:1ivt 

.. ~ (SilUr ... _1ddiIioDtI....ny.- SBU dI!a 

iacNdoo, Iur ;. ... 1iIIIMI to, ..r.n-1haI is p<IIO<ICd ..... diIckAr< by 

Ihc PO",,, Ad, S U.S.C. fm •. The: Coatt.ctor wll cm:rt IhoIIIIy SIdI 

IppIi;IWo I*-' *'lIt:ioI& ... ...,- uura.:t, iocIoiF.Ic ~ !!lOll 

It!: ~I reqvi,.."..;s .. )lOIe.:I apilIII ~ cIid:IIiIt of S8U 

.. 

1.l.4.1.AIII~ palQllocl man be W!td StItOS c:iM:no Of ", .. 1owfoI 

~ JaideM twa (II '* II ... yean or ""'" of US RosIdtIq 

r-to:. ofleg:ll cs,-... to. u.i".td SwI~ 

T~ J AD ponomeJ ..... be...,. .,. ~~ '"~ 

00'.81). c--.aon iItar. ...... 10 anify fiqer;riot.-d ai:JiaI 

*kpw>d ohcd:, _ v.:ri,-..,.non of P"'I rmpko)menllIId echo:IIion 

(.II1 ....... ""Ibo~I). HicII*1li1"lald-..:rl). 

P'" of !heir tric pnnss OIly lla .. tbrir err:pIo)_ wp. -u. 

""'" ... ~ of !he requIreC doNme:!a. ConIntIoc! ..no ..-mtify b lbcy:':hdI *-..... ron "'1M ... 

P'~ l1:\l$I 'II'OIt IiJr tIte _lis of doe Cl'PB f"'fll"priat-balcd 

criminoI ~ ,...",. dtoQ: !ll lie .......rJlly ~ 

~pcnoaarIlI:oIl ... kP......u.a"",, __ .e 

IC<Wit)' Icnns h:ovt boon prcptrty ro:npIetetl and .. bnri!t<d to !he 

CDl.fw~ .foIJorora: 

"Ic----"", 
88 


ap. ~ !t.C.-__'"""_"___ ""'_"'" ~ .. __ .000I0c.._ 

-... -. .....-

~ IqerJriII wdf 

NorKlilcios<J<e Aj:r_ 

r .. C!eQ!~IvlR~ 

• SIardlrd F""" (Sf) SS-P, "0oa~ /tJT fWIIic rPomio/u," 

1,U.l.Ptnorw.I.-.;.d 111 pabm waI< ia pooil!<m"""" 111110 IIip. 

~sI: !Ml ~ • ~ Ia",..ipli<oo (Ill) arw:I bt tIS 

0rilnI. n.... pmoIII:d M ""' .... ~ .. tIO SPA..aI 011 

r=riIy form! IIovo beat prqa\)" ~ II1II ~ 111 I!IO 

CORfor~ fono..-.: 

C~f""""C>tdI 

~~ 

flirQcQ\ kl'plllWlArl "...... 

SF as-p, "QumkM •• i •• /tJT hblic 1Mr 1'oJ1riIw." 

11.s All pen<IlI<CI nil .... C:P8·jwod ~ ~ ... WIrlitt .. 

()o-,'erJ\ttItM f..;ililiq. 

1.26 All pcrsomoIn. -"'lo 0I1'nIipIior.I iIIII,..".., boI ... "'" IimiIa! to, lilt 

fGlIowi, !...,. be UDI~...c.,. this _, OOII\'iaiGn of, rel..,,-, , 

WDt ">iolaIce or I tcriooI ~ ,...,..d of_for ~ 

~ (f f.oibn 10 fit or P"7 r<dol iIIoDr!Ir .... Tho mB ,.,.... lilt 

riaM '" dmmi"" if • CorurJcIQl' cmp~ ... ipot 10 I lilt .... __ 

with _!lilt. TIle ComrxIof au q1# 10 _ 1% pdOII mifICd ..w 

.. ~ &Iy" oI&:ioIlIOIificIIion ~ Ibt ~ lOll! . 

ropiO<:<meot ";!h:n ft\'C ~ ~, ~ bm or a:haiDotiool af J"II(lIlMi 

Ire M.iItjo:t 10 Ibt _ iI"~ Rqm.ma.t. 

12.7 Tho CoatrO<;Ia' moybt ~ 1O.;p1 ~ orr-"Pf\IioI 

II do~"!'CIIIHa Q<! othot pa!ioaII i~ rtl&Ii .. IOIiois ff<l~. All 

iDfOl1lll:ic. po:oriIIN loy "tot ~.mn be fC.....! 111'" ~ 1\ 

Ibt C<Il<h:$ioa of tl:l1 Call ~ poriod. iii tddiIioro, Ibt C--

II>U!I ba .. p<CYidfcl1he P"IOftlItI _il!o.:I ..-iIh Iho SPA, 011 itMty 
89 


m·ll.c..oo:Jtlv..._ooI-,.s....,UC') 

~ ___ """"'_""'o(c..IiI(W'" -.. -"....-

.-.... IIIEiDlIIId ali .. ~ <lI:l:.ioooI ill 110< flSMA 

~~ NIST ~liM 004 all. p-.iblio: Inr ~ oLd! ia;!wdo!boot 

.mm:. 01 die F<dorol ~ ~ (FAR}. a...r ... IIIl'muIioa d. NOT 10: modo .. 1iIHIr II> 1M C«:rKIor. 

to "Pn$trI.\L!DD<TTTT VWnc),'D! f* ~ ~. r.uroo..ot: " 

SOIl;a.TI'AI'11. The 0xirIcI0r Wll ~ !he (o11owin& ~ ill In ~ w!IOII 

"" ~ ;. rtq:Iirod 10 t.r., I\lI6:o ;iJ.)"IicaJ -. 10 • «btll~1ed ~, 

...va. __ 1CCaII1D. ~ iatormaIim I)'IIn:I: 

FA). SUl)l.9,/'UsaUL/NA"tfrI ~tnr()Fca.W(TQtI'01O/t)/flUA." 

2OlJ) 

(0) Tho COIIltICIOI slid ~"'III.., ~ iaGtity ~~ 

id,ntifi.d ill m. CCIIIIIlCIlbaI inIpIem<o\ I\omollfld ~ ~1iaI Dinctil'O-12 

(HS1D-I2), Offin ol ~ at 8<111sd (OM8) ...... J.t-4JS.l(. Dd F..:mJ 

Iof(Jrll\ltion Pr«e~ Stall(Is,,1o r.;licarion (FlPS PUll) "'urnbrr 20 J. 

(b)n.~MlCOI/\WIIforallro.wolGo-._~~ 

iwodtoiboC_~iII_"lCCIi(Io";\hpaf~lI.'ldt:"lI!io~ 

Tho CoaIX1or U MllnlIIIdi ~ 10 toolUlliq; ~.11 !!>: ...tiaI ol 

.. , olthc~. <!!lUI otlIIrwite <lMmir..d by m. Ciowmm<:II; 

(1) \\k; .. ~l*dodfo:<QW¥1~. 

(l)Upoo~.flho~<mployte"~L 

(I)Cpoo-.a~ ... """'" 

(e) Tho CooncUac 0!Ii<:e" ""16oiq faJ prayr=I UII4a • _ iflb< c..:r-. 

f.ils 10 00InpIy ... r1111oew ~ 

(d)iIo:~.um.rt Ibw.-oI~~_)IO$I"I)"h d~iII 

oil .. ~ ... iIM I/Ir .. --.uIClOr', ~ m rtqUirtd 10 ~_ rtIII!ioo 

pry.i.:oI .... 10 . fabo!)~ fociliIy ra'lflll raIiu ..... 10. Frdon!Iyc:o:II:rolkd illformcioo .)'Ic!I.ll sbsll be tbr ~ oIlho pi;l< C,,"_ to 

_I*li idaolifGlioo 10 IIot illuinlqency i:I /II:JCOI'da:t . illl tbr _101 forth io 

~(\loftiateOiclo,"""""~ia"""'brlil:-~ 

Offw. 
90 


m-c~,"","_" 

~ _____ __ ut:) "",, __ ""'.,",*IWPoo 

-... -. ....-

U COOPD.AlNi WrTI! O1lIEll ORGAl'olZA11{)1Io'S. Tho ~ ..- III ...... 

w\lh .. ",.,aulti"" of o1her c..uocm, f<dml R........ s",kl, F<dtnl •• 

~..w.....d_ CfpIi......,., .. may 100 requR.J by'" Cf1'B. 

10.1 GE.>I!!lAI,. Tho n........- _ rile rifht. 10 ~ thIt die C_ re.i", 

~ aoployteJ "'- o;«1IilllloOd ...... der 1111 CatI iu"JOd \IIIda" tIiI BPA is 

~ -.,. III rile .. iIIIrrNo 01 ... c;"..""n-. no CaoncIioc Off __ iD 

p..!>.lri« 0I1IJC~ TtUSipoatI ~ ill ...... .. 

[OJ ~ ~ c. KH I'uscNto.. AU ~ ~ 01 loy 

PtnoorIoI_ 1oomhmiaod III ~ Cootnctiq: omeo-, .. m,-" fwibI< lli>'a rile 

~ Tho CII\InIo1cr WIlIIOI allow Kty P--.I ~ dIm& lb< 

81'A ~ period __ Ihr C .... 1i:ItI)' 1MIIilXs'" ~ Oftitc, 

will: I ~ III Ihr COR, prori6es 1I!t iIIbmmga ItOj'Oirtd hmiIo, IDIl io,n... ..... 

CMtt...m.r: 00"''' 'fIIWO¥II. All t«(IIUII lOr ~ onus! )lII>'"U I deIailod 

~"e..~~lIwpropoo:d~.~ 

__ f<lf rile I'fOI'OIId ~,1IIi 1<1Y.~'.,.adby Ibo 

Comm", Of&;a 1ICtded II> "I'JIfO'" cr dillpprlll't the ~ IIlbstituli ... Tho 

1tInU~"alIJ"'IPDO"i~_be.....-Lcr~,III" 

qualifglja oIlbo pmoo(l) III 100 ""'.ami. The C~OIfICtf. crill o=bmad 

~1Mi>"<, will ~_ "". roq-. and Il'OIDptly oorifi' If", c..,!OOOr of 

wmoI ... ~1baal( 

10.) 1'!.lTEMw. TiiRUTIi. The ~ IhalI not emptoy pmoo. lor wort CfI aio 

A~j{"""~ ... OCIIIIid«cdb)·tIoo~Clffietrlllbel 

poXaIIialllnallll Ihtllc:alQ., safoIy, -=riIy. poraI reIJ..Oeioc ... ~ ___ 

oflhe 81nlo aud'or iu poJlIllalioo. AJtj AAiI!"f1Oll dtItrmioW by ib Go\...,..,.11I> 

~ • ~ 1lr!tII 1lIIY bt iImrlaf.~ .........,j ffca paf--. ..., Ilio 

AlJftID'III by tIoo c.-..aq ou- a! JbaII lit RpIaood tty 1ht C-II III 

additimal_ to lh. QoVClDnltfl1. 

IO . Fcr ~of1bil....." J:<)' 1'mcIIrAI .. dd\nod .. 1M c-.m.....". 

who will ptrform sipifLanll<Cini<a!"OUt, .. .II ItO iKm.Iiod _m:n .. ~.eooI1II 

.. -
91 


QI'·II~~_". __ u.Q 

___ .-..... ~""'_.O'~1100 

_"_0('-

l DF1t!dTIONS. 

~ Stnorirr. ScMi1y'" :a _ ... _ cioe rist. and IIIpirD ofloaai 

rncJtioc frOIII Ih< \010, ...,., or ~ ...,.. 10 or modif"*""> "r 

~ Thill "'Iode:! 0INiq thai ~ N ~ ill .... """"* dr~1y Old ~~ .. c.:zfidlo.tiolity, "~y. sci ""Iilob!Iity IlmlP 

Ih< ... of managaiII, opmIiooal, and ~ ~ <>In:ltIIL 

Ct.fo./ttlti~". Pnsavi" ~ , .. trictiou.., ~ told &c:kIIurt, ~,"!i" 

_1"01" ~ penal prmr;, "'" j>I"Cpiouy IIIf<nDIDoo. 

f~ ~"""""". mtormlliao ~ 1lA) life .... _ ... JII"I*'CI 0IId 

ddaio$ irtlO:noD:. ... iakwmo:ioa I)"SI/U!of -.i" dIrif .-..ibkIiIy, iIIIqri!)o, 

~tiou, OJIIfJdmialily. oad om- rcpo.diotioa. "!lis ;""b!es p<O'>i<!io( tor 

~CIf~~""~pnoIC<Iioa.,~_raaioo 

capobdities. 

-----

All iaformllioa .-... ~ bodI ~ IIId ~ IfbItd 

_".~~_andilll"cn!Wio:IolICb<:qy. 

f1(tinMriIIa .I)ortoo. A diIInIo otI of ~ _ ~ b- *" ~ ~..q, 1IlIi0WlllU, ~ and disoominotioQ ol~~ in 

~widioldirofd~ ........ -*'Ior-..l. 

Willi ~ 10 IN Cr"l'B, inl'omwj.., 1<Chnoloir _ ony~ror 

~J)_"~of~...tin*,,-.a. 

~ aortjO. >!\Il)'SIL ~ -]'IIstioa, ............ ~ 

mowmaoI, ~ diljOy. ~ ~ nm.oo.. or 

n:«pUc.CIf olD or ~ ... by IhI efP&. if1!lC ~ if; '"'" by 

tIIo Cl'fB c!ir<cdy or if; UIfI! by • C".oIIInct.x PCIor • _ '01ItI rt.t 
92 


~~_001""""_uq 

C ___ .. _~s-..p.-.I"""' f{"""OH"'" 

-... -.-

malbr,...... ... -= 6l of llYl ~or(~ (l ~ 

'" I ripif<aou "'tal: in the JII<for- 0(1..me. or lho funIisbiq atl 

-

IIfInuDoa itdDoIoc1 m..laI ~ J:rilIrye.pjIQIIIII f ....... 

'" p«ijlbo<alo. Ir.puI. 0U/iM. IIId Il«JII" <Iovi<a II«CSYIY for 

1r<Wity ... .....,;n.o.~ ;alicroI..,.".... "sipd 10 bt =:rollod 

by ti'.e ccmI p;«ttIiOf unit 0( I ~1II<f. ootI.>m. r_ 0IId 

*:it. ~ ..m.u (~ "'Pi"'" ..m.u~ mil Jtll:fd 

JtOOIIf<CS; huI docs !lOt iuhldo IlI1 oquipuI:t: «qciJtd by • fede!aI 

Ccca.::Ior ilcidaMallO II«lmI 00IIIl'XI. 

/MrpiIJ. ~ ..... i""""", .......,. IIIOO£~ or deItnctioo, lflii 

iD.:l:dei:.....ma i!If<maIioo """'~ DId 0IIIbnticity. 

$<mol f'rovidtr. Senoiot I'roridm an: -an c:a:in .... ~ lho CFPB 

";";"'lQIlid.lrmmool)-' nne .. .., jo,jtvioblorodxfitplftltirylUlO) 

di!'ftlly or iDdintdy (0.1-. IIrOIJIII .. tlfiIiaIo~ """'"'" .rr.n b' 01 II .... :atdod, 01 

...-!JIr I'1If bt .,.....:aed 1O...taiI otra. """ 01 00 .... 1rdtd,. GG,""""'" <a:".irW:I. 

~ I _ forwril$O"*Gowmr.w or ~llIoof~ orl 

~ ... GowmrocnIOOQIroa; or (2) ~ buiMIo. OI..-..b1y moy 

be Olpt<'l<dlOtoIIIb::! ~ -.ici:bo GiJI~ •• "ll'~ol 

IDOI!:IIr ~ "",,,*,. s.m:. providcn .. cl2IIifiod"", oftMl WI)'I: ~ 

.-

C""ullCl<d ~ 1'RMder. It. Cu!ncted s.mo.l'mn5cf (CSI') ill • 

p!WlllWllloted 10 rt..'« 10 CIII:IlIIfflId Mi ... pro:aocs ~ 

by pri_ """" ~ .)'IIIft. -..d .......", 

~ 01 _0«. WonIaIiooI ..mea. A CSP pafonlll 

.!my dcf.lled fwldjOlll b IIIic:II m.:. IN reodiIy ioIeoti5oWe 

-.xrity ad""Iha! .. ~tMId"bodo.ition 

II1II...,......... """1I!I1bo~at~~101III 

.-y CSh «JIldod ~ ..... ~ FmiQd 

Equi;m<s Ca."£). I/oom .... -=c Oi'o III)' pufom ill .... 

~tc:MtieI ~tof~ eonuol il .. hk:heooo 

1/Ioy ... .oIdlld .... GJE. 
93 


----.---- m.IK_IAot-_ .. ,..,...,.s..,.,LlCI 

(_"-_~~Jor.,o._""""1WI r.."­ -.. -,,~ 

s.\and Serrict """""". A Shstd ~ Ptoo'idor (SSP) ;. ... 

fedml .pr.cy furtcMrU", .. I savio, proI'idcf for !he eFrB. Tho 

CFfB mol .. ft.lmI .-r -.Jd sip I Maoor ... of 

~ (MW). lnlmgetlC)' AgrteorCI! (1M) or DIll 

...... -

0) 1\t _ict ~ bI! k mpoMIlio if dIrinc 10 CfJ'B ~ 

~ (IT) 1OtICil)' rtqIIir<mentI b ,II iI~ IIl=I ~ 10, (sPB 

.....n. or CfGIIO.l.,. m. ......a ,..,....1«. <If .. bdIIIf of. tioo CFPB. ropd:_ 

of kuion. This clMe lP!'iio$ ID 011 or M'I)' pili of a. ~ Ibt iocWcI 

ia......... 1CdIooIocY .................. err .......... ~ .. tick ............ 

pr<Mdor must Ig, .. physicol .. rlt.:Irmic: ..,... to CfJ'8 iD&!marira 

(1) CFPB iofomIaciom 1Odmkv..:l ;,,~ _po:! 10 ... -n pro¥idon lUll 

.....a. ill dIt Uoi&<d SaIeo. ro. ~. ~ II1'II01 ~ oIl&id 

I<CtD:Jkv _ Ioforaatioo _ tKo pIKa, ..d orip.. rr-. riIU. Ib: Uoi:od 

..... 

{ll The III'Vi<t l"'iOt< WlI meiIIIIio I~IO __ io~ of all rna. 

provided ~~. Tho ~ IWl k _ MiWlIr lOr ~ 

imI!:ec!lrtdy "l"lll1eqoesl by 0. CfJ'B. 

(4) n....-.ioI pNVider flciiiry ~ CFPO iofOllllltioo.-ca 11M! """' all 

opo;!IieabIc fe&qI, ..... IDd kw:aI ....." ....u-.I. II1II Ioi~ .... ad 

~ n. facilMy _ iJlCludt proI<ICIioo opinIt ~ _ 01 ,II 

hI>m.. iotbina:lIn:a -.I ot.eifJ:oc:oo Il_ *'<idtod Jr'IIO\'IIOO. be tnoclIod. 

(S) CalIir:D<d ...my ~ 10 Cf'PlI ~ _ "" ,.,.:ned 10 "" 

rnB Wbia 60 miIu: .. "d~ by!he ...... "" prov!W. 

(6J TN ktVi<:< pmvider WlI eQ".ort Iha1 ;.. nnpioym. io lilt pcrfilrnl&OC< of Iho 

_1<1, m:eiw ao! ~ ...... ~ foOOIIriIr __ ~icin&: ill 

~ ,,;m Off"", 0( M"'""""I 0Il(I It.>.:!!"! (OMB) CirrolH ,\.1)0 aI'd 

F<denI~s.c.ny~AClof2002(f1SMA)~ 

I~_""'""'"_bw 
94 


c-

~--____ '"' -.-uq .......... ·,. .... tlo..<;ftlloOo 

-~-,,"""*-

(1) Tho..me. pIV'idIr .... lP'* Ibo ~ _ 11> .. , ad all fIoc-.Jm.t II>(! 

irforll'llti<Jo _ lINd .. "WO" of !he ~ Tho Cf1'8 .. .all ~ -...:aI 

......., II> CISIIR Ib!be....w, ~ io W ~ ............... 

..,fcmd, effec:lM. lid ~ u DmIed. That r<YirwI iodIdt, lor: II' IlOl 

!i.i!td 10., ~" Ii!OlIDi<al ..... of Ibo C<lOII\II .... __ ""<! 10 

Itf.pard CfPB iIIf.....rioo ,.......... 

(I) AI tb< .... .a oflh """'oct, tho ..rna JI'O"idtr *"II ,... Iii CF?B 

ilfOllllllioo -= pmidN 10. Of ~ by, !lit ICf\'ioo ~ dotiQIlho 

p<riod of!ht <OIdIOOl ne ttn'ic:o f'f(IficIn' Il>oII proricIt "";!icaIioo .. ail 0l'II 

iIf""'"""""'''"''' ... itIoo:!frCIII.~_G.FE;'~I)'5lteIiII~ 

..;,!, CfPIlIIaIIIIaniI ad p:«:tdn.. An Coif ..... ~ ~ mull br 

~Iy ..-I M ",,:IUd by !he U.S. &>~ I'mIe<Iin:> AgtDC)' 

''') 

(9) n.. .... 'Itt jIn>I'idc> r/IdI <0lI\"l)' wlII .... .". oflho CR.-..- ~ 

propcrI)' dauIeI ill 1hiI __ for IlfY C!"n·~ IT !lw ~ klot. .oIen. missia" 

~ror,Cf""" 

(IO)F«!be~o!~i<atoo~"Cfl'B-'''';nfma 

"'" of """'" bM.i, amlltIcilokl/f-tht-,!,df JOi.:ims. WeMticd lpJ)~ """ bt 

_po;! 10 WCfi: willi ~ ~ '" ~.q"UIII ~ -..I", IlOl 

fl.VCf IIOt brO'O'MI1yfIO over ~t... 

(11) Tk..ma. proridIo wi a.:Ibm 10 Cl'i'B <:<>!IIII\OI!«Ii!IIy ronllpDionI-.d 

~s.c.ny~-...-"""" 

I\. n.. '-'of~ ~ *"II catif, ~ ft r.n, 

f=imoIlIId opeIllt II o,lero.d 0111)'1"'" \lSi"! Ibe FodenI Dalaop C«t 

COIIf"..;.:.{lllOC)taI. ""'"""* I)'tI!oo ItId ~ r..-. .. 

B. ,I11III.......,. oflht pruokI wiJ lit '-"! 0II111t C1PB ~ of 

tbo KlIion&I lortir.llt of S~ W ~, ~ Ch<d!iat 

~ ~ (NIST. !\CPR}. Cb:dIiIII .. ~ II Ibt NtsT, 

"CPR "l'btilt. l~ ~ wbtr. _iIr """ropllllioof ... IID!"";~ fer 

,..,...t ~ Ibt CflIB oIaalI prcv'.« iootn.aX:a. 
95 


, ... .u_"""'_"" __ UQ 

a....... _ __ .......................... tjC .. c.wn. 

........ _,,-

C. The "'I~ ~ --. ... u¢a G ....... IboIIIOI 

.:tor aoyCFPII-~ '" e!Ublilho4l1'CWil)' _6~iorI. 

D. AppIieIrio:w Csipd lOr .... .t.>II t .... ......-.I .... a!CttlI wifIoo:I 

de .. 1ed f)'Ittm 1lfmiIIim_ pivilrge$ 

E. ~ IpfCiIicolly GptIII r", .. ~ G I.tcJrm:ioa .w..--. 

(lA1 .... det~ .. ....,.. by tOw CfPB. 1/1 n""'lll iTOIlI ~ _ 

-itrcoolip.Uco ~ NcoaE rrio~by .. aPII .. 

. ~-. 

(11)1loe..m:. ;nw\d<rWllllCllity die ~ orr.,.. and dIe<XlR 'O'iIhiI 30 

days G IIfI'J ~ doqt '" iaIpICI dill Jl>tf i:l:afm _ "" r..Il.\mtiDo 

.r .... C<:Ollflil:l 

(1)nro.po.. __ tIfdlr<m:na.DUoI 1I!r..mc.~""","~ 

'" prooide I..m:. dill doei lIOI .. (c.l zr.oinlWI) _ ""_ die ...-.i<c 

pfO"Iidtr. IIlbci, ""'I' eXj)ftlll. will comd iweI wid:in !IO do)l of DOIif~ by It.. 

~Otrar_ 

(I) Tht .m.:.l'IoricI« II:III!1/.l'I foll1~ I-.d 10, ad .. lxoined ",!he 

Caoa~ Oft"1OCI" It.. CfPII-, Savict l'rM'ider s.:r-A_"1Iml prior 10 Iht 

.....aa...r .. ~ 

(2) The IItYke P'",io\et IhIII _lain 1 ~ .. ~ wi!b .a.q-

~ M III a.... nil ~ IN! ~ lIOIla1ed "'-lilt ~ _ 

~ of lilt ~ _ ~ IU "ill bo toIIonllO =--.. IffiIriI)o ~IT IW"- WI 1ft ck>'e!ll!*I. P'0CW!d, 1I>Iw.litud, ,It'd. '" mair.tinod 

-..det"_"""~~~""oldlrC-'s~ 

..mr-. by die rntI, 

el) I'rico Ie dx = .... of .. «IaIIICt. Ibo mB IrII)' ..... 1Ik<;uat: K<Vity 

C<IIIII'ok il ille ~ .. Tita::ec:l. " la I nIidouo. ;, ,..m..t. !be "IIio!oIioI 

";1Ib<~byIlKCfI'B",ponol"""":l<j~~~ 
96 


(>O.'l "--' -' _l1C) 

.-...-

_ _, __ "-..... , ........ .,0..""'''''' .. _tl_ 

(,Al n.. Cocmc:OI IpCt 10 --., !11 pIftOII!IId .. Alorimd !o)' I!oo 

CFPII. me IOCMieIl, ~MIII. arod NIIIpftII..tquri: tb: pUM tile 

~. ior<piIy', -.lmibbi/ilrofCfl'll iIIflnWioa dial ft ~ 

~ U'IDtmi!I, ... Cf .......... .-q 1M ntcatioo oflllil COII1r:I. 

fBJ n.. 0I-tS! ~ _ 10 ea.mo It.e ~ ...0-

~ willi FcdmI Ja"" till! incl-.Idt, bill .. no! li":ltd 10, me I'oda 

~ ~ w.......- AcI oI2tm (1'ISMAk 1IId-.iotll'<oletal 

policies MId I'f"<tdum dII1 iJltluQe, hill ... DDllimiled 10, mID Circutar A· 

1)0, FIPS ~ 199 -' zoo. -.I [)cpIrmIIaI ofl!oc T~ Dir<di>-. 

~J..(ll. Ol(lin of rme docwutl It< ~ by me CFPB otT ... <If 

~ aM .. ..,.;w. ..... ...- Faiion 10 miou:a ~ 

.;m 'l'Piitabio _:tt. lftUlItiooi, iItd I"*- NY be =-- fer _ 

lm:iIIIoioa. 

(C) n..~,-idn '""'" lllliw.in .. a:ti .. iaftmatioo I«"I.Oiry prI>!fI!I. 

n.. JII'4PII 1lioii ~ odaao abcII rtprdiaJ to.&c _ 

protccIiD,J CfPIl ialixmation It me Ca:mdcr'. Iil. (lr.dom"a In)' 

~.rmd, ~ Cf ~ ...... CGr.Ir_'.~ 

1)'IImS). ond th: __ flWIai''''''''' ~ ~ ,,~& 

od I)"lIIm ~ of """*' 1)'1""'" """"""" .-I 

1< ~1)'IIOr.IL 

(0) Tho ..mtc JIIO'i6tr ""1 .. ~ ~ 10 jIm_ 11M If 

~ or CFP9 ~ • rUn ~ prQ'lided fer by tIlil <ml!l!1 11 

....,.....,. 

(El the...nc. ,woriW1hall.1t 1brir_..,cnw,1II;t .uo. 1o.,. DJ' 

hlrmful o/fOd Ihat ~ kMwn !1Iihe ~ provid<t of . "'" or disclooan of 

Q"PB iIIfonaIiaa lor die c--.-.. "-IItiaa "d>t ..."... .. " iIIiI 

,1-

(I) Tho 0l'8 otr ... ,,("yborsmrity ..a-iobtulioo 01 ...... .u.-iou 

lI«"\I:ity ftq"mmtna ."d IU:lda:ds aod ",,]1 ,,",,"d. <lewll U(IQ! rtqUOll n.. ""ice 

~.;ubcllOlifit,,1of..,.~~ IO ~~ 
97 


('J>-I~I""",_","'-l"'""'w:) 

___ ........ __ Ml"'"""'''fMIIl~1» 

-... -... ~ 

....... II>M ... I .""'" ;",p.r 011 ..... Savior 1'ItIridI:r'. iI£n:aIioo 

stalri1YoI:>I;~ ... .dtrIbisQ;JnIrICI. 

(2) Tbe CfPB -.ill ~ * -.I lot , ... 01_ 8spcdioo ,,"...u...._ 

CIdI year. Tho CI'PB ;, iII.ok dUcntioa 1liiy d<!emWIt m.t.".,..""";2 Wp<ctiao 

io 1<CCIlIIl". 

13.Q l'ERfORMANCI REQUIREMENTS SUMMARY. Tho CltntXlOl..me. uqUl"l"ml'lltllIf 

~ itIo ~ ~ lila! I. "mIJ 10 ~ -:.l iIImo. 11to 

~ ~ Ddi.mblcs S''''-Y wiIbtt iIw ~ TIINI(.) bridly 

dncriba tbt u...t.oldt Of ........, >«qIIIbit IcvtII of ..m.. ~ for <tCb 

~~1'ltoa~ .. criIicoIlIl"'_ n..~ 

RequilIlI".e:tllS SII!ru!Ilf}' (rOf porpootIo or itlspec(ioo .rod~) is" AlIIcltmeot ,. 
98 


o:n.n._ ...... _ ... ..-,_UQ ~_,_ ....... ~ ............... "o.._o.. -... _" ....... 

"" ....... Safill.Utl~y 

fAU; I.P""-~I ~. 'Ill< c-.-" • .,.:co oW 1M"""'''' .adr ....... ~~ --.~-. .... ~_,..,<ftdil,... ... -=!bi'.)'_Qyo 

,- ........... -. no c.ooc.n ,,_.w .. ob<....,.. '"""".,. .. dIirI7_ .. )'O.,.._ ..... 

__ 10 oIlI ..... or ............. C_ ...... ""'" 

~"""""._""'( .. dd,'IIIII.,._oId>iW~_ 

IIor_")" 

.. ...-- noc.....lIIOo1tq;o ....... -. ....... ""*""" ooI ............ Jrqo-..,.."._owri 

-..,.:.. .. ~~ -

_ ................... 

.-. ~"... ;;,; 

I~ .-.. _.~oL""_""""iMIIlM_-"'r.. --.. m;,.'-.......... , ... rq<'I1.w..&clIllio~ 

I;;:; j 

"I 

c.._"""""-""",,,,",,1XoO 
99 


~"",,_"-"_UQ 

e.-__ ................. ".... ........... r..r_tooo _A._, ........ 

"'~b", llI<_"""Io .... ~.Icoa~" ... ,.'- -' 

~_ ..... 1IaIIt ............ <tOdIo<Md<laaoodi\lolU:ori<alaodio~..;_OrooIl k 

....... Ofa' • .,..,......,. • .., .. ....,._.1.'1<1_ 

nocd. Tho c..- ob!I .....,.. .... __ .,."..,.. .... <Zd """ .-

...... __ ..... Cl'I'IrI.,..........-.r n.~ .... ,.". __ ioIboCl'Pl'lliol ol .. -...(oo<_· ... ll ..... 

.... ~,.....oIn...,.1OOI .. O':_~,_ ... .u... .,..af'._-. .. C-oIIoII ... ,...;..!~ __ ... 

_4IIIoc_"M1I~"l(JO!O .. lh<,..-

s,- ~"""""!orol1"""nqo;.-io fie rws.un am_"" ....... ""'"-l ....... IIiIIori<oI .... _ ........... .,. ..... _ ... r.o. 

At "'" 0>1 ....... _ ~ por*. "'" CooIro<:a< .... ,...... :lie arB 

.;e.!IoII_"III ... ~_ ... __ ~ 

... ~~ _ ~ "*"U .. _I(($, ..."...... ... ""*" ~ .. CSI'B, ...... poo.-t~ .. bI:l 

Dolt !:l!I!:p<o! ,. ID~!'). 1.Ip*IoI. Iio 0101/' .... Oc ............ COl. 

_ ... _..,. ..... c:.o...n.. ........ .,_....-. 

"""",,,oooL-o, 
100 


t7!','K.-

~ __ 

....... _ .. .....,_UI.') ............. __ ......... I;N*( .. _ 

-.. -.~ 

"" ....... SclEllWllOW'lD.Y 

:\I;!!:'t!!io!Iofol&to ....... ...,.... .... oIok.,,_ .. _ .. W' 

TIlt o.:r.. ............. d:)f'" <W«o) 01-.-........... wiIo ... ............ __ io~l .. ~_ ......... ...., 

.. _.,. .. ",,-- (10 • ..-.,.-. __ .. II1II10_ .. __ «10(1) ..... 

_ .. " ............. DOc. ~ c.-..w ... ,...-. .. 

""""",,,,, ... ~ .... - .......... ...,-,-.... ,.... __ ... ,."Dk_ ... ,... .... ')"'._.....,.,...,. 

"""'1Iy1all""C1'l'I:IIMIIII~,IooIlooU ..... ""* .... -"'_*" 

_",oftJo ... r... ... IId.", ... C»Il 

n..c..:.roWl • ...-. .. ~"" ...... IIy ..... -'" .,. _ or *-iot ... _ "''''' CFI'B. s.Q __ .... 'Ie 

oppInio._"",...n_b!'Ioo$","CFI'!I_""~ SoiiI 

oIoJdioc""" ..,,.,,,<<1l1000'''''''''' ""' .... oIokoillo ,,,,-t, "'"0111, 

1."._ .... __ &_ ...... ..-... _ 

.... ,....""_lll)_.....,.~.,."'_ ...... 

-1-----
101 


(PI'.,,..... ....... _ ... ......,._UQ c-.-._ 

_ .. _-t_ ....... __ ooI_<lr-CWIJolo 

.. , """"" """"'OONa' lAS*:~,.. ~J ""'-:':'CI!!j!<!M ~11!!p:vtio; bmao: n.. __ oUII!oII,....,.., 

..... ,.." ........ "",,_.,., .......... _ ". ......... Ul!oolr""",_ .. ~"",obollIl<I'O"'itd .. 01'B-",~ .... _6r.J_Cj1o!1lr __ 

iltp.ouocCFPll.!dool"Jo ~"'~"'l~. 

m'I_ (..uk,..,...-, ........ ....,._.,. .... 

...... , .. ri 

aJ'(I,... .. _ .... bc ......... io.~f>nI __ .Ol'II 

"'ok(_ItIII,,·ail<bIe .. lok<lIIool<l<l1_do,.of.w"'~Dn 

","c-..-"!oII~"'""",-""",/II;IIo)iIc'" 

__ oIizrO "l""" .... ""'-"" oI,...;,.q . '"fI'" b ....... _ 

",,"_ .. rna 

1t<poo~,"""for" __ ~"' bo "";IoIir .. ""~ 

""",~IOciooUI)"''''_oIo)o'' ___ 

0. • .-,. IuoI.. pnioooI)o <kpbyoI ~...,. oW k prtPI'iOr<I " iii< 

CJI'II_._ ~>I\o"60~n... 

Al __ ,,,,,,,,_d<oop~.,,",,,""fl_!oII~"lIi1 .. ... _...,.6t)1. __ Stoabo_u. .... r .... 

(!p_lgwlO"...,.."'l"" .. bc=-do< .. ____ 

.,..o/hrlb<,....,.n..s.. .. _U.'~1 ...... .w.iooaIl<pIl r:bt c.-~ !oil ~ "'~ -.c:iq'" 

dopIoyq o<i:!iboooI """" 0'Ii!Ii0 .. IMioou .,. " ....... , _ r- 110: 

"" 

M 11K !p<nco ... ~ M«Io Qotry -.I ....... I-....IIy oWl !oil ~...,_.., ... ...,aIoIoo4q ... '* __ ...... _ _~s,.-r .... , 

A""...."Dooo_TIoo~_........,Kllllbo,............, .. ...... ..,oo!cooIo<doyIoIIot"""''''_l« __ J.I,SJ-oT' .... , 

!~. __ a.a. 
102 


"'·u.c_, ~_, ...... _ooI~_UC) __ ....... -. ..... _.(HII~_ 

-... -.-

SQIaJ.uo Dv.1';U~ 

1"II<c-·'_IIW ""_'_~._"'Mr<Ol"" 

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• ThII..-tlslnWdedlnlhl'_:>t 

$IIQ'II'I\ un<:Ier .... l~,"bow,1S I ",bitt. 

B. A deoaipl"" oIallhI' I'I1ltS of prooi>ct.lIII4/Of seo'Iitn hi .. bt 

~un<:lerthls~~~todoll'rflllntllowll>t 

w~ rKltoJ 6o/!Ir$1ft IObt s?fM. 

OIIffor. rps WctmI!ion " Mrilaty StMCfS 

SoIidtltion I tH' ll ~.oo:I01 

P'IdoliO 

SKtion ! -$moM &J .... m ~n ~ .. _<l~ .. M_.M;r<t .... ______ ~ .. __ <l ... _ 
120 


~ n. f<IIowio1 pi. ptOtUt. i'>d/OII smim .. b. 

1'.IbaIn~~d Ut>derthstorltl'llt1,..t Ihftypn 01 ~~ 

~~ptrini thtm Irt 11oI'~: 

8\;sintnSl .. 

.. 

(Ot!oa, S&, VOSS 

....... HUBlone, 50B, WOSf 

• 

s.b<untrICt~ 

Dl'ICI!p(;onor 

lIollII'Amo~ 

1.1ocbIe I~ 01 lilt rnrIhod..std IOdtwlo,llhe 

-

1IIt>cMtr.q ~ kit S1I. YOS8, SDYOSI, 1UZont, SOB, 

and WOS! ~tmI; Lt. ! Jqllain IfIt mtthod.nod st,le!ht 

...... ntUINI! mis r .. do"..¥t) used to ~!l/SI1hf IItfQIItlI&e 

iIOIIfs; howlhf..".. to ~ ~an:rKlr:l lOS&, YOS8, Wt'OSI. 

KlJS2ont, SOlI. tnd wosa concem.Wff' ~intd: and how 

lhe ~irs 01 51, Y058, sovosa. HU8ZotIt. SOI,n 

WOSB _f dtttrmlrotd. !rIWd! "'¥ _ oolMll"!he 

Itr mitlitlon ~ 

l.tr.jhtdIOS!w_ hMrI(It X bHnlnduded .. !htdclltrand 

pttt...up L'IIconUJdq lOIh: IIIIH ...... fOIrd'oroel 4. W ildrtd (om 11M btt<11rKloc1K1, opIIIn lhetMlllOd M Ie 

do~"""", tilt ~a!e Jhott oIl1K11tolu to lie tIo&Ittd IS 

~to 58, 'o'OSI,SDYOSa, IkIBlone, Sl)B, n' 

W""~ 

I. PROGRAAI AOM f,ISTRATOR 

Tho "'~irc pIIn is b be ld~f't(Ilry !hrConcrKlOO' "'~ .... :I.-" 

prov;skHlsof t;lp;'bbIe '"" ¥!d It>t p.'illllII't IrnpIemenltd r.d~, In( 

cNrv"lN! no'" or Iho prop'lm ..mnbtIr.orWf lit _ ..... nlclt!l!in wrilr1 

to !he CorIaCI,. OI!ktr MI_ !llln1h'rty(JOt~r.1tr """ .... M 

Will I'lOl rtqUir. on lI'nnIediolt. conIne! I:IOdifimion 5uchrllqtll), M 1"" .tI 

he ixt..'dtd In !ht~.ox I~ ~....,tII " .• lmtn! Com,1t! modfkItion. 

OIfer<ll': ArfIII tnformll"'" & A<Msoty 5tr{,m 

So'Jd'.Jtloll'CH·1H'(»);)1 

,.60110 

loKIiOIIII- 5tu. B.1iwti PI~ 1IJr"_" __ .. ~_II""'''.''''''''-''_Io'' __ I/''''_ 
121 


(OI!!DOOlAL 

h nt.'!If, r!tk. ~ wi"*' tho! coqxnte Ilrut1U!f.iIlII\!I..1lH aod 1l1PO"lIl".~ 

01 till' ~ M'IlIwi """'*'istfrtIM c.onu.cwlMlcontrlCt" prlllrIIII. 

• !QOO1.llU OPPOt\T1.INmES 4NOOUTUAQl EFfORTS 

~Krik IIforu tho oIImrwil ~II' lO tI''''" 11" .. \ se. VOSS, SDYOS8, 

HU6Z~ SOl, !tid WOS8 COfUfM ...... 11M III tqUIUbit ~ 10 

~ kif n ~d!aInIr_ 1brIf f/IIIrtl:..."i-dodr. boll ~not 

In\'!ed to, the to5owirlt K1iYi1itt: 

1Ioot .. _"....-.. ·_· ........ ~_~· __ tl""",.,.. 
122 


rv. SU~G ' WI ftO\WOWlf 

C. The Colll ooOlINlIUbm.~!he InG>Vdull S<A>aIontm:tc Rtporl (ISA) 

...o!illmmwy SUbcoo!ricT ~ I5SRI. usq Iht ~'. EIfctronit 

SubalnUKt Rtpon"" SylI .... ltS,O;$). Tho Conncta< ol1 .. w!Imit the ISR . ... WI 

o. 

TfPOtb eltctron1cal/yto 1 1ioI&Ie, 1"",,,,0"I0fII·1II1dt SV$te .... which em bot ~'" It 

l1li ......... ",Iosito: _ ........... Tho eSRS lo ........ rt~ I0OI for. 

~n~1 plln 'C«Impr~", "" stmmlint thl rtporl!rla proms, ~ 

proMcle tho GovcrJllftMt witIt !mtntdlat. oam to tho OIntn<tor ~ .. ko/llflCttnc 

d>11. Tho OIntfldOf IIlaII IIt rt$pOI>IiIIo forfltputtlr'l KQQt. MIl ~ r.portI 

"'to tho ~!oRS . COI'trlCtOr "P<'rtI,. 01 M and SSR oco;omplhhtnl'nto l1li,. the oW 

wiI _ upOn rtalp! 01 written fIOti&M.On from l1li ~ 0IfKtr'1 

TrdInbI~. 

..., .. 

" 

=.= 

-

.. .. 

-

-

Off

Soic/u(lon 

eror: -v&.'

I Cfl'..IH.QDJ1 

lro'orrNIlGn & AdvIlCh"/ Se!'oitH 

-
123 


A. ~ Iht pnr~Cc«ridOl II flO! usq: caas 11-.0 fOISI, VOSS, 

SOYOSI, HUlIZone, 50&,..-1 WOSI ~ Idlhe '-I of pidn 

..,d other dallldc~ such oendor~ 

6. OrJM'IimIorIs<O.'ltKled In IIr. iIIerI'(II to ruee sa, I'OSI, SIlVOS8, 

HU82oM, SOB, aM wosa IOUrcn; 

c. OIl. contratt·br<ontrId basi!, rtCOrd! 00'1 NCh IOIbconIrIcI dliUtiGn 

ftlukJnc In .., 'Wln! 0/ mort t~ tile ~ ~ thr~ 

~ ~ SI, vasa, SIMlSI, SOB, 1IICI1'.OS8«111Cfm1 

wtr.ll)tidItd ~ wI!f Ihfy ... " IrIt,Q, I.ppki!llf. the _ 11'.# 

th.lWlrei wu root mldrlO 1II11II busness coro.:.rn; 

D. KKords to RI ~ otherCI<Jlreodl efforu. ..... eGnlXU -"II rnrorIlylllCl 

$nIIII busintU u~ lUIOdI~ llfndam 11 $/Ni.nd mirlO(ity 

bushtss pnIQftmetII ~H IIICI tnde fin; 

£. ~ t~ luppaI'l ourNt ~ n! ~ pr(lddfd to 

bu\ti> tI"tCI<J&h (ll _klhop5, !trI'IInI!1, u.",.. prl)pM. ~tMI 

...... 1IIII(l)~ofil<lMdrsl\twr.!fKl~~tl /rQJ( ... 

Iht 1lm'If, IdchIS. arld IMfntss IiIf of.MIl!1,,~ (:hi! itrm b.OI 

ftl!lllrtllOO'l, eonum~ blris fOI ~"I' 0( cNsior>~6e 

...... .tr<ioIp/Msj; 

¥. OIl. COOI'ad-by-alntrl(t tlull._dI to support wbw.Il1K1 ~atJ 

inducIrlc the ..... iddr!K, Me! !he IMnss lilt of 01<11 MIeonuKIor 

(t'MIlt1!m ~ not requirwd 00'11 CIlo!rJt1-by.contrKl basis lor ~ 0( 

~wI6e<O.~""I1S~n 

OIf!fOf: ",,"s InforllliuOO'I &. MYborys.Mt:H Plige' 0/10 

Sc!'eltoI:on'(ff·12~1 5f<tio,£-SrnoII80IiN,.PIw 

1l<._</ __ .. IIIiI_' ........ ~_ .... __ </ .. _ 
124 


g:>t!fI!llNlIAl 

Ot~, __ _ 

PiA/lAFPROYW81: _ ________ _ 

aPllOlfioeolSmdI' O'~~~ .-... ,._- --

0"' IO 

SttdofI E - \maJ ~ Pili" 

Offenll:Afi..!s l" f~1tiotI & AIMsoryStI'AoH 

Solitilllioo>.V;>-lH·WXlI 

\Iot .. _.~ •• _,...,. •• ...,..,.""--... --,, ........... 
125 


m.!lCOQl ....... _ ... ~_1.I.C) 

"...,.,_ • ..-............ -.. .... __ 11'-(,0 _ _ l __ ~_ 
126 


Cft.~~I"""'_ooI-'-'1l.C) r __ r_~""'~ __ .CI<6Ir_1looo 

_1,"-.....-.... 

ATTACHWENrl 

DATA MANAGEMENT PLAN 

1-----... 
127 


(]'!' __ .I -c.oo<»I(A<p_""'_~u.<.") ' __ ~ __ """<fo.ltCftDoro 

-",~ _,,_,w. 

111IS PAGE ll\'TENTIONAU Y LEFT BIMoX 
128 


CO~FIDEHTIill 

C' ARGUS 

K - Data Management Plan 

CO llectiM, Tril nSlTlission, Validation, Aggl'€gatiM, Reporting, Slora,;e aooAna!ysis 

of Credit Ca rd Oatil 

Off""" .... gIlS lr1:OrlNl~OI1 & j\Jj'I,iSOl'\'~! 

SoIknltiQn HFP-t2-R-<tOOOl 
129 


CONFlOEHTW 

~afldTlldrrNrk 

~ 0 lOUNf./Jr~tioo1~Ad'riooryServices, lie. H<l Pi" ~tMdocummt nt, 

be ~prod\l~. storf<j ." I [etoM IYI'emor tr.r»mitt.~." ''''lie"" 01 b'/11\f mum. 

e'fttrlWlk, medl;iniul.. p/IOtOCOll'l1".. ~ [e(or$1t or otht<wiSt wIt!owt otrItten 

p"million from AlI\II. 

.... "1 ~ I ~ trICI!ma't 01 ......... tdorrrMlanand NMoorySeMtti, uc. ,\I10lIw 

COqII'I' """ .,...o:ld ... ",11 Ire IMof foI idtrCI'btion purpo!I!S on.'r !lid W1 be trodornlrts 

.... - ArfIJl tnlarmadon & kM\orySeMtti, UC 

SO Mlin Slree\ 

So"Re 1175 

Whitt' PlIoIm, 1fI10606 

(914))0'/-1100 

U,lt updltf<j f~ry 11.1m 

(II/mot: "'1<11 WlY.lNtion & Advisory Smko. f~ I 0/29 

SokbtiorrICfP-I2-MXml K.o.u.~tFion ..... _<l~M ... _I ....... ~_II .. __ .... _ 
130 


TASL£ OF CONTENTS 

OlftlOf:,I,/Jvs lrf_.ilion " A6'1i1OtY SerYicti ' ill! 2 g/ 29 

SOki:Jl· .... CF~ I1 «IXIn l. DfU ~_ i'M 

a."_""-."""'_ •• ~_·" __ fl"'_ 
131 


COhl lpENTW 

SoIiI;I:Jtion I(HI.!2.MOOOl I. DiI&Io! ... c~:~ • .,_t4 __ ... ___ ... ....-,-.... --<t ... ~ 
132 


~:Joo' CFP-12-R-«XXll (~,Marll(tn'II:I\tPlin '"' .. _., __ .. ""_Io""""' ..... ~ ........ ~ .. --" ... ".,.,... 
133 


'''.''''''~ 

S/lroclttloo _ CfP-1H.cron (. Om MWlerr.trll Plan "" .. _t(,.,.,-..... ,. ,.ojort ..... ,....-I-··-"""o(...., ......... 
134 


ScIIcilItlOO1' tFp.IH.(XXIOl K. Om /dfnIlemtflt P'olI. "".,_of...-. .. IftIO_.ooI/O«., ... ~--... ,.,.,-t/ ... ..,...,. 
135 


OI ~ ,vtLll W(II''''''lion & IuMl4lry Sertite'l ~ 1 of 29 

SoICftRion,cr'·12·R-«O)I K.tliIU,....4~,.. 

..... -<l~ .... -.......... ~-~ ... --<lofoj--
136 


roNfIOH'll.l.l 

ot:tror.ArI'" Infumobon & ~1.e'oIceI P~ of 19 

So'ici\i~.CfP·12 ~ K.DatJM~Pbn 

.... -<l .............. -~-.... .......-,-.... --.""'-
137 


CONFIOINTW. 
138 


COlfR""tmAL 

OIffror: .... "'IIr>.fomlOl;", $. Aoll'i$Oot s.rv.tcl: 

SoIdI,,:ion I (fP·12·MlmL ... .,_.,.....-.. tIII_ • ...",. .. ,.._,_ Jo ... __ .,OfIol __ 
139 


~flDEfl'TlAl 

OIf ror :Ari ~lnIormo "" ~I'j~1 r,..l101~ 

SoIidIJlioII' (JP- 12-MOll1 It C!atJ 1obt\ti~1 PIon 1Ior"_ • ...-.. __ ........... ,.".-,_ ... __ ... 

-
140 


CONfiDENTiAl 

Offfror:ArcuI ""_tion'AcM!ofySenim '. UIII2t 

5oItbIicIIt'O:P·I2-.';-O:IOO1 K. [W; ~trltl1l PI.., 1Iot._f(~""_~"""", ... -...-._ .. IIt __ f("," 

-
141 


CQf*jO£NTlIIl 

OIferor:"'C",Wctm.:on'~s.mm PIce 13 c129 

5okill~' CfP. !l·~·ro:Xll t:.!lo\J "'"'iif'l".ffll1Ian .... "_oI"'_ ..... _Io...., ... noj;I<oIioio7_It ... __ oI ... 

-
142 


'.ht.,_o/ ......... ""'_Io_' ..... ,~_~ ...... _o/ .... 

-
143 


CONFlDHfllJIt 

OCitlor:AIJII!oI"'O!II'IttIO~&~Sa'¥Qs PlltlSoili 

Soiitili:ion I U'·Il·R-OOOOl l. 0Ml "'-CenonI r .. \Iot"_".,..... .... _ ........... ~_,, ... __ </ .. 

-
144 


CONFIOfImAl. 

OIfttor: A1i1lS W~ & Mmc.y So!N:"" Pli' 16 0129 

5o:!c;tal:"" f m·U·R-«IOO1 K. 0iIt1 ~ ~ ..... _ ........... ,.,._ ........... -,_iII ... __ ., ... 

-
145 


COI!FIQ(1I11AL 

~ AlJUlIiI.'oolllllioll "'.t.d¥bo<y Slnice$ 

5oi;iI.fon. UP-1 2·A.oDlJ 

...... _f/~ ...... _.M}«, .. II<~I_ ..... _"''''ff ... 

-
146 


COIIFlDEHllAl. 

ctr .. e<: ""'" Wormllion & AIMsory Strtict> Pip 180(29 

So':(,U1:loo' UP·ll·R-OOOO1 K. Om l1"'il~:ntfl1 Ph" ..... _" __ .. OOio_~ooI;<f<I .... ~_ ... __ I( ... 

-
147 


C()!:IF IOENTIAL 

()I!eror ""'" ~, M<:sory 5MiuI 

So6d'.tlt011l ap.ll·UllXlI "" .. _"_ ... ,.,. _ """" ..... __ )0 ..... ,,,..,"',, .... 

-
148 


l ~"~emtr. !'bo1 10< .. _._ ...... ,.,,_,,"' ......... ...-."' __ ... 

-
149 


"' ... ,""" 

.... "'_o/....-..... __ ........ 0110~_~. '""'_<1 ... -
150 

151 


-
152 

153 


hp2lo1/9 

1.D;a1l~1'!.I" """_oI_ .. .,;,_ .-;r<t··~_·· __ oI'" 

-
154 


CDNflt>fNlIAl 

OIltror. AI£ljslnlon..:ion & ~t ~ 

5clal""" I CJP·ll·A-OOOOl 

"," .. _~~ ..... _ • ...;..t ..... ~_~,.. ..... _t{ ... 

-
155 


CONFIOEHTlAL 
156 


@ADENTTA\ 

Of.t«f: Atl,\ Wono-~ ' MriIo<y SeMm 

ot~~ation t(ff· ll-R·OC(IO 1 ""' .. _1/....-..... _ ..................... _.,.. __ 1/ .. 

-
157 


CONflOI'NTlAl 

OIferor: "'JUS~'" & AcMsorv SeMl:el Soki~:Ion I CfF·lI*OOX11 

... "-

. .-.",,,- .... .......-.-~ ... --... -
158 


(ft.~I __ "-' ___ uq 

CioIIdo, ___ ............ w ... ~~""" 

_~"'"'(looIr_"'" 

ATTAOt\IDlTl 

DATA QUAIJJY MANAGEMENT PLA.'l 

c....~ __ 
159 


~""",_ ____ • .....,~u.a ~ ... _ .... ~~11000 

_~DoooI!oo!OJ~'" 

nus pAQf 1Nmo11O)Wl Y LEFTBI.A.\'X 

1 ... ----· .... 
160 


CQNFIQ(JITIll 

r';1 

WARGUS 

L - Data Quality Management Plan 

Collection, Transmission, Validation, Aggregation, Reporting, 

Storage and Ana lysis of Credit Card Data 

ou ... or. A'IVIIf\f(M'rM(;on & AdvilOt'yStMm 

Solki'.niorl, CI~·l1-R.(((IOt 

ib< .. _"....-..... _~ ... ,«t .... ,~_" ... __ .,.;,,,.,.. 
161 


COtlFltlHmAl 

CoJllfli~U'oi T,Jdemiri 

Copyriltlt C lOI2 AlrJS WonuUo.ul Mrisory ServUs, lie. Iio jlI<tofllileot:/!llfnl mIT 

be reJ),xoteO, ltorfd in J ret,,".1 'I'1re!'n Q(111"""'ilttd .., Jny1«m or by IIfi """1'11, 

eIoctnlrk.~~~~orctr.r.ise..,;:!tou!W\'ItretI 

iIf' ''''nIor1 from All ... 

AriUS b J "Iistf-.d rracI!-': of AqIo> Infonntiao ¥.<I ArMlory St~ lIC. MIIlI!tr 

c:ompanf.-.d ~ _,re usee' for idtnti/bllotlpurpcses crly."d nwt ~ Il'IdtmH'<l 

ofltlti'oomrN. 

MJ"'W<nIM!on' MiMt'/5fntm.. LtC 

SOMoInJ.trffl 

Slar I11S 

'M'Iik JIIIIm. ~ lO606 

(914)307·l1OO 

Wtror AlII" wmMlon & AdoiI«y SMicts hce I 01 U 

So!ldt.ton.OP·IH.(IlOO! 0111 Qu'" MiI'Ilritrnt:l'l l'lion 

..... _fl_ ..... _ilroojf<t ..... ,...-,_~* __ fl~_ 
162 


OOIf'Or:"'lUIWOfIllillon&~5fMo!1 P.2of l3 

SoItImiorl ' Cfp·U·MIXIOI l·OIU~"~1IM "" .. _ • ...-..... _· .......... ~_ ..... __ fl .... ~ 
163 


St>!:ti:'tion I (fP.1J.R-OOXIl l· (»1. Qual~ M. !to1eM Pl,n .... "_,,~.., .. _,,_., .... ,.,.,,...,..,_~ .. l<t"'</""' ~ 
164 


CONFID!HI1Al 

1Io._ ............ IfIio_il_ ... ~_il ... __ "IM,..,.... 
165 


(OHFlDEH'I1Al 

OOffor:Af"alrllormifon" AIMsoorrSfMcI'S hr&t OJ 01 U 

5okltlf,,, I Cff-12-R-«IOO1 I· om Qul:ty ~l ~ "".,_ ... <I"ftw_ .. '*" __ ............. "' _~. _ _ <l~-" 
166 


CONFlO!NTIAl 

l -()ata CM ioty MlI1jgemeol Plan 

"" .. _oj~ .. <;i<_~"","""",~""""'~"""""_f/IIO~ 
167 


(ONFIDnfflAt 

SoI~a~li"" iI CF~ 2-1\4l101 l . Doll Q:Ji%,- Man"! ...... 1 p~ """_o{""'_ ..... _~...,." .... ~_ "",'_"""o{""~ 
168 

169 


Off«w: Arp;JWomIat 01\& ~ SfM<M 

SoIc~,"oon' C:P-12·R IXlIOI 

P..,h'U 

Dr",Q;*YMI~1'IItt 
170 


Soidtatiorll CFp·l1·R4)XI1 L· DII.I O'.IIoI:f ~~...c :M'. 

...... -"~ ..... ,.,.-""""" ... -.,"'-)< .. --,, ... ~ 
171 


OOtlor AI"" lr.'lImIItion l AIIfiooryStMu! 

Solid •• a:p·!H.aDlI 

~11ol13 

l'()au~~"" "" ... __ .iiOt_"""'_~_''' ''' ~_''''''''''_.''''' __ 
172 

173 


OIfftor: "'evs ~!io" lAlMlor! SfMI:« 

SoIiti".Jtio ~. CFP·1H-OOOOl 

P,itUoIU 

0.11 (kJ.olq M~'lijfmer~ PIa ~ 

.... -~...-... -~ .......... ........,.-..... --~ .... -
174 


mu .. \IqI ......... Abo)S<-.:;q 

UDo. '-"":t r.w.::.~~llo.J. .. hjgf::.ac.o!oo 

hobI \,...~ 

ATI.lI:lL\IDITl 

flFUI1Q,i11M 
175 


~~Waioo._-''''",IIQ 

~ __ ~"ir9."''''((&(;ih­

-V-/.9b 
176 


~J(_II;Jr;HuoaIll_""'!:W 

c.b,~r"*~.lt<r5flr9"~"""c.or.. 1ClrI, ..... ~ 

CiJ'ilrdi~-CteilCdb 

f=II~bclJd' ib:5ix[llasi:fml.i:I; 

."-1Wt n..ooIe'!.."..' bir«Nl'a.;m:_ ''''''''''''''-''''-!oI; bn.w!leMi .... 

=~Sror'("'rilrf.!sr.~""'.ircir.dIll."""aillll~llk.t.'iI!dlfjE1i11.\11.llt,~ 

fit ~ rt &B b it ~ 4111 &18 R!!;r:III aW.".. DiIIlIIPtJ be lIprtII (l i ~ IS 

ImUlallk~m~_IttW!!!1mlle~6im.ktP.l\YIIf~l5i:. 

t!dr.ii:tim.Mm:u;o~"It~iifd!I!~z:ma.:·t"b~ll_lbi 

~"'llilllllbotb!fM'tW.!ftlGllt.(I'mU::")'~MI~jIOOI.~klicl!liiun. 

Ib1! Ikdd IZI!' It ~ b !Ii:wi111 ~ ItA 3i:ti.I em iktIIQ:\oio. ClXfl* r"i ~ d ;cd br: 

~1I"'lilihxa:l::.r.a(!l.,i:bW:-.!lF.,I_!ml1t,~~)FaPCt".m~ 

• CU I .... ·ltizib::lrlr.dDII:!f ...... &It:"'''''~:al~ob:.1Eitfr.:ir •• :;,. .. 

• 1IIIit::...... !km.lIIkClli6:{l..CIIl·_IIkdt)3G$r!'Ii 

, .... "'" {MjiriitU"bIIkI~~ jK>Nir.ur"lP='- j!iilil!ri:: 

I 

lI!k~"~~iil:IDo.~l:r:d~\ t:i""lcWhbd""" 

, nl:d vrttrlll llljliqlllJi:riMtlXllllllll."GI.l'Il31I11fi11l*_fdI 

~1Ir.ir_m-"Rpn'I'<i ~&.~_a;. •• lIlIibl(ri 

EkIl;Or;,~IIIIt( It.Cpm:;If3II:aJ.'S. 

, .. I 

!l:s:.,._ 

f~:'IaI:S 

, ... , 
177 


(E'. :<.]lIJl.iWol':~"""'LLO 

~, t.oor ... I<:.br.w.. ~lIJqt ot! .,.I{&t!t~ .. 

. b:2»:~ 'r'J""""" 

i ~ I rtf 

~iltlEl'lIII~tI:tIl6c_ W_1!' <W!"I'l"Jl!"'lklJtln...:~ to 

flAlil"tIIIttmi:lll"''A.i-r:(lis .. ~;'''~irOlcm 

l UeQ,CdT • , . ~ - -. . • • ~ .. iZtr:c ..... •· , il!al~.:erDI=> .u:t1ll1:~cri.IIis\:ao:jpC."lEjtZl!!!~\l 

I t'liI:~c.i·Il:!Ii'lDlll~co.it =~riIr.~·:S~ri"II;:r* 

~.jlDytme"",~gblllpr.~ .. 01tII~!ldriltilfoil.t:lJt 

, Nlit(uil~~ 

lqIlt ,Q~i:"'itt~ 'f.!I'I"t 

MrJ 

, 1lmI l)~ 

. ~OO DlGl; 

~.IJb<' 

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Blackbox Logic LLC 


AMENDMENT OF SDLlCITA nONIMODIFICA nON OF CONTRACT I t CONTRACT 10 CODE I PAGE OF PAGES 

I I I 

2.AMENDMENTIMODIFICAnQN NO 1~· FFECTlVEOATE 4. REQUISITIONIPURCKASE REO. NO 15. PROJECT NO. (If appbbM) 

0001 10/05/2011 

6 ISSUED BY COOE LSPD- AZOLLER 1. AOMIN1STEREDBY(.Ither/tlanI/em6) coo, iSPD 

Bureau of the Public Debt Bureau of the Public Debt 

Division of Procurement Division of Procurement 

Avery SF Administration Branch 

200 Third Street Avery SF 

Attn : A. Zoller 200 Third Street 

Parkersburg WV 26101 Parkersburg WV 26101 

8. NAME AND ADDRESS OF CONTRACTOR /No.. SheI, CO\IlI)". Slll,utld l1P CldI) (xl SA. AMENDMENT OF SOLICITATION NO 

SLACKSOX LOGIC LLC 

1200 11TH STREET SUITE 880 !lB. DATED (SEEfTEM tl) 

DENVER CO 80202-5826 

x IDA. MODIFICATION OF COHTRACTIORDER NO. 

TPD- CFP- 11 -C-0012 

lOB. OATEO (SEE ITEItf f3) 

CODE 004938321 jFACIllTVCOOE 09130/2011 

TheaboYel'l.ll'flt:ler8sok:ita1ionlli~a5setIorthI'lItem14. Thehourandda(eIpldfieclb"IDpta/OOers tSextena~. D llnoIlxlended 

O!Ier$mU$l~dgereceiploflhi.amenctneotj:QJr\o"'l'IolI'anddlte~edin .... 5OIk:tta!ionorlltlllll8l1deG,byonea/lh8fo1ow!ngmelhods: ('IBycompietiog 

l\em.e.,dlS,andrelooWlg copie$o/thermendn\e(\t(b)ey~glngreceiptolttj.amendmen1011eactlOlpyctltlBoIIer&l.tmlted:or(c)8y 

separate letter ortelegwn which incIucIesa reference!01he lIOIicitalionand amendment mtnbel'l. FAILURE OF YOUR ACKNOWlEDGEMENT TO BE RECEIVED AT 

THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN RE.ECTION OF YOUR OFFER. Wby 

Yirtueollhisa'Tl8l"lClnentyoude"lod\angeanctlef~IUMlitled.sud"ldlangellllYbemadeb'flelegramorlell .. prOYIdecIe8Chle~orletl"lTIIkesrr.erenc:e 

!O""so5dtItionandlhi$~andilreceivedprior!olhtopenilghcManddaiespedfied. 

12. ACCOUNTING ANO APPROPRIATION OATA (/I reqWed) 

See Schedule 

13. TKS ITEM ONLY APPUES TO MODIFICATION OF CO NTRACTS'ORDERS. IT MODIFIES THE COHTRACT/ClIUlER NO. AS DESCRIBED IN ITEM 14. 

~ A. THIS CHAHGE OROER IS ISSUED PURSUANT TO: (SpedfyIHlltMyJ THE CHANGES SET FORTH IN ITEM l~ ARE MADE IN THE CONTRACT -_._. ORDER NO. IN ITEM lOA. 

B. THE ABOVE NVMBERED CONTRACT.()RDER IS MQOFIEOTO REFlECT THE ADMINISTRATIVE OiAttGES(such as cnanges in paying alb. appropriation date, IIIC.) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.1ro(b). 

C. THIS SUPPlMENTAl AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF 

14. DESCRIPTION OF AMENDMENTIMODlFICATION (Orga~led by UCf secIion headings, incl!lCing SQfcilatioob:lrltract subject ma/lef whefe feasible.) 

The purpose of this modification is to change the Contracting Officers 's Technical 

Representative (COTR) from Rich Horn to Xiaoling Ang. Xiaoling can be reached at 

202-435- 7686 or vi a email at Xiaoling.Ang@cfpb.gov, 

Period of Performance : 09130/2011 to 09/29/2016 

15.\ NAME AND TtnE OF SIGNER (Type orpridJ 1SA. NAME ANDTTTlE OF CONTRACTING OFFICER (TypeorptiriJ 

158. CONTRACTOR/OFFEROR 

NSN154O-()1·152-aOl0 

P!"e14oul.artionl.A/Silble 
283 


AMENDMENT OF SOUCITATIONIMODIFICATION OF CONTRACT 11. CONTRACT 10 CODE I PAGE OF PAGES 

1 I 1 2. AMENDMENTIMODIFICATION NO. i;' EFFECTIVE DATE 4. REQUISrnONIPURCHASE REQ. NO r PROJECT NO. (If applicabfe) 

0003 04/18/2013 

6. ISSUED BY CODE IBPD-RDILLON 7. ADMINISTERED BY (lfolherlhan Item 6) CODE IBPD 

Bureau of the Public Debt Bureau of the Public Debt 

Divison of Procurement Di vision of Procurement 

Avery 5F Administration Branch 

200 Third Street Avery 5F 

Attn: R. Dillon 200 Third Street 

Parkersburg WV 26101 Parkersburg WV 26101 

8. NAME AND ADDRESS OF CONTRACTOR (No .• "'"'- """"Y. StaIoItId ZIP Codo) (x) 9A AMENDMENT OF SOLICITATION NO 

- BLACKBOX LOGIC LLC 

1200 17TH STREET SUITE BBO 9B. DATED (SEE ITEM 11) 

DENVER CO 80202-5B26 

x lOA. MODIFICATION OF CONTRACTfORDER NO 

TPD-CFP-11-C-0012 

lOB. DATED (SEE ITEM f3) 

CODE 00493B327 I FACILITY CODE 09/30/2011 

11. THI ITEM o L N YAP PUESTO AM END M E N F TSO so UCITA TlONS 

OThe-'numberodsolici1ationisamendedasseiforthinttamI4. The hoJ,and dale spec;roed fa receipI of Off... O~ex1ended. Oisnotex1ended 

Offers musl ed<rWIedge receipl rllh~ amendmenl prior 10 Ihe hoJ, and date specifoed in Ihe soIK:ita!ion a as arnandod. by one of Ihe following melhods: la) By """plating 

Items 8andl5.andrelllning __ copiesoflheamen<fmenl;(b)Byad<nowledgingreceiplof~amendmenioneachcopyoflheollerS<lbm~ed a(c)By 

sep<nI.~tteratelegram wtlicI1 includes a reference to Ihe solicitation ancI amendmenl numbers. FAILURE OF YOUR ACKNOVvl.EDGEMENT TO BE RECEIVED AT 

THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER. «by 

virtue of Ihis emendmenl you d .... to c:Ilange en oller already S<lbm~od, SlJCh change may be mode by telegram a lette" provided eech telegram Of letter makes reference 

to Ihe SOlicitation and Ihis amendment. and ~ receivod prior to Ihe opening hoJr and date spec;roed. 

12. ACCOUNTING AND APPROPRIATION DATA(" required) 

See Schedule 

13. THIS ITEM ONLY APPUES TO MODIFICATION OF CONTRACTSIORDERS. IT MODIFIES THE CONTRACTIORDER NO. AS DESCRIBED IN ITEM 14. 

~ A lm8E~':~~ ~~~Ef~ ISSUED PURSUANTTO (Spedfy authority) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT 

B. THE ABOVE NUMBERED CONTRACTIORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as cl!anges in paying o/fial. approplilllion dafe, e/c.) SET FORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b) 

C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF 

D. OTHER (~fy fypaof moc1i6callOn and autholify) 

E.IMPDRTANT: Contractor !!lis no!. Ois'BGU"edtosignlhisdoannentendretum copiestotheissuingoffa 

14. DESCRIPTION OF AMENDMENTIMODIFICATION (Orpanized by UCF section headings. incfucfing soiicitallOn.tonfract wbjed ma/le( wile .. feasibfe.) 

The purposes of t his modification are to: 

1. Appoint Jessica Russell as the Contracting Office r's Representative (COR). Jessica may 

be reached at 202-435-7771 or via email at Jessica. Russell@cfpb.gov. 

2. Appoint Xiaoling Ang as the Al ternate COR. Xiaoling may be reached at 202-435-76B6 or 

via email at xiaoling. ang@cfpb .gov. 

Period of Performance: 09/30/2011 t o 09/29/2016 

Except as provicfedhenln, aU term. and conditions of the docunenl referenced in Item 9AOf tOA. as heretofore changed, ramains II1Chenged and infuillorce and effect. 

1SA NAME AND TITLE OF SIGNER (Typeorplint) tSA. NAME AND TITLE OF CONTRACTING OFFICER (Type orplint) 

158. CONTRACTORfOFFEROR 

NSN7~1.t52-«l70 

Pravious edilion unusable 

JACOB C. OBERLIN 

15C. DATE StGNED 16B. UNITED STATES OF AMERICA t6C. DATE SIGNED 

?~ 4.18.2013 

~01~~ 

STANDARD FORM 30 (REV. 11).83) 

P,esaibedbyGSA 

FAR I4BCFR) 53.243 
284 


AMENDMENT OF SOUCITAnONIMODIFICAnON OF CONTRACT r' CONTRACT 10 CODE I PAGE OF PAGES 

1 I 1 

2. AMENOMENTIMODIFICATION NO. I;' EFFECTIVE DATE 4. REQUISmONIPURCHASE REQ. NO. X' PROJECT NO. ("applicable) 

0001 04/18/2013 

6. ISSUED BY COD~ IBPD-RDILLON 7. ADMINISTEREP BY (" oilier //Ian Item 6) CODE IBPD 

Bureau of the Public Debt Bureau of the Public Debt 

Di vison of Procurement Division of Procurement 

Avery 5F Administration Branch 

200 Third Street Avery 5F 

Attn: R. Dillon 200 Third Street 

Parkersburg WV 26101 Parkersburg WV 26101 

8. NAME AND ADDRESS OF CONTRACTOR lNo .• """ """'Yo _ItIdZIPCorJe/ . ~ 9A. AMENDMENT OF SOLICITATION NO 

BLACKBOX LOG I C LLC 

1200 17TH STREET SUITE 880 98. DATED (SEE ITEM 11) 

DENVER CO 80202-5826 

x lOA. MODIFICATION OF CONTRACTIORDER NO 

TPD-CFP-11-C-0012 

120002 

lOB. DATED (SEE ITEM (3) 

CODE 004938327 I FACILITY CODE 09/13/2012 

11. THIS ITEM ONLY APPUES TO AMENOMENTS OF SOLICITATIONS 

OTheabOve"'mberedsoiicilBllOl1umended .... lloI1hn Ilem 14. The hour end dal. specifl8d far recetpt of 011.... O'S.xlerded. O~nolexlended 

OIlers mus1 acI<nowfedg. receipl of !hi, emendmeni prior 10 !he hoor and daI. specifl8Cl in !he soiicilation or .. amended. by one of !he loIlowing melMds: (a) By completing 

11ems8andlS.endrollming __ copiesoflh.amendmenl;(b) Byad<nowleclgingrec:oiploflhisamendmenioneachcopy of!heoffOfsubmillad;ar(c) By 

separat.Ie1IOf or lelag .... whidl include. a reference 10 !he soiicitalion and amendmenl numbers. FAILURE OF YOUR ACKNOVltEDGEMENT TO BE RECEIVED AT 

THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER. If by 

virtue of Ihis amendmenl you desir.1O change an offar 'Iready ,"bm~ed, such change may be mad. by lelagram or ~H"', provided .. eIllalagram or ledar m,kes refer"""" 

10 !he solidlelion and Ihis amendment end is received prior 10 Ihe opening hour and dala specified 

12. ACCOUNTING AND APPROPRIATION DATA (If tequired) 

See Schedule 

13, THIS ITEM ONLY APPLIES TO MODIRCATION OF CONTRACTSIORDERS, IT MODIRES THE CONTRACTIORDER NO. AS DESCRIBED IN ITEM 1" 

~ A THIS CHANGE ORDER IS ISSUED PURSUANT TO: (Spacily aulhotity) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT ORDER NO. IN ITEM lOA. . 

B. THE ABOVE NUMBERED CONTRACTIORDER IS MODIFIED TO REFLECT THE ADMINISTRATIVE CHANGES (such as changes in paying oIfice, apptOpIialion dale, aft.) SETFORTH IN ITEM 14, PURSUANT TO THE AUTHORITY OF FAR 43.103(b) 

C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF 

D.OTHER(SpaciIy/ypeof_lionandaullloti/y) 

E.IMPORTANT: ConIradot l!I~not Oisr8CJl"edlosignlhisdocumeniendrelum copieslolheisS<Jingoff .... 

14, DESCRIPTION OF AMENDMENTIMODIFICATION (Of9aniled by UCF section heedings, inducting sclicilaIion.tontraClsubjact mailer wIIeIe Ioasible.) 

The purposes of this modification are to: 

1. Appoint Jessica Russell as the Contracting Officer's Representative (COR). Jessica may 

be reached at 202-435-7771 or via email at Jessica .Russell@cfpb.gov. 

2. Appoint Xiaoling Ang as the Alternate COR. Xiaoling may be reached at 202-435-7686 or 

via email at xiaoling. ang@cfpb.gov. 

Period of Performance: 09/30/2012 to 09/29/2013 

ExcepI .. providedhllfein aalllfm.endCOt'dilionsoflhedoc:umenirefarendedinttem9AorlOA.ashereio/,,",cI1anged,remains~andinfulifarceandeffect. 

lSA NAME AND TITlE OF SIGNER (Type or plinf) 16A NAME AND TITlE OF CONTRACTING OFFICER (Type Of plinf) 

158. CONTRACTORIOFFEROR 

NSN750Cl·152ol1070 

Premus ediIion unusable 

JACOB C. OBERLIN 

1SC. DATE SIGNED 16B. UNITED STATES OF AMERICA 1SC. DATE SIGNED 

____ r~____ 4.18.2013 

l_oICotIIrdIgOb:! 

STANDARD FORM 30 (REV. 10.83) 

Presai1>ed by GSA 

FAR (48 CFR) 53.243 
285 


BlackBox Logic LLC 

ATTN: David Feiner 

DEPARTMENT OF THE TREASURY 

BUREAU OF THE PUBLIC DEBT 

PARKERSBURG, WV 26106-5312 

September 30, 2011 

Subject: Award of Fixed Pnce Contract 

Contract #: TPD-CFP-11-C-0012-loan Level Mortgage Text File Data 

Dear Mr. Feiner. 

Congratulations! BlackBox Logic LLC has been selected to fulfill the requirement for Loan Level 

Mortgage Text File Data sets for the U.S. Department ofTreasury on behaff of the Consumer Finandal 

Protection Bureau (CFPB). We are enclosing a copy of the award document. 

Please review the enclosed Contract and ff in agreemen\ please complete blocks 30a, 30b and 30e on 

Page 1 of the. Standard Form 1449. By signing the SF1449, you acknowledge and accept the terms and 

conditions of this Contract. After signing the document, please retum a copy of the signed form back to 

me either electronically at psb3@bpd.treas.govATTN: Angie Zoller or via fax to (304) 48()'7204. 

The designated Contracting Officers Technical Representative (COTR) will be Rich Horn. Rich may be 

contacted at 

Consumer Financial Protection Bureau 

ATTN: Rich Horn 

Fifth Floor 

1801 L Sl NW 

Washington, DC 20036 

PH: 202-435-7406 

Email: Rich.Horn@treas.gov 

A copy of the deSignation letter that details the COTR responsibilnies and the scope of their authonty are 

enclosed for your records. 

Mr. Alan Dotson will be the Governments Administrative Contracting Officer (ACO). He may be reached 

at (304) 48()'7206. Ms. Bemadette Kem Will be the aHemate ACO and she can be reached at (304) 48()' 

7003. All administrative staff can be emailed at contractadministration@bpd.treas.gov, referencing 

Contract# TPD-CFP-11-C-0012 and the correct contact name in the subject line. The fax number for all 

contacts is (304) 48()'7204. 

If you have any questions conceming this award, please contact Ms. Angala Zoller at (304) 480-8954 or 

psb3@bpd.treas.gov, referencing Contract # TPD-CFP-11-C-0012 AZ in the subject line. 

Enclosures 
286 


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This IDIQ contract is awarded for a bq.se year of 

12 mont;hs and four option ye~r periods. 

Funds will be obligated when a task order is 

issued. 

Task order.s may be issued for any items/services 

listed on Attachment A - Master Service 

Agreement. 

Contracting Officer Technical Represesntati ve 

(COTR) is Rich Horn 

202-435-7406 

Rich .Horn@cfpb.qov 

Technical POC: 

Ron Borzekowski 

Phone : 202-435-7381 

Email: Ron.Borzekowski@cfpb,.gov 

Invoicing will be in advance at the 'beginning of 

the each month for all re'quirements except 

Professional Services. Professional services 

will be Net 30 in arrears. 

Supplemental Clauses, PWS, and Master Service 

Agreement are attached hereto and incorpQrated. 

Continued ... 

32aQUANTITY INCOLUMN21HASSEEN 

21. 22. 21 

QUANTTTYUIIT utlTPRICE 

DRECEIVEO D'NSPECTEO 

ACCEPTED,AND CONFORMS TO THE CONTRACT, EXCEPT AS 

DNOTEO 

2 of n 

32b.SIGNAT\JREOFAIJlliORIZEDGOVERNMENTREPRESENTATlVE I 32c. DATE 32~. PR NTED NAME ANDTlTlE OF AIJlliORIZEIl GOVERNMENT REPRESENTATIVE 

32G,MAllINGAODRESSOF AIJlliORIZEIlGOVERNMENTREPRESENTATlVE 

33. SHIP NU~IElER ~. VOUCHER NUMBER 

DPARTIAl DFINAL 

l5,AMQlJNTVERIFIED 

CORRECT FOR 

38.SlRACCOUNTNUMBER 39. 5IR VOUCHER NUMBER 40. PAD BY 

321. TElEPHONE NUMBER OF AIJlliORIZED GOVERNMENT REPRESENTATIVE 

32g.E.J.IAll.OFAlITHORIZEDGQ\o'ERNMENTREPRESENTATIVE 

o COMPLETE 

I 37. CHECK NUM8ER 

DPARTlAl DFINAL I 

41a I CERTIFY THISACCOlMr IS CORRECT AND PROPER FOR PAYMENT 42.1. RECElVED ElY'(Prim) 

41b,SIGNAT\JREAMlTlTLEOFCERTlFYINGOFFICER 41c.DATE 

42b.RECEIVEDAT{l..tlCatiMJ 

f42c. DATE REC"O (yyM!MlOJ j 42d TOTAL CONTAINERS 
288 


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52.212-4 CONTRACT TERMS AND CONDITIONS -- COMMERCIAL ITEMS (JUNE.2010) 

(a) Inspection/Acceptance. The Conlractor shaH only tender for acceptance those items thai conform to Ihe 

requirements of this contract The Government reserves the right to inspect or test any supplies or services 

that have been tendered for acceptance. The Govemment may require repair or replacement of 

nonconforming supplies or reperformance of nonconforming services at no increase in contract price. If 

repairlreplacement or reperformance will not correct the defects or is not possible, the Government may 

seek a"n equitable price r~duction or adequate consideration for acceptance of nonconforming supplies or 

services. The Government must exercise its post-acceptance rights-

(1) Within a reasonable time after the defect was discovered or should have been discovered; and 

(2) Before any substantial change occurS in the condition of the item, unless the change is due to the 

defect in the ilem. 

(b) Assignm~nt. The Contractor or its assignee may assign its rights to receive payment due as a result of 

performance of this contract toa bank, trust company, or other financing instiMion, including any Federal lending 

agency in accordance with the Assignmenl of Claims Act (31 U.S.C. 3727). However, when a third party makes 

paymenl (e.g., use of the Govemmentwide commeTtial purchase card), the Contractor may not assign ns Mghts to 

receive payment under this contract. 

(c) Changes. Changes in the term_s and conditions of this contract may be made only by written agreement of 

the parties. 

(d) Disputes. This contracl is subject to the Conlract Disputes Act of 1978, as amended (41 U.S.C. 601-613). 

Failure of the parti,es to this contract to reach agreement on any request for equitable adjustment, claim, appeal or 

action arising under or relating to this contract shall be a dispute to be resqlved in atcordance with the clause at FAR 

52.233-1 , Disputes, which is incorporated herein by reference. The Conlractor shall proceed diligently with 

performance of this conlract, pending final resolution of any dispute aMsing under theconiracl. 

(e) Oefinftions. The clause at FAR 52.202-1 , DefinItions, is incorporated herein by reference. 

(Q Excusable delays. The Contractor shall be liable for default unless nonperformance is caused by an 

occurrence beyond the reasonable control of the Contractor and without ns fault or negligence such as, acts of God or 

the public enemy, acts of the Government in either its sovereign or contractual capacity, fires, floods, epidemics, 

quarantine restrictions, strikes, unusually severe weather, and delays of common carriers. The Contractor shall notify 

the Contracting Officer in writing as soon as ~ is reasonably possible after the commencement of any excusable 

delay, setting forth the full particulars in connection" therewith, shall remedy such occurrence with all reasonable 

dispatch, and shall promptly give written nolice to the Contracting Officer of the cessalion of such occurrence. 

(g) Invoice. The Contra'ctbr shall submit an original invoice a'nd three copies (or electronic invoice, if authorized,) 

to the address designated in the contract to receive invoices. An invoice must indude0) Name and address of the Conlractor; 

Oil Invoice date and numbe" 

Oii) Contract number, conlract line item number and, ~ applica~e, the order numbe" 

(iv) DescMplion, quantity, unn of measure, unit pMce and extended pMce of the items delivered; 

(v) Shipping number and date of shipment, including the bill of lading number and weight of shipment if shipped 

on Govemment bill of lading; 

(vi) Terms of any discount for prompt payment offered; 

(vii) Name and address of official to whom payment is to be sen~ 

(viiQ Name, tffie, and phone number of person to be notified in event of defective invoice; and 

(ix) Taxpayer Identification Number (TIN). The Comractor shall include its TIN only ~ required elsewhere in this 

contract. 

(x) Electronic funds transfer (EFT) banking information. 

(A) The Contractor shall include EFT ban.ng information only ~ required elsewhere in this conlracl. 

(8) If EFT banking information is not required to be on the invoice, in order for the invoice to be a proper 

invoice, the Contr!3ctor shall have submitted correct EFT banking infomiation in accordance with the applicable 

solicitation provision, comract clause (e.g., 52.232-33, Payment by Electronic Funds Transfer-Central' Contractor 

Registration, or 52.232-34, Payment by Electronic Funds Transfer-Other than Central Contractor Registration), or 

applicable agency procedures . 

. (C) EFT banking information is not required ~ the Govemment waived the requirement to pay by EFT. 

(2) Invoices will be handled in accordance with the Prompt Payment Act (31 U.S.C. 3903) and Office of 

Management and Budget (OMB) prompt payment regulations at 5 CFR 1315. 

(h) Patenf indemnity. The Contractor shall indemnify the Govemment and its officers, employees and agents 

against liabilily, including costs, for actual or alleged direct or conbibutory infMngement of, or inducement to infringe, 

any United States or foreign patem, lrademarl< or copyrighL aMsing out of the performance of this contract, provided 

the Contractor is reasonably notified of such claims and proceedings. 

(i) Payment. (1) Items accepted. Payment shall be made fot items accepted by the Govemment that have been 

delivered to the delivery destinations set forth in this contri3ct. 

TPD-CFP-11-C-llQ12 
292 


(2) Prompt payment. The Government will make payment in accordance with the Prompt Payment Act (31 

U.S.C. 3903) and Office of Management and Budget (OMB) prompt pay regutations at 5 CFR 1315. 

(3) Electronic Funds Transfer(EFT). If the Govemment makes payment by EFT, see 52.212-5(b) for the 

appropnate EFT clause. 

(4) Discount. In connectiorlwith any discount offered for early payment, time shall be computed from the date. of 

the invoice. For the purpose of computing the discount eamed, payment shall be considered to have been made on 

the date which appearS on the payment check or the spe~fied paym¢nt date if an electronic funds transfer payment is 

made. 

(5) Overpayments. If the Contractor becomes aware of a duplicate contract financlng or invoice payment or 

that the Govemment has otherwise overpaid on a contract financing or invoice payment, the Contractor shall-

(i) Remn the overpayment amount to the payment office cned in the contract along with a descnption of the 

overpayment including the-

(A) Circumstances of the overpayment (e.g. , duplicate payment, erroneous payment, liquidation errors, 

daters) of overpayment); 

(B) Affected contract number and delivery order number, if applicable; 

(Cl Affected contract line nem or subline nem, if applicable; and 

(D) Contractor point of contact. 

(il) Provide a copy of the remittance and supporting dO(:Umentation to the Contracting Officer. 

(6) In/erost. 

(i) All amounts that beoome payable by the Contractor to the Go.vernment under this contract shall bear 

simple Interest from the date due until paid unless paid within 30 days of becoming due. The interest rate shall be the 

interest rate established by th.e Secretary of the Treasury as provided in Section 611 of the Contract Disputes Act of 

1978 (Public Law 95-563), which is applicable to the penod in which the amount beoomes due, as pro~ded in (i)(6)(v) 

of this dause, and then at the rate applicable for each six-month penod as fixed by the Secretary until the amount is 

paid. 

Oil The Government may issue a demand for payment to the Contractor upon finding a debt is due under the 

contract. 

(iii) Final decisions. The Contracting Officer will issue a final decision as required by 33.211 if-

(A) The Coniracting Officer and the Contractor are unable to reach agreement on the existence or amount 

of a debt within 30 days; 

(B) The Contractor fails to liquidate a debt previously demanded by the Contracting Officer within the 

timeline specified in the demand for payment unless the amounts were not repajd because the Contractor has 

reqt,Jested an installment payment agreement or 

(C) The Contractor requests a deferment of collection ona debt pre~ously demanded by the Contracting 

Officer (see 32.607-2). 

(iv) If a demand for payment was previously issued for the debt, the de'mand for payment included in the final 

decision shall Identify the same due date as the original demand for payment. 

(v) Amounts shall be due at the earliest of the follOwing dates: 

(A) The date fixed under this contract. 

(B) The date of the first written demand for payment, including any demand for payment resulting from a 

default termination. 

(vi) The interest charge shall be computed for the actual number of calendar days involved beginning on the 

due date and ending on-

(A) The date on which the designated office receives payment from the Contractor, 

(8) The date of issuance of a Govemment check to the Contractor from which an amount otherwise 

payable has been withheld as a credit against the contract debt; or 

(C) The date on which an amount withheld and applied to the contract debt would otherwise have beoome 

payable to the Contractor. 

(Vii) The interest charge made.urider this clause may be reduced under the prOcedures prescribed in 32.608· 

f of the Federal Acquisition Regulation in effect on the date of this contract. 

Ul Risk of lOSS. Unless the contract specffically pro~des otherwise, nsk of loss or damage 10 the supplies 

provided under this contract shall remain with the Contractor until, and shall pass to the Govemment upon: 

(1) Delivery of the supplies to a carrier, if transportation is f.o.b. ongin; or 

TPD-CFP-ll-C-jJ012 
293 


(2) Delivery of the supplies to the Govemment at the destination specified in the contract, if transportation is 

to.b. destination, 

(k) Taxes. The contract price includes all applica~e Federal, State, and local taxes and duties. 

(I) Termination for the Government's convenience. The Government reserves the right to terminate this contract, 

or any part hereof, for its scle convenience. In the event of such termination, the Contractor shall immediately stop all 

work hereunder and shall immediately cause any and all of its supplier; and subcontractor; to cease work. Subject to 

the terms of this contract, the Contractor shall be paid a percentage of the contract price reflecting the percentage of 

the work performed prior to the notice of tetminatidn, plus r~asonab[e charges the Contractor ,can demonstrate to the 

satisfaction of the Government using its standard record keeping system, have resuHed from the termination. The 

Contractor shall nol be required 10 comply with the cost acoounting standards or contract cost principles for this 

purpose. This paragraph does not give the Government any Hght to audit the Contractors records. The Contractor 

shall nol be paid for any work pe.rformed or costs incurred which reasonably could have been avoided. 

(m) Termination for cause. The Government may' terminate this contract, or any part hereof, for cause in the 

event of any default by the Contractor, or if the Contractor fails to comply with any contract terms and conditions, or 

fails to provide the Government, upon request, with adequate assurances of future pertormance. In the event of 

termination for cause, the Government shaH not be liable to the Contractor for any amOunt for supplies or ,seNices not 

accepted, and the Contractor shall be liable to the Govemment for any and all rights and remedies provided by law. ~ 

it is determined that the Government imprope~y terminated thi.s contract for default, such termination shall be deemed 

a termination for convenience. 

(n) rille. Unless specified elsewhere in this contract, title to items fumished under this contract shall pass to the 

Government upon acceptance, regardless of when or where the Government takes physical possession. 

(0) Warranty. The Contractor warrants and implies that the items delivered hereunder are merchantable and frt 

for use for the particular purpose described in this contract. 

(p) Umftation of liability. Except as othei'Mse provided by an express warranty, the Conlractor will not be liable 

to the Government for consequential damages resulting from any defect or deficiencie;g in accepted items. 

(q) Other compliances. The Contractor shall comply with all applicable Federal, State and local laws, executive 

orders, rules and regulations applicqble to its pertormance under this contract. 

(r) Compliance wfth laws unique to Government contracts. The Contractor agrees to comply with 31 U.S.C. 1352 

relating to limitations on the use of appropriated funds to influence certain Federal contracts; 18 U.S.C. 431 relating 10 

officials notto benefit; 40 U.S.C. 3701 , et seq. , Contract Work Hour; and Safety Standards Act; 41 U.S.C. 51-58, AntiKickback Act of 1986; 41 U.S.C. 265 and 10 U.S.C. 2409 relating to whisheblower protections, 49 U.S.C. 40118, Fly 

American; and 41 U.S.C. 423 relating to procurement integrity. 

(s) Order of precedence. Any inconsistencies in this solicitation or contract shall be resolved by giving 

precedence in the following order: 

(1) The schedule of supplies/services. 

(2) The ASSignments, Disputes, Payments, Invoice, Other Compliances, and Compliance with laws 

Unique to Govemment Contracts paragraphs of this ciause. 

(3) The clause at 52.212-5. 

(4) Addenda to this solicitation or contract, including any license agreements for computer software. 

(5) Solicitation provisions" this is a solicitation. 

(6) Other paragraphs of this clause. 

(7) The Standard Form 1449. 

(8) other documents, exhibits, and ;lttachments. 

(9) The specification. 

(t) Central Contractor Registration (CCR). 

(1) Unless exempted by an addendum to this contract, the Contractor is responsible during pertormance and 

through final payment of any contract for the accuracy and completeness of the data within the CCR database, and for 

any liability resulting from the Govemmenfs reliance on inaccurate or incomplete data. To remain registered in the 

CCR database after the initial registration, the Contractor is required to review and update on an annual basis from 

the date of initial registration .or sub~equent updates ~s information in the CCR database to ensure it is current, 

accurate and complete. Updating information in the CCR does not alter the terms and conditions of this contract and 

is not a substiMe for a properly executed contractual document. 

(2)0) If a Contractor has legally changed its business name, "doing business as" name, or division name 

(whichever is Shown on the contract), or has transferred the assets used in pertorming the contract, but has not 

completed the necessary requirements regarding novation and change-at-name agreements in FAR Subpart 42.12, 

the Contractor shall provide the responsible Contracting Officer a minimum'of one business day's written notification 

of its intention to (A) change the name in the CCR database; (8) comply with the requirements of Subpart 42.12; and 

(C) agree in writing to the timeline and procedures specified by the responsible Contracting Officer. The Contractor 

musl provide with the notification sutficient documentation to support the legally changed name. 

Iii) If the Contractor fails 10 comply with the requirements of paragraph (t)(2)(i) of this clause, or fails to 

pertorm the agreement at paragraph (t)(2)(i)(C) of this clause, and, in the. absence of a property executed novation or 

TPD-CFP-ll-C<l012 
294 


10 

change-of·name agreement, the CCR infonnaiion that shows the Contractor to be other than the Contractor indicated 

in the contract ";11 be considerad to be incorrect infonnation within the meaning of the 'Suspension of Paymenr 

paragraph of the electronic funds transfer (EFI) clause of this contract. 

(3) The Contractor shall not change the name or address for EFT payments or manual payments, as 

appropnate, in the CCR record to reflect an assignee for the purpose of assignment afclaims (see Subpart 32.8, 

Assignment of Claims). Assignees shall be sepatately registered in the CCR database.lnfonnation pro~ded to the 

Contracto.!s CCR record that indicates payments, including those made by EFT, to an unimate recipient other than 

that Contractor will be cpnsidered to be incorrect information within the meaning of the 'Suspension of payment" 

paragraph of the EFT clause of this contract. 

(4) Offerors and Contractors may obtain information on registration and annual confirmation 

requirements ~a the intemet at hUp:/lWww.ccr.govorbycaliing 1-888-227"2423 or 269·96.1·5757. 

(End of Clause) 

52.212-4 CONTRACTTERMS AND CONDITIONS - COMMERCIAL ITEMS (JUN 2010) ALTERNATE I (OCT 2008) 

When atime-end·materials or labor·hour task orderis contemplated, the follo";ng paragraphs (a), (e), (i) and (I) shall 

take precedence over those in the basic dause. 

Aftemate I (Oct 200U). When a time-and·matenals or labor·hour contract is contemplated, substitute the following 

paragraphs (a), (e), (i) and (I) for those in the basic clause. 

(a) Inspection/Acceptance. (1) The Govemment has the nght to inspect and test all matenals fumished and 

services performed under this contract, to the extent practicable at all places and times, including the penod of 

performance, and in any event before acceptance. The. Government may also inspect the plant or plants of the 

Contractor or any subcontractor engaged in contract performance. The Government will perform inspections and tests 

in a manner that will not unduly delay the work. 

(2) If the Govemment perfonns inspection or tests on the premises of the Contractor or a subcontractor, the 

Conilactor shall fumish and shall require subcontractors to fumish all reasonable facilnies and assistance for the safe 

and convenient performance of these duties. 

(3) Unless otherwise specified in the contract, the Govemment will accept or reject seNices and materials at the 

place of delivery as promptly as practicable afier delivery, and they";l1 be presumed accepted 60 days afler the date 

of delivery, unless accepted eanier. 

(4) At any time dunng contract perfonn'nce, but not later than 6 months (or such other time as may be specified in 

the contract) after acceptance of the selVices or materials last delivered under this contract, the Government may 

require the Contractor to replace or correct services or matenals that at time of delivery failed to meet eontract 

requirements. Except as otherwise specified in paragraph (a)(6) of this clause, the cost of replacement or correction 

shall be determined under paragraph (i) of this clause, but the 'hourly rate' for labor hours incurred in the replacement 

or correction shall be raduced to exclude that portion of the rate attrbutable to profit. Unless otherwiSe speened 

below, the portion of the 'hourly rate' attnbutable to profit shall be 10 percent. The Contractor shall not tender for 

acceptance materials and services required to be replaced or corrected without disclosing the former requirement for 

replacement or correction, and, when required, shall disclose the corrective action taken.llnsert portion of labor rate 

aftributable to profft] 

(5)(i) If the Contractor fails to proceed ..;th reasonable promptness to perfonn required replacement or correction, 

and if the replacement or correction can be performed within the ceiling price (or the ceiling price as increased by the 

Govemment), the Govemment may-

(A) 8y contract or otherwise, perfonn the'replacement or correction, charge to the Contractor any increased 

cost, or deduct such increased costirom any amounts paid or due under this contract; or 

(8) Tenninate this contract for cause. 

(ii) Failure to agree to the amount of increased cost to be charged to the Contractor shall be a dispute under 

the Disputes clause of the contract. 

(6) Notwithstanding paragraphs (a)(4) and (5) above, the Govemment may at any time require the Contractor to 

remedy by correction or replacement, ";thout cost to the Govemment, any failure by the Contractor to comply wnh the 

requirements of this contract, if the failure is due to--

(i) Fraud, lack of good faith, or "; ~I misconduct on the part of the Contracto!s managenal personnel; or 

(ii) The conduct of one or more of the Contractor's employees selected or retained by the Contractor after 'any 

0.1 the Contractor's managerial personnel has reasonable grounds to believe that the employee is habHually careless 

or unqualified. 

(7) This clause applies in the same manner and to the same extent to corrected or replacement materials or 

selVices as to materials and selVices originally de.li ve~ under this contract· 

TPD-CFP-11·C-0012 
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11 

(8) The Contractor has no obligation or liability unqer this contract to correct ot replace materials and services that 

at time of delivery do not meet contract requirements, except as ·provided in this clause or as may be otherwise 

specffied in the contract. 

(9) Unless otherwise specified in the contract,the Contractols obligation to comect or replace Gbvemmentfurnished property shall be governed by the clause pertaining to Government property. 

(e) Definaions. (1) The clause at FAR 52.202-1, Definitions, is incorporated herein by reference. As used in this 

clause--

~) Direct matenals means those materials that enter directly into the end product, or that are used or 

consumed directiy in connection with the furnishing of the end product or seMce. 

(ii) Hourly rate means the raters) prescribed inthe contract for payment for labor that meets the labor 

category qualifications of a labor category specified in the contract that are-

(A) Pertorrned by the contra.ctor; 

(8) Pertorrned by the subcontractors; or 

(C) Transferred between divisions, subsidiaries, .or affiliates of the contractor under a common 

control. 

(iii) Materials means-

(A) Direct materials, induding supplies transferred between divisions, subsidiaries, or affiliates of the 

contractor under a COmmon control; 

(8) Subcontracts for supplies and in~dental services for which there is not a labor category specified 

in the contract; 

(0) Other direct costs (e.g. , incidental services for which there is not a labor category specified in the 

contract, travel, computer usage charges, etc.); 

(D) The following subcontracts for services which are specifically excluded from the houny rate: 

[Insert any subconiracts for services to be excluded from the hourly rates prescribed in the schedule.l; and 

(E) Indirect costs specifically pro~de<! for in this clause. 

(iv) Subcontractineans any contract, as defined in FAR Subpart 2.1, entered into with a subcontractor to 

furnish supplies or selvices for pertorrnance of the prime coniract or a subcontract induding transfers betw .. n 

divisions, subsidiaries, or affiliates of a contractor or subcontractor. It includes, but is not limited to, purchase orders, 

and changes and modifications to purchase orders. 

(i) Payments. (1) Services accepted. Payment shall be made for services accepted by the Government that 

have been delivered to the delivery destination(s) set forth in this contract. The Govemment win pay the Contractor as 

follows upon the submission of commercial invoices approved by the Contracting Officer: 

(i) Hourly rate. 

(A) The amounts shall be compUted by multiplying the appropriate houny rates prescribed in the 

contract by the number of direct labor hours pertorrned. Fractional parts of an hoUr shall be payable 

on a prorated basis. 

(8) The rates shall be paid for all labor pertorrned on the cont",ct that meets the labor qualifications 

specified in the contract. Labor hours incurred fo pertorrn tasks lor which labor qualifications were specified in 

the contract will not be paid to the extent the work is pertormed by individuals that do not meet the 

qualffications specffied in the contract, unless specifically authorized by the Contracting Officer. 

(C) Invoices may be submitted once each month (or at more frequent intervals, ~ approved by the 

Contracting Officer) to the Contracting Officer or the authorized representative. 

(D) When roqueste<! by the Contracting Officer or the authorized representative, the Contractor shall 

substantiate invoices (including any subcontractor hours reimbursed at the hourly rate in the sche<!ule) by 

e~dence of actual payment, individual daily job timecards, records that verify the employ .. s m .. t the 

qualifications for the labor categories specified in the contract, or other SUbstantiation specified in the 

contract. 

(E) Unless the Sche<!ule prescribes otherwise, the houny rates in the Schedule shall not be varied by 

virtue of the c.ontractor having performed work on an overtime basis. 

(1) If no overtime rates are pro~ded in the Sche<!ule and the Contracting Officer approves 

overtime work in advance, overtime rates: shan be negotiated. 

(2) Failure to agree upon these overtime rates shall be treated as a dispute under the 

DispUtes dause of this contract 

(3) If the Schedule pro~des rates for overtime, the premium portion 01 those rates will be 

reimbursable only to the exient the overtime is approve<! by the Contracting Officer. 

(ii) Materials. 

(A) If the Contractor furnishes materials that meet the ~efinition 01 a commercial item at FAR 

2.101, the price to be paid for such materials shall be the contl1lctols establiShed catalog or market 

price, adjusted to reflectthe-

(1) Quantities being acquired; and 

(2) Any modifications necessary because of contract requirements. 

TPD-CFP-11-C'{)012 
296 


12 

(8) Except as prOvided for in paragraph (Q(I)0i)(A) and (D)(2) of this clause, the 

Govemment will reimburse the Contractor the actual cost of materials (less any rebates, refunds, or 

discounts received by the contractor that are identifiable to the contnlct) pro~ded the Contractor-

(1) Has made payments for materials in accordance with the lertns and conditions of the agreement or invoice; or 

(2) Makes these payments ..;thin 30 days of the submission of the Contractors payment request to the 

Government and $uch payment is in accordance with the terms and conditions of tile agreement or invoice. 

(C) To the extent able; the Contractor shall--

(1) Obtain malenals at the most advantageous pnces available I>ith due regard to 

secunng prompt deliveiy of satisfactory matenals; and 

(2) Give credIT to the Govemment for cash and trade discounts, rebates, scrap, 

commissions, and other amounts U1at are identifiable to the contract. 

(D) Other Costs. Unless listed below, other direct and indirect costs";l1 not be reimbursed. 

(1) Other Direct Costs. The Govemment will reimburse the Contractor on the basis 

of actual cost for the follo";ng, provided such costs comply with the requirements in paragraph (i)(l)(ii)(8) of this 

clause: [Insert each element of other direct costs (e.g., travel, computer usage charges, etc. Insert -None" if no 

reimbwsemenf for other direct costs will be provided. If this is an indefinfte delivery contract, the Contracting Officer 

may insert 'Each order must list separatety the elements of o//Jer diract chargers) for that order or, if no 

reimbursement for other direct costs will be provided, insert 'None'.1 

(2) Indirect Costs (Maleria' Handling, Subconlract Administration, etc.). The 

GQvetnment will reimburse the Contract.or for indirect costs on a pro-rata basis over the period of contr;;lct 

performance at the following fixed price: [Insert a fixed amount for the Indirect costs and payment schedule. Insert $O~ 

if no fIXed price reimbursement for indirect costs will be provided. (ff this is an indefinite delivery contract, the 

Conlracting Officer may insert "Each oirier must lisl separalely the fixed amounl for the indirect cosls and paymenl 

schedule or, if no reimbursemenl for indirect costs, insert 'None).' 

(2) Total cost. It is estimated that the total cost to the Govemment for the pertormance of this contract shall 

not exceed the ceiling pnce set forth in the Schedule and the Contractor agrees to use ITS best efforts to pertorm the 

work specified in the Schedule and all obligations under this contract within such ceiling price. If at any time the 

Contractor h.as reason to believe that the hourly rate payments and matenal costs that";l1 accrue in pertorming this 

contract in the next succeeding 30 days, if added to all other payments and costs previously accrued, ";11 exceed 85 

pertent of the ceiling price in the Schedule, the Contractor shall notify the Contracting Officer giving a revised 

estimate of the tolal pnce to the Govemment for perfOrming this contract with supporting reasons and documentation. 

If at any time dunng the performance ot this contract, the Contractor has reason to believe that the total pnce to the 

Govemment for performing this contract";l1 be substantially greater or less than the then stated ceiling pnce, the 

Contractor shall so notify the Contracting Officer, giving a re~sed estimate of the total pnce for performing this 

contract, with supporting reasons and documentation. If at any time during performance Of this contract, the 

G.ovemment has reason to believe that the work to be required in performing this contract will be substantially greater 

or less than the slated ceiling price, the Contnlcting Officer ";11 so ad~se the Contractor, giving the then revised 

estimate of the total amount of effort to be required under the contract. 

(3) Ceiling price. The Govemment";l1 not be obligated to pay the Contractor any amount in excess of the 

ceiling price in the Schedule, and the Contractor shall nOt be obligated to continue PerfQrmance if to do so would 

exceed the ceiling pnce set forth in the Schedule, unless and until the Contracting Officer notifies the Contractor in 

writing that the ceiling price has been increased and specifies in the notice a revised ceiling that shall constitute the 

ceiling pnce for performance under this contract. When and to the extent that the ceiling pnce set forth in the Schedule 

has been increased, any hours expended and material costs incurred by the Contractor in excess of the ceiling price 

before the increase shall be allowable to the same extent as IT the hours expended and material costs had been 

incurred after the increase in the ceiling price. 

(4) Access 10 racords. At any time before final payment under this contract, the Contracting Officer (or 

auttlorized representative) Will have access to the following (access s.hall be limited to the listing below unless 

olherwise agreed to by the Contractor and the Contracting Officer): 

(i) Records that verily that the employees ..;hose time has been included in any invoice meet the 

qualffications for the labor categones specffed in the COntract; 

0i) For labor hours (including any subcontractor hours reimbursed at the hourly rate in the schedule), 

when timecards are required as substantiation for payment-

(A) The onginal timecards (paper-based or electronic); 

(8) The Contractors timekeeping procedures; 

(C) Contractor records that show the distributio.n of labor between jobs or contracts; and 

(D) Employees whose time has been included in any invoice for the purpose of venfying that 

these employ_ees have worked the hours shown on the invoices. 

(iiij For material and subcontract cQsts that are reimbursed on the b?lsis of actual cost-

(A) Any invoices or subcontract agreements substantiating matenal costs; and 

(8) Any documents supporting payment of those invoices. 

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(5) OverpaymentslUnderpayments. Each payment previously made shall be subject to reduction to the ex/ent 

of amounts, on preceding invoices, that are found by the Contracting Officer not to have been properly payable and 

shall also be subject to reduction for overpayments or to increase for underpayments. The Contractor shall promptly 

pay any such reduction within 30 days unless the parties agree otherwise. The Govemment within 30 days will pay 

afiy such increases, unless the parties agree otherwiSe. The Contractors payment will be made by check. If the 

Contractor becomes aware of a duplicate invoice payment or that the Government has otherwise overpaid on an 

invoice payment, the Contractor shall-

(i) Remit the overpayment amount to the payment office cited in the contract along with a description 

of the overpayment including the-

(A) Circumstances of the overpayment (e.g., duplicete payment, erroneous payment, liquidation errors, date(s) of 

overpayment); 

(8) Affected contract number and delivery order number, if appliceble; 

(C) Affected contract line item or subline nem, if applicable; and 

(0) Contractor point of conlact. 

Oi) Provide a copy of the remittance and supporting documentation to the Contracting Offcer. 

(6)(i) All amounts that become payable by the Contflict,or to the Government under this contract shall bear 

simple interest from the date due until paid unless paid within 30 days of becoming due. The interest rale shall be the 

interest rate established by the Secretary of the Treasury, as provided in section 611 of the Contract Disputes Act of 

1978 (Public Law 95-563), which is. applicable to the penad in which the amount becomes due, and then at the rate 

applicable for each siX month penod as eslablished by the Secretary until the amount is paid. 

(ii) The Govemmenl may issue a demand for payment to the Contractor upon finding a debt is due under 

thecontract. 

Oii) Final Decisions. The Contracting Offcer";l1 issue a final decision as required by 33.211 if-

(A) The Contracting Offcer and the Contractor are unable to reach agreement on the existence .or amo.unt of a debt in 

a timely manner, 

(8) The Contra.ctor fails to liquidate a debt previously demanded by the Contracting Offcer ..;thin the timeline 

specifi.ed in the demand fOf payment unless the amounts were not repaid because the Contractor has requested an 

installment payment agreement; or 

(C) The Contractor requests a deferment of collection on a debt previously demanded by the Contracting Offcer (see 

FAR 32.607-2). 

(iv) If a demand for payment was previously ISSUed for the debt, the demand for payment included in the 

final decision shall identify the same due date as the original demand for payment. 

(v) Amounts shall be due at the earliest of the follo";ng dates: 

(A) The date fixed under this contract. 

(8) The date of the first wntten demand for payment, including any demand for payment resulting from a defautt 

tetmination. 

(vi) The interest charge shall be computed for the actual number of calendar days involved beginning on the 

due date and ending on-

(A) The date on which the deSignated office receives payment from the Conlractor, 

(8) The date of issuance of a Government check to the Contractor from which an amount otherwise payable has been 

withheld as a credit against the contract debt; or 

(C) The date on which an amount ..;thheld and applied to the contract debt would otherwise have become payable 10 

the Contractor. 

(vii) The ihterest Charge made under this clause may be reduced under the procedures prescribed in 

32.608-2 of the Federal AcqUisition RegulatiOll in effect on the date of this contract. 

(viii) Upon receipt and approval of the invoice designated by the Contractor as the 'completion invoice' and 

supporting documentation, and upon compliance by the Contractor..;th all terms of this contract, any outstanding 

baiances will be paid within 30 days unless the parties agree otherwise. The completion invoice, and supporting 

documentation, shall be submitted by the Contractor as promptly as practicable follo";ng completion of the wor!< 

under this contract, but in no event later than 1 year.(or such longer penod as the Contracting Officer may approve in 

wnting) from the date of completion. 

(7) Release orc/aims. The Contractor, and each a"ssignee under an assignment entered into under this 

contract and in effect at the time of final payment under this contract, shall execute and deliver, at the time of and as a 

condition precedent to final payment under this contracl, a release discharging the Government, its officers, agents, 

and employees of and from all liabilities, obligations; and claims ariSing out of or under this contract, subject only to 

the following exceptions. 

0) Specified claims in slated amounts, or in estimated amounts if the amounts are not susceptible to 

exact statement by the Contractor. 

(ii) Claims, together with reasonable incidental expenses, based upon the liabilities of the Contractor 

to third parties ansing out of pertorrning this contract, that are not known to the Contractor on the date of the 

execution of the release, and of which the Contractor gives notice in wnting to the Contracting Offcer not 

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more tIlan 6 years after the date of the release or the date of any notice to the Contractor that the 

Government is prepared to mak~ final payment, whichever is eanier. 

~ii) Claims for reimbursement of costs (other than expenses of the Contractor by reason of its 

indemnification of the Govemment against patent liability), including re_asonable inad.ental expenses, incurred 

by the Contractor under tile tenns of this contract relating to patents. 

(8) Prompt payment. The Government will make payment in accordarn:e witll tile Prompt Payment Act 

(31 U.S.C. 3903) and prompt payment regulations at 5 CFR part 1315. 

(9) Eleelronic Funds Transfer (EFT). Ifthe Government makes payment by EFT, see 52.212-5(b) for tile 

appropnate EFT clause. 

(10) Discount. In connection witll any discount offered for early payment, time shall be computed ~om tile 

date of the invoice: For the purpose of computing the discouht earned, payment shall be considered to have been 

made on the date that appears on the payment check or the specified payment date if an electronic funds transfer 

payment is made. 

(I) Termination forthe Government's convenience. The Government reserves the nght to tenninate tIlis contract, or 

any part hereof, fot its .50.1e convenience. In the event of such termination, the Contra~or shall immediately _stop all 

work hereunder and shall immediately cauSe any and all of its suppliers and subcontractors to cease work. Subject to 

the terms of this contract, the Contractor shall be paid an amount for direct labor hours (as defined in the Schedule of 

tile contract) determined by multiplying the number of direct labor hours expended before the effective date of 

tennination by the hourty rate(s) in the contract, less any hourly rate payments already made to the Contractor plus 

reasonable charges the Contractor can demonstrafe to the satisfaction of the Government using its standard record 

keeping system that have resulted from the termination. The Contractor shall not be required to comply with the cost 

aocounting standards or contract cost pnnoples for this purpose. This paragtaph does not give the Govemment any 

nght to audit the Contractors records. The Contractor shall not be paid for any work pertonned or costs incurred that 

reasonably could have been avoided. 

ADDENDUM TO 52.212-4, CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (JUN 2010) 

INVOICES 

Invoices shall be submitted electronically to the e-mail address shown in Block 18a, page 1 of award. Protected 

Microsoft Excel files are tile preferred format; however, Adobe Acrobat Portable Document Format (PDF) and 

Microsoft Word are also aoceptable 

PAYMENT INFORMATION: 

Receive a free email notice of your electronic payment. Register at WYM'jpp.gov. 

OVERPAYMENTS 

In accordance with 52.212-4 section (i) 5 Overpayments: Accounts Receivable Conversion of Check Payments to 

EFT: If tile Contractor sends the ~overnment a check to remedy duplicate contract financing or an overpayment by 

the government, it will be converted into an electronic funds transfer (EFT). This means ihe Governmeni will copy tile 

check and use tile account infonnation on it to electronically debit tile Contractors account for the amount of tile 

check. The debn from the Contrador's account will usually occur within 24 hours and will be shown on the regular 

account statement 

The Contractor will not receive the original check back. The Government will destroy the Contractor's o'riginal check, 

but will keep a copy of n. If the EFT cannot be processed for technical reasons, the Contractor authorizes the 

Govemment to process the copy in place of the original check. 

MARKING OF SHIPMENTS: 

Please ensure that tile contract number (Block 2) is clearly visible on all shipping/service documents, containers, and 

invoices. 

1052.201-70 CONTRACTING OFFICER'S TECHNICAL REPRESENTATIVE (COTH) APPOINTMENT AND 

ALITliORllY (APR 2004) (DEVIATION) (DTAR) 

a. The Contracting Officers Technical Representative(s) is listed on page 2 of award. 

b. Perfofrtlance of work under this contract must be subject to the technical direction of the COTR identified above, or 

a representative designated in writing. The tenn "technical direction" includes, without limitation, direction to the 

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contractor Ihal directs or redirects the labor effort, shifts the work between work areas or locations, fills in delails and 

olherwise selVes 10 ens.ure thai tasks outlined in the work slalemenl are aooomplished salisfactorily. 

c. Technical directon must be v.ill1in the scope of the spectfication(s)lwork stalement. The COTR does nol have 

authority to issue technical direction that: 

1. constitutes a change of assignmenl or additional work outside the specffication(s)/work slalemen\ 

2. constitutes a change as defined in the clause titled 'Changes'; 

3. in any manner causes an increase or decrease in the contract price, or the time required for contract 

perlormance; 

4. changes any of the lerms, conditions, or specification(s)lwork slalemeni of the conlract; 

5. interferes with the Contractor's right to perfonn under the terms and conditions of the contract; or 

6. directs, supelVises or otherwise controls Ihe actions of the contractors employees. 

d. Technical directon may be oral or in wriling. The COTR shall confirm oral direction in writing v.1thin fwe workdays, 

v.ill1 a copy 10 the contracting officer. . 

e. The contractor shall proceed promptly v.1th perlonnance resulling from the lechnical directon issued by Ihe COTR. 

ff, in the opinion of the contractor, any direction of the COTR, or hislher designee, falls v.ill1in Ihe limnalions in (c) 

above, the contractor shall immedialely notify the contracting officer no laler than the begiming of the next 

Govemmenl work day. 

f. Failure of the contractor and the contracting officer to agree that technical direction is within the scope of the 

coniraci shall be subject 10 the lerms of the clause titled 'Dispules.' 

52.213-2 Invoice, (April 1984) 

In accordance with the above clause the contractor shall invoice at the beginning of the service period for the entire 

period. 

52.216-18 ORDERING (OCT 1995) 

(a) Any supplies and services 10 be fumished under Ihis contract shall be ordered by issuance of delivery 

orders or task orders by the individuals or activities design~ed in the Schedule. Such orders may be issued from 

09/30111 Ihrough 09129116. 

(b) All delivery orders or lask orders are subject 10. the term, and conditions of this contract. In the evenl of 

conflict between a delivery order or task order and this contract, the contract shall control. 

(c) If mailed, a delivery order or task order is considered "issued" when the Government depos~s the order in 

lhe mail. Orders may be issued orally, by facsimile, or by electronic commeroe methods only ~ authorized in the 

Schedule. 

52.216-19 ORDER LIMITATIONS (OCT 1995)· 

(a) Minimum order. When the Government requires supplies or services covered by this contract in an 

amounl of less Ihan $24,000.00, the Govemmenl is nol obligaled 10 purchase, nor is Ihe Contractor obligaled 10 

fumish, those supplies or services under Ihe contract. 

(b) Maximum orde, The Contractor is nol obligaled 10 honor-

(1) Any order for a single nem in excess of $1,645,000.00; 

(2) Any order for a combination of nems in excess 018,379,000.00; Of 

(3) A series of orders from tha same ordenng office v.1Ihin 30 days thai logether call for quantilies exceeding 

the limitation in paragraph (b)(I) or (2) of thiS section. 

(c) If this is a requirements contract (i.e., includes the Requiremenls dause al subsecton 52.216-21 of the 

Federal Acquisition Regulation (FAR)), the Govemmenl is nol required 10 order a part of anyone requirement from Ihe 

Contractor if that requirement exceeds the maximum-ordj"lr limitqtions in paraglilph (b) of this section. 

(d) Notwfihslanding paragraphs (b) and (c) of this seclion, the Conlraclor shall honor any order exceeding the 

maximum order limnations in paragraph (b), unless Ihal order (or orders) is relumed 10 Ihe ordenng offioe within 10 

days after issuance, v.ill1 writien notice stating the Contractors inlenl nollo ship the nem (or nems) called for and the 

reasons. Upon recaJ~ng this notice, the Govemmenl may acquire the supplies or services firom another souroe. 

52.216-20 INDEFINITE QUANTTTY (OCT 1995) 

(a) This is an indefinile-quanlify contract fot the supplies or services specified, and effective for the penod 

slaled, in the Schedule. The quantities of supplies and services spec~ed in Ihe Schedule are estimates only and are 

nol purchased by this contracl. 

(b) DeliVery or perlormance shall be made only as authorized by orders issued in acoordance v.1th the 

Ordering dause. The Contractor shall fumish 10 the Govemmenl, when and ~ ordered, the supplies or selVices 

spec~ed in the Schedule up 10 and including tha quantify designaled in the Schedule as the 'maximum.' The 

Government shall order at least the quantity of supplies or services designated in the Schedule as the ·minimum.· 

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(c) Except for aoy lim,ations on quantities in the Order limitations clause or in the Schedule, there is no limit 

on the number of orders thq:i may be i.ssued. The Gov,emmenl may issue orders requiring delivery to ml,lltiple 

destinations or performance at multiple locations. 

(il) Any order issued during the effective period of this contract and not completed within that period shall be 

completed by the Contractor within the time specified in the order. The contract shall govern the Contractors and 

Govemment's rights and obligations with raspect to that order to the same eident as IT the order were completed 

during the contract's effective period; provided, that the Contractor shall not be required to make any deliveries under 

this contract after 9129/16. 

52.2t7-8 OPTION TO EXTEND SERVICE (NOV 1999) 

The Government may require continued performance of any services-within the limits and at the rates specified in the 

contract. These rates may be adjusted only as a result of revisionS to prevailing labOr rates provided by the Secretary 

of Labor, The option provision may be exercised more than once, but the total extension of pertormance hereunder 

shall not exceed 6 months. The Contracting Officer may exercise the option by written notice to the Contractor within 

30 days before the contract expiration date. 

52.217-9 OPTION TO EXTEND THE TERM OF THE CONTRACT (MAR 2000) 

(a) The Govemment may eidend the tenn of this contract by written notice to the Contractor within the final 

30 days of each contract period; provided, that the Government gives the Contractor a preliminary written notice of its 

intent to extend at least 30 days ~fore the contract expires. The preliminary notice does not commit the Gov~mment 

to an extension. 

(b) If the Govemment exercises this option, the eidended contract shall be considered to include this option 

clause. 

(c) The total duration of this contract, including the exercise of any options under this clause, shall not 

exceed 60 months. 

CONTRACT TERM 

The period of perfohTlance for this procurement is a Base Period of 12 months and four 12-month Option Periods. 

CONTRACT MINIMUM AND MAXIMUM 

(~) The minimum amourit the Government is obligated to order during the term of the contract is 

$154,000.00. 

(b) The maximum amount of the contract will be $8,379,000.00. 

PERFORMANCE EVALUATION 

This contract is subject to a pertonnance evaluation. Following the end of the rontract period, a completed 

GQvernment evaluatiQn shall be forwarded to the Cootractor. The Contractor may sublll' written comments, if any, 

within the time period specified in the evaluation transmittal. The Contractor's comments shall be considered in the 

issuance Qf the final evaluation document. Any disagreement between the parties regarding the evaluation shall be 

forwarded to the Bureau Chief Procurement Officer (BCPO). The final evaluation of the Contractors perfonilance is 

the decision of the BCPO. A copy of the final pertonnance evaluation report will be sent to the Contractor and to the 

Govemment'.s past performance database at www.ppirs.gov. 

PUBLIC-RELEASE OF CONTRACT VERSION REQUIREMENT 

Wrthin 10 business days of award, the contractor shall submit to the COTR a .pdf file of the fully executed contract or 

task order with all proposed necessary redactions, including redactions of any trade secrets or any commercial or 

financial information that it believes to be privileged or confidential business information, for the purpose of public 

disclosure at the sole discretion of the Government The contractor shall provide a detailed written statement 

specifying the basis for each of its proposed redactions, including the applicable exemption under the Freedom of 

InfOI111a1ion Act (FOIA), 5 U.S.C. § 552, and, in the case of FOIA Exemption 4,5 U.S.C. § 552(b)(4), shall 

demonstrate why the information is considered to be a trade secret or commercial or financial information that is 

pri~leged or confidential. Infonnation provided by the contractor in response to this requirement may nse~ be subject 

to disclosure under the F01A 

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The Government ",II carefully consider all of the contractor's proposed redactions and assadated grounds for 

nondisdosure prior to ma~ng a final detenninatiOll as to what infonnation in the fully executed contract may be 

prope~y \IOthheld. 

52.212-5 CONTRACT TERMS AND CONDITIONS REQUIRED TO IMPLEMENT STATUTES OR 

EXECUTIVE ORDERS -COMMERCIAL ITIEMS (AUG 2011) 

(a) The Contractor shall comply wtth the follo\\Ong Federal Acquisition Regulation (FAR) dauses. which are 

incorporated in this contract by re'ference, to implement provisions of law or Executive orders applicable to 

acquisitions of commercial items: 

(1) 52.222-50, Combating Trafficking in Persons (Feb 2009) (22 U.S.C. 7104lgH. 

_ Attemate I (Aug 2007) of 52.222-50 (22 U.S.C. 7104(gH. 

(2) 52.233-3 Protest Aft., Award (AUG 1996)(31 U.S.C. 3553). 

(3) 52.233-4, Applicable Law for Breach of Cootract Claim (DeT 2004) (Pub.l. 108-77, 108-78) 

(b) The Contractor shall comply \10th the FAR dauses in this paragraph (b) that the Contracting Officer has 

indicated as being incorporated in this contract by reference to implement pro~sions of law or Executive orders 

appUcab)e to aQquisitions of commercial items: 

_X_ (1) 52.203-5, RestJictions on Subcontractor Sales to the Govemment(Sept 2006), "'th Alternate I 

(Oct 1995) (41 U.S.C. 253g and 10 U.S.C. 2402). 

_ (2) 52.203-13 Contractor Code of Business Ethics and Conduct (Apr 2010) (Pub.l. 110-252, T~e VI. 

Chapter 1 (41 U.S.C. 251 note)). 

_ (3) 52.203-1.5 Whistleblower Protections under the American Recovery and Reinvestment Act of 2009 

(June 2010) (Section 1553 of Pub. L. 111-5). (Applies to contracts funded by the American Recovery and 

Reinvestment Act of 2009.) 

17 

_X_ (4) 52.204-10, RepOrting Executive Compensation and First-TIer Subcontract Awards (JuI2010) (Pub.l. 

109'282) (31 U.S.C. 6101 note). 

_ (5) 52.204-11 American Recovery and Reinvestment Act-Reporting ReqUirements (JuI2010) (Pub. L. 

111-5). 

_X_ (6) 52.209-6 Protecting the Govemmenfs Intere.st When Subcontracting \10th Contractors Debarred, 

Suspended. or Proposed for'Debannenl (Dec 2010) (31 U.S.C.- 6101 note). 

_ (7) 52.209-10, Prohibition on Contracting "'th Inverted Domestic Corporations (section 740 of DivisiOll C 

of Pub. l. 111 -1 17, section 743 of Division 0 of Pub. l. 111-8, and section 745 of Division 0 of Pub. l. 110-161). 

_ (8) 52.219-3, Notice ofTotal HUBZone Set-Aside or Sole-Source Award (Jan 2011) (15 U.S.C. 657a) .. 

_ (9) 52.219-4, Notice of Price Evaluation Preference for HUBZOIle Small Business Concerns (JAN 2011) (ff 

the offeror elects to waive the preference, tt shall so indicale in tts offer) (15 U.S.C. 657a). 

_ (10) [Reserved] 

_ (11)0) 52.219-6, Notice ofTotal Small Business Set-Aside (JuneZ003) (15 U.S.C. 644). 

_0i) Alternate I (Oct 1995) of 52.219-6. 

_ (iii) Alternate II (Mar 2004) of 52.219-6 _ 

_ (12)0) 52.219-7, Notice of Partial Small Bu~ness Set-Aside (June 2003) (15 U.S.C. 644), 

_ 0i)Altemate I (Oct 1995) of 52.219-7. 

_ (iii) .AJtemate II (Mar 2004) of 52.219-7. 

_X_ (13) 52.219-8, Utilization of Small Business Concerns (Jan 2011) (15 U.S.C. 6371dH2) and (3)). 

_X_ (14)(i) 52.219-9. Small Business Subcontracting Plan (Jan 2011) (15 U.S.C. 637IdH4)). 

_ 0i)AKemate I (Oct 2001) of 52.219-9. 

_ (iii) Alternate II (Oct 2001) of 52.219-9. 

_ (iv) AIIemaie III (JuI2010) of 52.219-9. 

_ (15) 52.219-14, Limttations OIl Subcontracting (Dec 1996) (15 U.S.C. 637(a)114)). 

_X_ (16) 52.219-16, Liquidated Damages-Subcon-lracting Plan (Jan 1999) (15 U.S.C. 637(d)14HFlOl). 

_ (17)(i) 52.219-23, Notice of Price Evaluation Adjustment for Small Disadvantaged Business Concerns 

(OCT 2008) (10 U.S.C. 2323) (if the offeror elects to waive the adjustment, tt shall so indicate in tts offer). 

_ (ii) Alternate I (June 2003) of 52.219-23, 

_X_ (18) 52.219-25, Small Disadvanlaged Business Participation Program-Disadvantaged Status and 

Reporting (Dec 2010) (pub. L. 103-355, section 7102, and 10 U.S.C. 2323). 

_X_(19) 52.219-26, Small Disadvanlaged Business Participation Program-Incentive Subcontracting 

(Oct 2000) (Pub. L 103-355, section 7102, and 10 U.S.C. 2323). 

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_ (20) 52.219-27, Notice oITotal Service-Disabled Veteran-OWned Small Business Set-Aside (May 2004) 

(15 U.S.C. 657 O. 

_X_ (21) .52.219-28, Post Award Small Business Progmm Rerepresentation (Apr 2009) (15 U.S.C. 

632Ial(21). 

18 

_ (22) 52.219-29 Notice cfTotal Set-Aside for Economically Disadvantaged Women-Owned Small Business 

(EDWOSB) Concerns (Apr 2011). 

_ (23) 52.219-30 Notice oITotal Set-Aside for Women-OWned Small Business (WOSS) Concerns Eligible 

Under the WOSB Progmm (Apr 2011). 

_X_ (24) 52.222-3, Convict Labor (June 2003) (E.O. 11755). 

_X_ (25) 52.222-19, Child Labor-Cooperation with Authorities and Remedies (JuI2010) (E.O. 13126). 

_X_ (26) 52.222-21 , Prohibition of Segregated Fadlities (Feb 1999). 

_X_ (27) 52.222-26, Equal Opportunity (Mar 2007) (E.O. 11246). 

_X_ (28) 52.222-35, Equal Opportunity for Velerans (Sep 2010)(38 U.S.C. 4212). 

_X_ (29) 52.222-36, Aflinnative Action for Workers with Disabilities (Oct 2010) (29 U.S.C. 793), 

_X_ (30) 52.222-37, EmploymenlReports on Veterans (SEP2010) (38 U.S.C. 4212). 

_X_ (31) 52.222-40, Notification of Employee Rights Under Ihe National Labor Relations Act (Dec 2010) 

(E.O. 13496). 

_ (32) 52.222-54, Employment Eligibility Verification (JAN 2009). (Executive Order 12989). (Not applicable to 

the acquisition of commercially available off-the-shelf items or certain other types of commercial items as prescribed in 

22.1803.) 

_ (33)(i) 52.223-9, Estimate of Percentage of Recovered Materi.al Content for EPA-Oesignated Items 

(May 2008) (42 U.S.C. 6962{cl{3I{AlIiil). (Not applicable to Ihe acquisition of commercially available off-the-shen 

items.) 

_ (ii) Altemale I (May 2008) of 52.223-9 (42 U.S.C. 6962{ill2l1CI). (Not applicable to the acquisnion of commerdal~ 

available off-the-shen items.) 

_ (34) 52.223-15, Energy Effidency in Energy-Consuming Products (DEC 2007) (42 U.S.C. 8259b). 

_ (35)(i) 52.223-16, IEEE 1680 Standard for the Environmenlal Assessment of Personal Computer 

Products (DEC 2007) (E.O. 13423). 

_ (ii) Memale I (DEC 2007) of 52.223-16. 

_X_ (36) 52.223-18 Encouraging Conlractor Policies to Ban Text Messaging While Dnving (AUG 2011) (E.O. 

13513). 

_ (37) 52.225-1 , Buy Amencan Act-Supplies (Feb 2009) (41 U.S.C. 10a-1Od). 

_ (38)(i) 52.225-3, Buy Amencan Act-Free Trade Agreements-Ismeli Trade Act (June 2009) 

(41 U.S.C. 10a-l0d 19 U.S.C. 3301 note, 19 U.S.C. 2112 note, 19 U.S.C .. 3B05 note, Pub. L. 108-77, 108-78, 108-

286,108-302,109-53, 109-169,109-283, and 110-138). 

_ (ii) Memate I (Jan 2004) of 52.225-3. 

_ (iii) Memate II (Jan 2004) of 52.225-3. 

_ (39) 52.225-5, Trade Agreements (AUG 2009) (19 U.S.C. 2501 ef seq., 19 U.S.C. 3301 note). 

_X_ (40) 52.225-13, Restrictions on Cert.ain Foreign Purchases (June 2008) (E.O.'s, proclamations, and 

statules adminiSlered by the Office of Foreign Assets Control of the Department of the Treasury). 

_ (41) 52.226-4, Notice of Disaster OJ Emergency Area Set-Aside (Nov 2007) (42 U.S.C. 5150). 

_ (42) 52.226-5, Restrictions on Subcontracting Outside Disaster or Emergency Area (Nov 2007) (42 U.S.C. 

_ (43) 52.232-29, Terms for FinanCing of Purchases of COmmeraalltems (Feb 2002) (41 U.S.C. 255(0, 

10 U.S.C. 2307(0). 

_(44) 52.232-30, Installment Payments for Commerdalltems (Oct 1995) (41 U.S.C. 255(0, 

10 U.S.C. 2307(0). 

_X_ (45) 52.232-33, Paymenl by Electronic Funds Transfer-Central Contraclor Registration (Oct 2003) 

(31 U.S.C. 3332). 

_ (46) 52.232-34, Payment by Electronic Funds Transfer-Other Ihan Central Contractor Registration 

(May 1999) (31 U.S.C. 3332). 

_ (47) 52.232·36, Payment by Third Party (Feb 2010)(31 U.S.C. 33321. 

_ (48) 52.239-1, Privacy or secunty Safeguards (Aug 1996) (5 U.S.C. 552al. 

_ (49)(Q 52.247-64, Preference for Pnvalely Owned U.S.-Flag Commercial Vessels (Feb 2006) 

(46 U.S.C. Apox. 1241{bl and 10 U.S.C. 2631). 

_ (ii) Allemate I (Apr 2003) 0152.247-64. 

(c) The Contractor shall comp~ with the FAR dauses in this pamgmph (c), applicable to commercial 

services, that the Contracting Officer has indicated as being incorporated in this contract by reference to implement 

provisions of law or Executive orders applicable to acqUisitions of commercial items: 

_ (1) 52.222-41, Service ConlractActof 1965, (Nov 2007) (41 U.S.C. 351 , ef s~q.). 

TPD-CFP·ll·C·0012 
303 


_ (2) 52.222-42, Statement of Equivalent Rates for Federal Hires (May 1989) (29 U.S.C. 206 and 

41 U.S.C. 351 , elseq.). 

_ (3) 52.222-43, Fair Labor Standards Act and Service Contract Act-Pnce Adjustment (Multiple Year and 

Option Contracts) (Sep 2009) (29 U.S.C. 206 and 41 U.S.C. 351 el seq.). 

_ (4) 52.222-44 Fair Labor Siandards Act and Service Contract Act-Pnce Adjustment (Sep 2009) 

(29 U.S.C. 206 and 41 U.S.C. 351 el seq,). 

_ (5) 52.222·51 Exemption from Application of the Service Contract Act to Contracts lor Maintenance, 

Calibration, or Repairaf Certain Equipment-Requiremenis (Nov 2007) (41 U.S.C. 351, el seq.). 

19 

_ (6) 52.222·53 Exemption from APplication of the Service Contract Act to Contracts for Certain ServicesRequirements (Feb 2009) (41 U.S.C. 351, el seq.). 

_ (7) 52.226-6 Promoting Excess Food Donation to Nonprofit Organizations (Mar 2009) (Pub. L. 110-247). 

_ (8) 52.237·11 , Accepting and Dispensing of 51 Coin (Sept 2008) (31 U.S.C. 5112(p)(1I). 

(d) Complroller General Examination of Record. The Contractor shall comply with the provisions of this 

paragraph (d) ~ th~ contract was awarded using other than sealed bid, is in excess of the simplffied acquisition 

threshold, and does not contain the clause at 52.215-2, Audn and Records-Negotiation. 

(1) The Comptroller General of the United States, or an authonzed representative of the Comptroller General, 

shall have access to and righl to examine any of the Contractor's directl)i pertineht records invoMng transactions 

relaled to this contract. 

(2) The Contractor .shall mak.e available at its offices at all reasonable times the records, materials, and other 

evidence for examination, audn, or reproduction, until 3 years after final payment under this contract or for any shorter 

period specffied in FAR Subpart 4.7, Contractor Records Retention, of the other clauses of this contract. If this 

contract is complete~ or partially terminated, the records relating to the wor!< terminated shall be made available for 

3 years after any resulting fihallermination settlement. Records relaling to appeals under the disputes clause or to 

litigation or the settlement of claims ansing under or relating to this contract shall be made available until such 

appeals, litigation, or daims are finally resolved. 

(3) As used in this clause, records include books, documents, accounting procedures and practices, and 

other data, regardless of type and regardless of fann. This does not require the Contractor to create or maintain any 

record thai the Contractor does not maintain in the ordinary course of business or pursuant to a provision of law. 

(e)(1) Notwithstanding the requirements of the dauses i~ paragraphs (a), (b), (c), and (d) 9f this clause, the 

Contractor is not required to flow down any FAR clause, other than those in paragraphs (e)(1)(i) through (xi) of this 

paragraph in a subcontract for oommerdal items. Unless otherwise indicated below, the extent of the flow down shall 

be as required by the clause-

(0)52.203-13 Contractor Code of Bu~ness Ethics and Conduct (APr 2010) (Pub. L. 110·252, Trtle VI, 

Chapter 1 (41 U.S.C.251 note)). 

Oij 52.219-8 Utilization of Small Business Concerns (Dec 2010) (15 U.S.C. 637(dll2) and (3)), in all 

subcontracts that offer further subcontracting opportunities. If the subcontract (except subcontracts to small business 

ooncems) exceeds $650,000 ($1.5 million for construction of any public fadlity), the subcontractor must include 

52.219-8 in lower tier subcontracts that offer subcontracting opportunities. 

(iiij(Reserved) 

(iv) 52.222·26 Eqyal Opportunity (Mar 2007) (E.O. 11246). 

(v) 52.222·35, Equal Opportunny for Veterans (Sep 2010) (38 U.S.C. 4212). 

(vi) 52.222·36, Affirma~ve Action forWor!<ers with Disabilities (Oct 2010) (29 U.S.C. 793). 

(vii) 52.222-40, Notification of Employee Rights Under th~ National La~or Rel.ations Act (Dec 2010) (E.O. 

13496). Flow down required in accordance with paragraph (Q of FAR clause 52.222-40. 

(viii) 52.222-41 Service Contract Act of 1965 (Nov 2007) (41 U.S.C. 351 el seq.). 

(ix) 52.222·50, Combating Trafficl<ing in Persons (Feb 2009) (22 U.S.C. 7104(9)). 

_Alternate I (Aug 2007) of 52.222·50 (22 U.S.C. 7104(g)). 

(x) 52.222·51 Exemption from Application of the Service Contract Act to Contracis for Maintenance, 

Calibration, or Repair of Certain Equipment·Requirements (Nov 2007) (41 U.S.C.351 el seq.). 

(xi) 52.222·53 Exemption from Application of the Service Contract Act to Contracts for Certain ServicesRequirements (Feb 2009) (41 U.S.C. 351 el seq.). 

(xii) 52.222·54, Employment E1igibilny Vertfication (JAN 2009). 

(xiiij 52.226-6 Promoting Excess Food Donation to Nonprofit Organ~ations (Mar 2009) (pub. L 11()-247). 

Flow down required in accord.ance with paragraph (e) of FAR clause 52.226-6. 

(xiv) 52.247-64 Preference for Pnvately Owned U.S.·Flag Commerdal Vessels (Feb 2006) (46 U.S.C. 

APpx. 1241(b) and 10 U.S.C. 2631). Flow down required in accordance with paragraph (d) of FAR 

clause 52.247-64. 

TPD-CFp·11·C-{)012 
304 


20 

(2)While not required, the contractor may include in its subcontracts for commercial items a minimal number 

of additional dauses necessary to satisfy's contractual obligations. 

Alternate / (Feb 2000). As preSClibed in 12.301(b)(4W), delete paragraph (d) from the basic dause, redesignate 

paragraph (e) 'as paragraph (d), and re~se the reference to 'paragraphs (a), (b), (c), or (d) of this clause' in the 

redeSignated paragraph (d) to read 'paragraphs (a), (b), and (c) of this clause'. 

Alternate 1/ (Dec 2010). As prescribed in 12.301(b)(4)(ii), substitute the follo';ng paragraphs (d)(I) and (e)(l) for 

paragraphs (d)(l) and (e)(l) of the basic clause as follows: 

(d)(l) The Comp~oller General of the United States, an appropriate Inspector General appOinted under section 3 or 

8G of the Inspector General Act of 1978 (5 U.S.C. App.), or an authorized reprasentative of e,her of the foragoing 

qffiGials shall have access to anc! right to-

(i) Examine any of the Contractor's or any subcontractors' records that pertain to, arid involve transactions relating to, 

this con~ct; and 

(ii) Interview any officer or employee regarding such transactions. 

(e) 

(1) Notwithstanding the requirements ot the clauses in paragraphs (a), (b), and (c), of this clause, the Contractor is not 

required to floW down ahy FAR clause in a subcontract for commercial items, other than-

(i) Paragraph (d) of this clause. This paragraph flows down to all subcontracts, except the authority of the Inspector 

General under paragraph (d)(I)~i) does not flow down; and 

(ii) Those clauses listed in this paragraph (e)(I). Unless otherwise indicated below, the extent of the flow down shall 

be as required by the dause-

(A) 52.203-13, Contractor Code of Business Ethics and Conduct (Apr 2010) (Pub. L. 110-252, Hie 

VI, Chapter 1 (41 U.S.C. 251 note)). 

(B) 52.203-15 Whistieblower Protettions Under the American Recovery and ReinVestment Act of 

2009 (June 2010) (Section 1553 of Pub. L. 111-5). 

(C) 52.219-8, Util~ation of Small Business Concems (Dec 2010) (15 U.S.C. 6371d)(2) and (3»), in all 

subcontracts that off.er further subcon~cQng opportunities. If the subcon~ct (except subcontracts to small 

business concems) exceeds $650,000 ($1.5 million for construction of any public facility), the subcon~ctor 

must include 52.219-8 in lower tier subcontracts that offer subcontracting opportunHies. 

(D) 52.222-26 Equal Opportunity (Mar 2007) (E.O. 11246). 

(E) 52.222-35, Equal Opportun" for Veterans (Sep 201 0) (38 U.S.C. 4212). 

(F) 52.222-36, Affirmative Action forWor1<ers.;th Disabilities (Oct 2010) (29 U.S.C. 793). 

(G) 52.222-40, Notification of Employee Rights Under the National Labor Relations Act (Dec 201 0) 

(E.O. 13496). Flow down required in accordance with paragraph (fj of FAR clause 52.222-40. 

(H) 52.222-41, Service Contract Act of 1965 (Nov 2007) (41 U.S.C. 351, et seq,). 

(I) 52.222-50, Combating Trafficking in Persons (Feb 2009) (22 U.S.C. 7104(g)). 

(J) 52.222-51 Exemption from Application of the Service Contract Act to Contracts for Maintenance, 

Calibration, or Repair of Certan Equipment-Requirements (Nov 2007) (41 U.S.C.351 et seq.). 

(I<) 52.222-53 Exemption from Application of the Service Contract Act to Contracts for Certain 

Service&-Requiremenls (Feb 2009) (41 U.S.C. 351, etseq.). 

(L) 52.222-54, Employment Eligibility Verification (Jan 2009). 

(M) 52.226-0, Promoting Excess Food Donation to Nonprorrt Organ~tioos. (Mar 2009) (Pub. L. 

110-247). Flow down required in accordance .;th paragraph (e) of FAR clause 52.226<5. 

(N) 52.247-64, Preference for Privately Owned U.S.-Flag COmmercial Vessels (Feb 2006) (46 U.S.C. 

Appx. 1241(b) and 10 U.S.C. 2631). Flow down required in accordance with paragraph (d) of FAR clause 

52.247-64. 

CONTRACT DOCUMENTS, EXHIBITS, AND AITACHMENTS 

Attachment A: Master Service Agr~ment 

TPD-CFP-11-C-0012 
305 


PERFORMANCE WORK STATEMENT IPWS) 

LOAN LEVEL MORTGAGE DATASET LICENSE SUBSCRIPTION 

SEPTEMBER 23, 2011 

1. OVERVIEW I BACKGROUND 

21 

On July 21, 2010, Presidem Obama signed lhe Dcxld-Frank Wall Street Refonn and Consumer Protection Act Ithe 

"Refonn Act"), which created the Consumer Finandal Protecton Bureau ICFPB). Trtle X of the Reform Act directs the 

US Department ofTreasury Ithe "Treasury Department') to provide interim administretive oversight and transition 

oversight a"nd to organize an orderly startup of the Bureau. The Govemment now seeks a Contractor to provide a 

subscription to loan level mortgage datasets. 

2. OBJECTIVE 

The CFPB requires a Contractor with extensive experience to provide Residential Mortgage Loan-Level Data, which 

indudes origination and pertonnante data fields over time. CFPB is looking for the grealest market coverage 

possible, both the greatest current lactive loan) coverage and the greatest historical coverage available. The data 

must support the highest level of qu~ity, e~denced by use of the data for research purposes, including use in peerreviewed publications. The data must be refreshed with as great a frequency as practicable and the Contractor must 

provide if requested, substantial analytical support-ooth on the data itse~ and Ipotentially) for slandard or customized 

reports. 

3. SCOPE 

CF?B seeks to retain access to Loan~evel mortgage datasets to allow the Research, Markets, and Regulations 

Division to conducl research to build the e~dentiary record needed for numerous upcoming Congressionally 

mandated mortgage rulemakings and reports, and to monitor the mortgage market effectively for emerging trends. 

4. REQUIREMENTS 

Datasets must meet the following five criteria: 

11) Minimum Criteria: Residential Mortgage Loan-Level Data, which inCludes ongination and 

pertonn.-nce data fields, over time 

(2) Market Data Coverage: We are looking for the greatest market coverage possible, 

particularly as it complemenls the LPSlMcDash data. 

(3) Historical Data Coverage: We are looking for both the greatest current (active loan) 

coverage and the greatest historical coverage available, ideally in one consistent dataset. 

(4) Data Quality: The data must support the highest level of quality, e~denced by (among other 

things) use of the data for research purposes, induding use in peer-reviewed publications. 

(5) Data limelineness: The data must be refreshed with .as great a frequency as. practicable. 

(6) Analytical Support: We are looking for a venddr who can provide, upon request, substantial 

analytical support-both on the data itse~ and for siandard or customized reports. 

Contrectors license subscription must faalrtate CFPB staff in th,jr efforts to'fuffillthe scope of this contrect by 

providing loan-level mortgage datasets to all the following: 

Monitor mortgage trends 

Evaluate policy options 

Conduct long-tenn quantnative rese~rch on the impact on detault probability from a wide variety of loan 

origination data fields 

Amass empirical records for numerous upcoming rulemakings and reports to Congress and the public 

CFPB requires "NO" use restrictions. CFPB seeks the contrector to pro~de the following rights: 

1. Use 

a. Full rights to publish' research, analyses, reports, and other work based on these data-sets 

b. No advance notice or advance review of, or permission for publication of CFPB's research results 

.hould be nece~ary 

c. Right to reference use of the dataset in publications and other public communications using the data 

TPD-CFP-1 1-C-0012 
306 


d. Right to publish research, analysis, reports, and other work should survive any license (i.e., CFPB 

shall still be able to publish work even IT CFPB license to the data has expired) 

22 

e. Right to merge the data with all otller datasets without affecting any of our usage or publication nghts 

2. Support 

a. Include contractual language to codify the support levels datasets will provide with respeel to the 

data O.e., SIA, point-of-contaci, time fQ< response, etc.) 

b. Contractual language which confirms that, when any new fields are added to the datase\ our data 

dictionary is updated and we have a clear explanation of any changes/updates made 

c. Optional requirement: access to a web'based portal to access the data sets 

3. Enhanced Options 

a. Ability to include custom fi~ds in the dataset. 

4. Delivery 

a. Datasets will be made available in standard formats (e.g. CSV, talHlelimned tex\ XML) thet are 

natively compatible for loading into SAS SelVer, PostgreSQl, and MS SQL SelVer environments. 

b. Datasets will be made available to CFPB via common file transfer protocols (e.g., SFTP). 

c. If authentication is required for acces.ng the product, CFPB will be provided required credentials. 

5. REFRESH 

If the Contractor, in its product lineJ upgrades or substitutes a new item with enhal'lced performance features for an 

item that is available under this Contract1 such item or system may be included in this Contract in place of or in 

addition to the existing nem or system, provided that an improved ratio of performance versus pnce is attained. The 

Contractor shall notify the Contracting Offcer of any such changes in ,s product line that affect this Contract promptly 

upon commercial announcement or availability of the-change. Price fair and reasonableness will be determined prior 

to the issuance of a del~ery order for any new proposed 'erns. 

6. QUALITY ASSURANCE SURVEILlANCE PIAN (QASP) 

The Conlracting Officets Technical Representative (COTR) will summanze and document the Contractots 

performance in the categories listed below (evaluation based on meeting the requirements of this PWS): 

Quality of SelVice 

Cost Cootrol 

TImeliness of Performance 

Business Relations 

SUlVeiliance method. Random Evaluation. This metllod employs a 'spot check' style of evaluation and may be 

adjusted, based on qualtty trends. The Government retains the nght to inspect all requirements of the contract. 

Unacceptable performance will be recorded and the Contractor shall be required to correct the unacceptable condition 

wtthin a 24-hour time penod. If the Contractor does not correct the unacceptable condition within 24-hours, the COTR 

will notify the Contracting Officer who will take appropnate administrative action for unacceptable performance. iMlen 

an observation indicates defective performance, the CaTR will require the Contractor to initial the observation. The 

initialing of the obseMtion does not constitute concurrence with the obselVation; n on~ indicates acknowledgement 

that the Contractor has been made aware of a potentially defective performance. 

7.0 TASK ORDER REQUIREMENTS 

Any TO issued dunng the effective penod of this contract and not completed w,hin that penod shall be 

completed by the Contractor within the time specified in the TO. The contract shall govern the Contractors 

and Goveminenfs nghts and obligations with respeel to that TO to the same exient as IT the TO were 

completed dunng the contracfs effective penod; provided, that the Contractor .shall not be required to make 

any deliveries under this contract after 5 years from expiration of the contract. 

TASK ORDER REQUESTS 

a. Task Order Requests. The Government shall issue each TO Request electronically to the Contractor 

for review and preparation of a proposal. Each TO Request shall specify the technical req~irements , the 

desired deliverable produC\ performance standards, documentation standards, QASP,acceptance erRena, 

dient agency benchmarks, and performance schedule, in suffioent detail to permn an accurate pnce, work 

hours, other resources and completion date by the Contractor. It is the Contractots respons ~ltty to propose 

TPD-CFP-11-C-0012 
307 


approprtate labor categortes, within the scope of the contract, and level-of-effort necessary to pertorm the 

services or provide the d.eliverables described in each TO Request. 

b. The following types ofTask Orders may be issued: 

23 

Fixed-Price: This is a task for which there are reasonably definite reqUirements, and for which there is one or 

more tangible deliverables. 

Labor-Hours: This is a task thai addresses a requirement where ther,e are no ODCs and it is not possible to 

define the work specffically e.hough to permIT the development of a firm fixed-prtce estimate. No matertals are 

necessary in the pertormance of the work. Labor-hour TOs shall be issued with a not-to-exceed ceiling prtce. 

7. PERIOD OF PERFORMANCE 

The pertod of pertorm,nce for this contract will be for a 12 month base pertod and four 12 month option pertods. 

8. PLACE OF PERFORMANCE 

The contractor shall perform services at the following locations: 

Con,s!Jmer Financial Protection Bureau 

Fifth Floor 

1801lSt.NW 

Washington, DC 20036 

TPD-CFP-11-C-0012 
308 


ADDENDUM TO 52.212-4, CONTRACTTERMS AND CONDITIONS - COMMERCIAL ITEMS (JUN 2010) 

INVOICES 

Invoices shall be submitted electronically to the &-mail address sh""" in Block 18a, page 1. Protected 

Microsoft Excel files are the preferred fonmat; however, Adobe Acrobat Portable Document Fonmat (PDF) and 

Microsoft Word are also acceptable. For payment and invoice questions contact Actounting Services Division 

at (304) 481J.l!300. 

PAYMENT INFORMATION: 

Receive a free email nouce of your electronic payment Register at 1.WNI.ipp.gov. 

OVERPAYMENTS 

In accordance \\1th 52.212-4 section (i) 5 OVerpayments: Accounts Receivable Conversion of Check Payments 

to EFT: If the Contractor sends tile Government a check to remedy duplicate contract finandng or an 

overpayment by the govemmenl, it \\111 be converted into an electronic funds transfer (EFT). This means the 

Government will copy the check and use the account information on ~ to electronically debit the Cootractor's 

account for the amount of the cheel<. The debtt from the Contractors account \\111 usually occur \\1thin 24 hours 

and \\111 be shown on the regular account statement. 

The Contractor \\111 not receive the onginal check back. The Govemment \\111 destroy the Contractors anginal 

chack, but \\111 keep a copy of it. w the EFT cannot be processed for technical reasons, the Contractor 

authonzes the Govemment to process the copy in place of the anginal check. 

MARKING OF SHIPMENTS: 

Please ensure that the order number (Block 4) is clearly visible on all shipping/service documents, containers, 

and invoices. 
309 

Clarity Services Inc. 


• 

Sarita Fratarolli 

DEPARTMENT OF THE TREASURY 

BUREAU OF THE PUBLIC DEBT 

PARKERSBURG, lIN 26106-1328 

September 26, 2012 

Installment and Liquidity Lending Markets 

Research, Markets & Regulations 

1700G.StNW 

Washington DC 200052 

Dear /1.0\5. Fraltaroli: 

In accordance with the procurement policies and procedures contained in the Treasury Directives 

~"anual, you are hereby designated as Contracting Representative (COR) in connection with the techniCJ[ 

phases of contract number TPD-CFP-12-C-OO 11, awarded 10 Clarity Services, Inc for the PayDay 

Lending Datasets. 

The COR represents the requesting organization throughout the 3Ci1uisition cycle. In genera~ your 

responsibilities include coordinating all required program office actions, placing task orders and 

pro\~ding assistance during administration of the contract. The Contracting Officer (CO) and the 

contract administrator are your points of contact in the Procurement office. 

DESIGNA nON OF COR 

A~ COR, your name appears in the contract schedule. A copy of this letter will also be provided to the 

Contractor. This letter sets forth in detail the full extent of your authority and limitations. It does not 

change or supersede the established line of authority and/or responsibility of any organization. This 

appointment as COR applies to the abo"e-referenced contract only, and shall tenninate on completion of 

tlte contract. 

SCOPE OF SPECIFIC RESPONSIBILITIES 

Administration: 

Represent and coordinate with the requesting organization, program office(s) involved, and management, 

all tedlIlical activities relating to this contract; 

Identify and monitor key administrative actions and accomplishment dates; 

r.,·lonitor the Contractor's performance in meeting the technical requirements of the contract to assure that 

performance is strictly within the scope of the contract; 

Detennine the level of quality assurance evaluation required to insure that services are received in 

accordance with the contract; 

Write and execute a surveillance plan, as appropriate; 

Represent the Government in certain conferences with the contractor and prepare memoranda for the 

record of pertinent facts; 
310 


Confirm all significant technical instructions to the Contractor and provide a copy of the confirmation to 

the CO; 

Maintain a filing system and a contract working file containing a complete history of actions taken with 

regard to the contract; 

Refer to the CO those matters, other than purely technic.11 issue problems, which may significantly affect 

the contract; 

Furnish thc CO a copy of conference reports and C(lrrespondence; 

Coordinate with the CO on the content of any contractually significant correspondence addressed to the 

Contractor in order to ensure technical and historical accuracy and to prevent possible misunderstanding 

or the creation of a condition that may be made the basis of a later claim. All correspondence addressed 

to the Contractor will be signed by the CO; 

Report to the CO and Legal Counsel suspected procurement frauds, bribery, conflicts of interest, and 

other improper conduct; 

Assure that the Contractor has a current facility clearance as well as appropriate clearance for his 

personnel to have access to buildings, materials, equipment, etc.; 

When required, furnish the CO a formal request for termination; and, 

Inspection and ACCfptance; 

Inspect allllork for full compliance with contract requirements; 

Promptlyreject all work that does not comply with contract requirements and immediately notify the CO; 

Am~se the CO uthe Contractor fails \0 remove, correct, or replace rejected work promptly; 

Provide technical guidance (not direction) am~sing the Contractor of formal appeal rights when there is a 

disagreement; 

Prepare and maintain a running list of items that rema in at variance with contract requirements, apprising 

both the Contractor and the CO of corrective action or the need for it; 

Maintain a master copy of the official list of defects and omissions; and, 

Ensure that all defects and omissions are corrected or completed. 

Administer contract changes pw.'iously authorized by CO; and, 

Ensure that the Contractor provides formal proposals for contemplated changes. 

2 
311 


Financial na t' nt Issues: 

Review the Contractor's invoices to insure that they reflect accurately the work completed in accordance 

with the requirements of the contract and certify acceptance, 

Monitor financial management controls by reviewing overall expenditures against obligations to insure 

that sufficient, but not excess, funds are available for use under the contract; and, 

Advise the CO of any delay factOlS (strikes, weather, etc.) and record their impact; and, 

lnfonn the CO when a Contractor is known to be behind schedule, with the reasons therefore, and 

coordinate with the CO corrective action necessary to restore the contract schedule. 

Submissions: 

Dctennine (from the contract) and track the number and types of submittals required from the oontractor, 

~laintain a record of submittals on a current basis; 

Approve or reject submittals as provided in the contract documents; and, 

Furnish the CO a notice of satisfactory or unsatisfactory completion 

EXCLUSIONS FROM COR R&WONSIBILITIES 

Requirements of law, regulation, or Treasury procedure prohibit the delegation of or responsibility for 

certain actions related to contracts. For this reason, you are advised that you may not: 

Make commitrncnis or promises to Contractors relating to award of contracts; 

Write contract requirements around the product or capacity of one souret', 

Solicit proposals; 

Award, agree to, or execute a contract or contract modification; 

Issue instructions to Contractors to start or stop work; 

Obligate, in any W3Y, the p3)ment of money by the Government; 

Approve items of cost not specifically authorized by the contract; 

Direct changes; 

3 
312 


Execute supplemental agreements; 

l\1ake a final decision on any matter that would be subject to appeal under the Disputes clause of the 

contract; 

Cause the contractor to incur costs not specifically covered by the contract with the expectation that such 

costs will be reimbursed by the Goverrunent; 

Tenninate for any cause the Contractor's right to proceed; 

Authorize delivery or disposition ofGoverrunent-furnished property not specifically authorized by the 

contract; 

Give guidance to ContractOlS, either orally or in writing, which might be interpreted as a change in the 

scope or terms of the contract; 

Discuss procurement plans or any other advance infonnation that might provide preferential treatment to 

onc finn o\-er another when a solicitation is issued for a competiti\-e procurcmrnt; 

Approve Contractor's requests for public release of infonnation regarding work being performed under 

the contract; or, 

Redesignate any of your assigned duties unless specifically authorized by the CO to do so. 

RE-DESIGNATION OF RESPONSIBILITIES: 

The above designated responsibilities maynot be re-designated, except for clerical tasks associated with 

that authority, Changes in the designation of COR will be made through the Contracting Officer and 

letter appointment as the need arises. If it becomes necessary to make a change in the COR designation, 

lOU must notify the CO and provide the name of your replacement. You must provide any active files to 

the named replacement and send any inacti\"e files to BPD or to other designated storage area as directed 

by CO. 
313 


I am providing you with one copy of this letter of designation. Please sign in the space provided below to 

indicate rou ha\'e read and will comply with the responsibilities outlined in the letter, make a oopy of this 

letter for your files, and return the original (scanned or faxed copy of this page is acceptable) to Money 

Gardner al: Any questions regarding the responsibilities outlined in 

this letter should be referred to the contract administrator or the CO at 

contractadministration1j:bpd,tre3s.gov. 

Sincae1y, 

Jacob Oberlin 

Contracting Officer 

ACCEPTED: ~_~=~~_~~ ___ _ Contracting Officer's RepresmMive 

DATE: 

Contract Number: 1PJ).Cfp·12~.(}()17 

5 
314 


Yuh Wen LING 

DEPARTMENT OF THE TREASURY 

BUREAU OF THE PUBLIC DEBT 

PARKERSBURG, lIN 26106-1328 

September 26, 2012 

Installment and Liquidity Lending r..laikets 

Research, arkets & Regulations 

\700G,StNW 

Washington OC 200052 

Dear r..is. Ling: 

In acoord:mce with the procuranenl policies and procedures contained in the Treasury Directives 

Manual, you are hereby designated as Contracting Representative (COR) in connection with the technical 

phases of contract number TPD-CFP·12.c~ 11, awarded to Clarity Services, Inc for the PayDay 

Lending Da\asets. 

The COR represents the requesting organization throughout the acquisition cycle. In genera ~ your 

responsibilities include coordinating all required program office actions, placing task orden and 

pro\~ding assistance during administration of the contract The Contracting Officer (CO) and the 

contract administrator are your points of conUc\ in the Procurement office. 

DESIGNATION OF COR 

As COR, your name appears in the contract schedule. A copy of this letter will also be prol'ided to the 

Contractor. This lettt'f sets forth in detail the full extent of your authority and limitations. It does not 

change or supersede the established line of authority and/or responsibility of any organization. This 

appointment as COR applies to the above-feft'fenced contract only, and shall tenninate on completion of 

the contract. 

SCOPE OF SPECIFIC RESPONSIBILITIES 

Administration: 

Represent and coordinate with the requesting organization, program office(s) im·olved, and management, 

all technical activities relating to this contract; 

Identify and monitor key administrative actions and accomplishment dates; 

Monitor the Contractor's performance in meeting the technical requirements of the contract to assure that 

perfonnance is strictly within the scope of the contract; 

Detennine the 1e\·eJ of quality assurance e\'aluation required to insure that services are received in 

accordance with the contract; 

Write and executc a SIIf\'cillance plan, as appropriate; 
315 


Represent the Government in certain conferences with the contractor and prepare memoranda for the 

J'C\:ord of pertinent facts; 

Confinn all significant technical instructions to the Contractor and provide a copy of the confumation to 

the CO; 

~laintain a filing system and a contract working file CQIltaining a complete history of actions taken with 

regard to the contract; 

Refer to the CO those matters, other than purely techniCJI issue problems, which may significantly affect 

the CQIltract; 

Furnish the CO a copy of conference reports and correspondence; 

Coordinate with the CO on the content of any contractually significant correspondence addressed to the 

Contractor in order to ensure technical and historical accuracy and to prevent possible misunderstanding 

or the creation of a condition that may be made the basis of a later claim. All correspondence addressed 

to the Contractor will be signed by the CO, 

Report to the CO and Legal Counsel suspected procurement frauds, bribery, conflicts of interest, and 

other improper conduct; 

Assure that the Contractor has a current facility clearance as well as appropriate clearance for his 

personnel to ha\·e access to buildings, materials, equipment, etc.; 

When required, furnish the CO a fonnal request for tamination; and, 

Ins!K'ction and AcceplanCl': 

Inspect aU work for full compliance with contract requirements; 

Promptlyreject all work that does not comply with contract requirements and immediately notify the CO; 

Am~se the CO if the Contractor fails to remove, correct, or replace rejected work promptly; 

PfO\~de technical guidance (not direction) am~sing the Contractor offonna[ appeal rights when there is a 

disagreement; 

Prepare and maintain a running list of items that remain at variance with contract requirements, apprising 

both the Contractor and the CO of corrective action or the need for it; 

r-.laintain a master copy of the official list of defects and omissions; and, 

Ensure that all defects and omissions are corrected or completed. 
316 


Administer contract changes pM'iousiy authorized by CO; and. 

Ensure that the Contractor provides formal proposals for contemplated changes. 

Financial Mana ITment Issul'S: 

Review the Contractor's invoices to insure that they reflect accurately the work completed in accordance 

with the requirements of the contract and certify acceptance. 

r..lonitor financial matt.:lgement controls by reviewing Ol'erall expenditures against obligations to insure 

that sufficient, but not excess, funds are available for use under the contract; and, 

Am~se the CO of any delay factors (strikes, weather, etc.) and record their impact; and, 

Inform the CO when a Contractor is known to be behind schedule, with the reasons therefore, and 

coordinate with the CO corrective action necessary to re;tore the contract schedule. 

Submissions: 

Determine (from the contract) and track the number and types of submittals required from the contractor, 

Maintain a record of submittals on a current basis; 

Approve or reject submittals as provided in the contract documents; and, 

Furnish the CO a notice of satisfactory or unsatisfactory completion 

EXCLUSIONS FRO\I COR RESPONSIBILITIES 

RC1]uiremenls of law, regulation, or Treasury procedure prohibit the delegation of or re;ponsibility for 

certain actions related to contracts. For this reason, you are adl'ised that you may not: 

Make commitments or promises to Contractor> relating to award of contracts; 

Write contract requirements around the product or capacity of one source, 

Solicit proposals; 

Award, agree to, or execute a contract or contract modification; 

Issue instructions to Contractors to start or stop 1I'0rk; 

Obligate, in any way, the pa}mcnt of money by the Government; 

Approve items of cost not specifically authorized by the contract; 

3 
317 


Direct changes; 

Execute supplemental agreements; 

Make a final decision on any matter that would be subject to appeal under the Disputes clause of the 

contract; 

Cause the contractor to incur costs not specifically covered by the contract with the expectation that such 

costs lI'ill be reimbursed by the Govcnunent; 

Tenninate for any cause the Contractor's right to proceed: 

Authorize delivery or disposition ofGorcnunent-fumished property not specifically authorized by the 

contract; 

Gi\'e guidance to Contractors, either orally or in writing, which might be interpreted as a change in the 

scope or terms of the contract; 

Discuss procurement plans or any other advance infonnation that might pro\~de preferential treatment to 

one finn O\'er another when a solicitation is issued for a competiti\'e procurement; 

Approve Contractor's requests for public release of infonnation regarding work being performed under 

the contract; or, 

Redesignate any of your assigned duties unless specifically authorized by the CO to do so. 

RE,DKr.;IGNAT10N OF RESPON'SIB11,lTlES: 

The above designated responsibilities rna}' not be re--designated, t.xcept for clerical tasks associated with 

that authority, Changes in the designation of COR will be made through the Contracting Officer and 

letter appointment as the need arises. If it becomes necessary to make a change in the COR designation, 

you must notify the CO and provide the name of your replacement. You must provide any active files to 

the named replacement and send any inacti\'e files to BPD or to other designated storage area as directed 

by CO. 
318 


I am providing you with one copy of this letter of designation. Please sign in the space provided below to 

indicate rou ha\·e read and will comply with the responsibilities outlined in the letter, make a oopy of this 

letter for your files, and return the original (scanned or faxed copy of this page is acceptable) to Money 

Gardner al: . Any questions regarding the responsibilities outlined in 

this letter should be referred to the contract administrator or the CO at 

contractadministration1j:bpcl.tre3s.gov. 

Sincerely, 

Jacob Oberlin 

Contracting Officer 

ACCEPTED: ~_~=~~_~~ ___ _ Contracting Officer's RepresmMive 

DATE: 

Contract Number: 1PJ).Cfp·12~..(}()17 

5 
319 


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2 of 18 

" • -~ Y:HEru..Ea9.MJEs.sER\'ICES ~ " ~ " ~~ " .~ " Gov ' t COR : 

Sarita Frattaroli 

Tel : 202- 435- 1465 

E-J:lail : Sarita . Frattaroli@cfpb .gov 

A.ltemate Gov ' t COR : 

Yuh Wen LING 

Tel : 202- 435- 9451 

E-mail : YuhWen . Ling@cfpb. gov 

Accounting Info : 

CFP55 /7SFXXXX - 2012- 61 0001- CFP4050000- 2512- 0000000 

- XXX- XX - XXXXXXXXX- XXXXXXXXX - XXXXXXXXX 

Period of Perfonnance : 09/ 26/2012 to 02/25/2014 

0001 PayDay Lending Da t aSet.s in accordance with the 312 , 660 . 00 

PWS . 

Ana lysis and Reports - $308 , 488 . 00 

Travel - $4 , 180.00 

, PLEASE NOTE : If does not 

participatoo in thoo da t a .study, a cost of $100, 000 

will be eliminated from the Firm Fixed Price . 

Obligatood Amount : $312, 660.00 

Amount : $291,000.00 

Amount : $21 , 660.00 

Period of Perfonnance: 09/27/2012 to 02/26/2013 

Continued ••• 

31. QlWiTlH Il COlIMN 11 HASeEEN 

ACCEPTED, .... DCOOl'ORNS TO TtE CONTR.O.CT, EX.CEPT AS 

o RECEIVED o IISI'ECTfO o NOIED 

Qb SIGN~TURl' OF .'.IJIHORIlI:OGOVBlNMENT R~ESENT T"'E 13

1<""T< 31< PIlNTEO NAME .... O T~tE OF .o.ulHORilEO GOVERNMENT Rl'PIlESENT~TrvE 

.)2. IoIAl. IKi I\CtIPESS OF AAHORIliO GOVERN"'NT REPRESENTATIVE 311 TELEPHONE lIJo,ftR ~ .otITHORilED GOVERNr.t:NT Rl'PIlESENTATI'IE 

31') E.w.l Of .'.IJIHOR[ED GOVBlmlEm R~ESENTAT"'E 

!3 SHP ",-""eER VOUCIERN .... OCR ~ AAlOUNTVERfED ~ PAYloENi 31 CHECK MJr.Il€~ 

FRRtCTfOR 

OPAAllAl OFII.<I. 

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)8 SoIlACCOlI<TNlI"BER 138 SIlI':iUCHER NUhl EiER too PAOBY 

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ll. SIGNAJURI' .... omlEOFCERTIFYNG~fnR '10""TE 

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I< (),O.TH~Ctl (n'IIiIMJOOJ I'l<l TOTAl. CONTAJ..f:RS 
321 


_OFOFFEI!Of!OROlMTPAC~ 

ClARlTY SERVICES INC 

-~ IAI 

~ 

181 

0002 ~tion P~riod 1 - PayDay Lending Data5ets refresh 

in accordance with the PWS . 

Phase Note ; if C,PB choses t o participatIO in a 

econdary optional dau pull (6/12 month." '0' does not take part in that 

Mly.si~ , M additional $25,000 will be 

liminated from the Firm Fixed Price . 

Amount : $65 , 300 . 00(Option WM Item ) 

Pericxl of Performance: 02/27/2013 to 08/26/2013 

0003 ~tion Period 2 - PayDay Lending Data5ets R .. fresh 

in accordance with the rws. 

Pl"Me Note : if CFPB choses t o participat .. in a 

econdary optional data pull (6/12 months) '0' does not take part in that 

Mlysis, an additional $25,000 will be 

liminated from the Firm Fixed Price . 

Amount : $65 , 300.00(Opt ion !.ine Item) 

Period of Performance: 08/27/2013 to 02/26/2014 

Invoicing : upon compl~tion of ba.s~ period of 

perfomance and each cpt ion period of perfomance . 

ft~r award, any qu~.s ion.s or i.s.su~.s related to 

this procurement will be handled by the Contract 

Mministration Branch at 

ContractAdministration@bpd .treas. gov . When 

~nd.ing an mail to this address, please include 

th~ award nU!Dh~r in th~ .subj~ct lin~ of th~ 

-mail . 

• SI<1$<()4,· ,1281 

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322 


52.2124 CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (FEB 2012) 

(e) Inspection/Acceptance, The Contractor shall only lender for acceptance those ~ems that confo rm to the 

requirements of this contract The Government reserves Ihe right to inspect or test any supplies or services 

that have been tendered for acce~ance. The Government may require repair or replacement of 

nonconforming supplies or reperformance of nonronforming services al no increase in cootracl price If 

repair/replacement or reperformance 'Nil l not correct the defects or is not possible, th e Government may 

seek an equitable I=fice reducbon or adequate consideration for acceptance of oonconlorming supplies or 

services. The Government must exercise its post-acceptance rights-

(t) Within a reasonable time after the defect was discovered arshould have been discovered; and 

(2) Before an y substantial change occurs in the condition of the item, unless the change s due to the 

defect in the ~em 

(b) Assignment. The Contractor or its assignee may assign its rights to receive payment due as a resuK of 

performance of this contract to a bank, trust company, or other financing institution, including any Federal lending 

agency in ac{;Ordance with the Assignmentof Claims Act (31 USC. 3n7). However, when a third party makes 

payment (e.g., use of the Governmentwide commercial purchase card), the Contractor may not assign its rights to 

re<:eive payment under this contract. 

(c) Changes. Changes in the terms and cond~ions of this contract may be made only by IY!itlen agreement of 

the parties. 

(d) Disputes. This contract is subje<:t to the Contract Disputes Act of 1978, as amended (41 US.C 601--613) 

Failure of the parties to this contract to reach agreement on any request for e~itable adjustment claim, appeal or 

action arising underor relating to this contract shall be a dispute to be resolved in accordance with the clause at FAR 

52.233·1, Disputes, which is incorp:lIaled herein by reference. The Contractor shall proceed diligently.,.,;th 

performance of this contract, pending final resoluton of any dispute arising under the contract 

(e) Definitions, The clause at FAR 52,202·1 , Defin~io , s incorporated herein by reference. 

4 

(n Excusable delays. The Contractorshall be liable for defauH unless nonperformance is caused by an 

occurrence beyond the reasonable control of the Contractor and .,.,;thout its fauH or negligence such as, acts of God or 

the public enemy, acts of the Government in either its sovereign or contractual capacity, fires, floods, epidemics, 

qtJarantine restrictions, strikes, unusually severe weather, and delays of common carriers. The Contractor shall notify 

the Contracting Officer i1 writing as soon as ~ is reasonably possible after the commencement of any excusable 

delay, setting lorth the full particulars in connection tIlerewitll, shall remedy such occurrence with all rea sonable 

dispatch, and shall prornlily give written notice to tile Contracting Officer of tile cessation of such occurrence 

(g) Invoice. The Contractor shall submij an orginal invoice and three copies (or ele<:tronic invoice, if authorized,) 

to the address designated in tile contract to receive invoices An invoice must include--

(i) Name and address of the Contractor, 

(ii) Invoice date and number, 

(iii) Contract number, contract line ijem number and, if applicable, the order number, 

(iv) Desctiliion, ~antity, ~ of measure, un~ price and extended !=rice of the rtems delivered; 

(v) Shipping number and date of shipment, including the bill of lading number and weight of shipment if shipped 

on Govemment bill of lading; 

(vi) Terms of any discount for ftOm~ payment offered; 

(vii) Name and address of official to whom payment is to be sent 

(viii) Name,@e,andphonenumberofpersontobenotified ineventof defective invoice; and 

(ix) Taxpayer IdentifICation Number (TIN). TMe Contractor shall include its TIN only ~ required elsewhere in this 

contract 

(x) Ele<:tronic funds transfer (EFT) banking information 

(A) The Contractor shall include EFT banking info rmation only if required elsewhere in tIlis contract 

(8) If EFT banking information is not required to be on the invoice, in orderforthe invoice to be a proper 

invoice, the Contractor shall Mave submitted correct EFT banking information in accordance witll tMe applicable 

sol icitation ftOvision, contract ctallSe (e.g., 52.232-33, Payment by Ele<:tronic Funds Transfer---Central Contractor 

Registration, or 52, 232·34, Payment by Electronic Funds Transfer·-Other tMan Central Contractor Registra~on) , or 

applicable agency procedures 

(C) EFT banking information is not required if the Govemment waived \t1e requirement to pay by EFT. 

(2) Invoices will be tlandled in accordance with the Prompt Payment Act (31 U,S,C. 3903) and OffICe of 

Management and Budget (OMB) promli payment regulations at5 CFR 1315 

(h) Patent indemnity. The Contractorshall indemnify the Govemment and its officers, employees and agents 

against iabilrty, including costs, for actual or al leged dire<:t or cootributory infri ngement 01, or inoocement to infrilge, 

any United States or foreign patent, trademarJr: or copyrigh~ arising out of the performance of this contrac~ provided 

the Contractor is reasonably noUfied of such claims afld proceedings 

(i) Payment. (1) Items accepted. Payment shall be made for items accepted bot the Government ttlat have been 

delivered to the delivery destinations setlorth in tIlis contract 

TPIU:FP·12~-OO17 
323 


(2) Prompt payment The Government wi ll make payment in accordance wiIIllhe Prompt Payment Act (31 

U,S,C. 3903) and OffICe of Management and Budget (OMB) prompt pay regulations at 5 CFR 1315. 

(3) Ele<:/rolljc Fuoos Transfer (EFT). If the Government makes payment by EFT, see 52.212-5(b) for the 

appropriate EFT clause. 

5 

(4) Discount. In connection with any discount offered for early payment, time shall be computed from the date of 

the invoice. For the purpose of computing the discount earned, payment shall be considered to have been made on 

the date lIIhich appears on the payment check or the specified payment date ~ an electronic fu nds transfer payment is 

made 

(5) Overpayments. lIthe Contractor becomes aware 01 a duplicate contraclfinancing or invoice payment or that 

the Government has otherwise overpaid on a contract financing or invoice payment, the Contractor shall-

(i) Rem~ the overpayment am::lunt to the payment office cited in the contract along with a description of the 

overpayment including the---

(A) Circumstances of the overpayment (e,g., duplicate payment erroneous payment Iquidation errors, 

date(s) of overpayment); 

(8) Affected contract number and delrvery order number, ~ applicable; 

(C) Affected contract line rtem 01' subline ~em, ~ applicable; and 

(D) Contractor lXIint of contact 

(ii) Provide a copy oftne remittance and supporting documentation to the Contracting Officer 

(6) Interest. 

(i) All amounts that become payable by the ContractQrto the Government under this contract shall bear 

sirnple interestlrorn the date due until paid unless paid within 30 days of becoming due. The interest rate shall be the 

interest rate established by the Secretary of the Treasury as provided in Sectioo 611 01 the Contract Disputes Aclol 

1978 (Public law 9~563), l'Ihich is applicable to the period in ...mich the amount becomes due, as pfO\>ided in (i)(6)(v) 

of this clause, and then at the rate applicable for each six·month period as fixed by the Secretary until the amount is 

paid 

(ii) The Government may issue a demand for payment to the Contractor upon finding a debt is due under the 

contract 

(iii) FJnaldeci3ions. The Contracting Officerwill issue a final decision as required by 33.211 if-

(A) The Contracting Officer and tile Contractor are unable to reach agreement on the existence or amount 

01 a debilYithin 30 days; 

(8) The Contractorfails to li~i date a dett pre'o'iously demanded by tile Contracting Officerwithin the 

bmeline specified in the demand lor payment unless the amounts were not repaid because the Contractor has 

requested an installment payment agreement or 

(C) The Contractor requests a deferment 01 coDection on a debt previously demanded by the Contracting 

Officer (see R§QU). 

(iv) If a demand for payment was previously is sued for the dett, the demand for payment included in the final 

decision shall identify the same due date as the original demand 101' payment 

(v) Amounts shall be due at the earliest of the 10110lYing dates: 

(A) The date fixed under this contract 

(8) The date olthe first wrjten demand lor payment including any demand for payment resullinglrom a 

defauH termination 

(vi) The interest charge shall be comp.Jted for the actual number of calendar days involved beginning on tile 

due date and endin g on--

(A) The date on which the designated office receives paymentlrom the Contractor; 

(8) The date 01 issuance 01 a Government check to tile Cootractor from l'Ihich an amount otherwise 

payable has been withheld as a cre ~ against tile contract det:t; or 

(C) The date on l'Ihich an amount withheld and applied to the cootract debt would otheMise have become 

payable to the Contractor. 

(vii) The interest charge made under this clause may be reduced under the procedures prescribed in ~ 

.? of the Federal Acquisition Regulatioo in effect on the date of this contract 

Ul Risko! loss. Unless tile contract specificany provides otllerwise, risk 01 loss or damage to the suppties 

provided under this contract shall remain with the Contractor until. and shall pass to the Government upon: 

(1) Delivery of the supplies to a carrier, if transportation is f.o.b origin; or 

TPIU:FP·12~..oor7 
324 


(2) Delivery 01 the supplies to the Govemment at the destination specified in the contrac~ ~ transportation is 

I.o,b, destination. 

(k) Taxes, The contract price inctudes al appicabte Federat, State, and local taxes and dutes. 

(I) Termination fer" the Gov€l'nment's convenience. TMe Government reserves the right to terminate this contract, 

or any part hereol, for its sole convenience. tn the event 01 such termination, the Contractor shall immediatety stOjJ all 

wor\( hereunder and shalt immedialety cause any and alt of its suppliers and suocontractors to cease work, Su~ect to 

the terms of this contract, the Contractor shall be paid a pertentage 01 the contract pfice reflecting the percentage of 

the work performed prior to the notice 01 terminanon, plus reasonable charges the Contractor can demonstrate to the 

satisfaction of the Govemment using its standard record keepng system, have resuHed from the termination, The 

Contractor shalt not be required to comply with the cost accounting standards or contract cost principles for this 

purpose. This paragraph does not give the Government any right to aud~the Contracto~s records. The Cootractor 

shalt not be paid for any work performed or costs incurred which reasonably could have been avoided 

(m) T€I'minalion ffXcause. The Governmenl may terminate this contract, or any part hereof, for cause in tile 

event of any defauH by the Contractor, I)( if the Contractorlais to comply with any contract terms and conditions, or 

lails to provide the Government upon request with adequate assurances olfuture performance, In the event of 

termination lor cause, the Government shall not be liable to the Contractorlor any amount for supplies or services not 

accepted, and the Contractl)( shall be liable to the Government for any and alt rights and remedies provided by law, II 

~ is determined thatlhe Government improperty terminated this contract lor delauK, sucll termination shall be deemed 

a termination fo r convenience. 

(n) Title, Unless specified e5€"o1oflere in this contract title to items fumished under this contract shalt pass to the 

Government upon acceptance, regardless ofwhen or where the Government takes physical possession. 

(0) Warranty. The Contractorwarrants and implies that the items delrvered hereunder are merchantable and frt 

lor use forthe particular purpose described in this contract 

(p) Limitation of liability. Except as otherwise pro't'ided by an express warranty, the Contractorwilt not be liable 

to the Government fo r consequential damages resuHiflll lrom any defect or deficiencies in accepted items. 

(q) Other compliances, The Contractor shall colTJjllywith alt applicable Federal, State and local laws, executive 

orders, rules and regulations applicable to its performance under this contract 

(r) Comp/iance with laws unique 10 Govemmenlcon!racls. The Contractor agrees to comply with 3t U.SC, 1352 

relating to limitations on the use of appropriated funds to inftuence certain Federal contracts; 18 U.S.C 431 relating to 

officials not to benefit; 40 U.SC 370t et seq" Contract Work Hours and Salety Standards Act; 41 USC 5t-58 AntKickbackAct of 1986; 41 U.S.C 265 and 10 USC. 2409 relating to whistle blower protections; 49 U.S.C. 401 18 Fly 

American; and 41 U.SC. 423 relating to procurement integrity 

(s) CXderof precedence Any inconsistencies in this solicMon or contract sha. be resolved by giving 

precedence in the 101l0l'.1ng order 

(1) The schedule of suppliesfser.ices 

(2) The Assignments, Disputes, Payments, Invoice, Other Compliances, and Compliance with laws 

Unique to Govemment Contracts paragraphs of this clause 

(3) The cJause at 52,212-5 

(4) Addenda to this solicitation I)( contract including any license agreements fl)( computer software 

(5) Solicitation provisions if this is a solicitation. 

(6) Other paragrap'ls oIthis clause 

(7) The Standard Foon 1449 

(8) Other documents, exhibits, and attachments 

(9) The specrticalion 

(t) Central Contractor Registration (CCR) 

(1) Unless exempted b¥ an addendum to this contract, the Contractor is responsible during performance and 

through final payment 01 any contract lor the accuracy and colTJjlleteness of the data within the CCR database, and for 

any liability resutting from lIle Government's reliance on inaccurate or incomplete data. To remain registered in the 

CCR database after the n~ia l registration, Ihe Contractor is required to review and up:jate on an annual basis from 

the date of initial registration or su~equent updates its informanon in the CCR database to ensure ~ is current 

accurate and complete Updating information in the CCR does notalter the terms and conditions of this contract and 

is not a substitute lor a propeny executed contractual document. 

(2)(i) II a Contractor has legally changed its bllSiness name, "doing oosiness as" name, or division name 

(....t1 ichever is shown on the contract), or has transferred the assets used in performing lt1e contract, but has not 

completed the necessary requirements regarding novation and change-<ll-name agreements in FAR Subpart 42, 12, 

the Contractor shall provide the responsible Contracting Officer a minimum of one business day's written notincation 

of its intention to (A) change the name in the CCR database; (6) comply with the requirements 01 Subpart 42.12; and 

(C) agree in writing to the timeline and procedures specified by the responsible Contractiflll Officer. The Contractor 

must provide with the notification sufficient documentation to support lt1e legally changed name. 

(ii) Iflhe Contractorlails to comply with the requirements of paragraph (t)(2)(i) 01 this clause, orfails to 

perform the agreement at paragraph (tX2)@C)ofthisciause, and, in the absence 01 a properly executed novation or 

TPIU:FP·12~-OO17 
325 


change-<lf-name agreemen~ the CCR information that shows the Contractor to be otherthan the Contractor indicated 

in the contract will be considered to be iocooect infoonation within the meaning of the 'Suspension of Paymenr 

paragraph of the electronic fu nds transfer (EFT) clause of this contract. 

(3) The Contractor shall not change the name or address for EFT payments or manual payments, as 

appropriate, in the CCR record to reflect an assignee for the PUlJXlse of assignment of claims (see Subpart 32.8, 

Assignment of aaims). Assignees shall be sellirately registered in the CCR c!ataoose. Information provided to the 

Contractor's CCR record that indicates payments, including those macle by EFT, to an ultimate recipient other than 

that Contractor wi ll be considered 10 be incorrect information within the meaning of the 'Suspension of paymenr 

paragraph of the EFT dause of this contract 

(4) OHerors and Contractors may ottain information on registration and annual confirmation requirements via 

CCR accessed through hltps.lAflflV.atquisifioo.govor by calting 1-888·227·2423 or 26g·961·5757. 

ADDENDUM TO 52.212-4, CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (FEB 2012) 

ELECTRONIC INVOICING AND PAYMENT REQUIREMENTS 

Intemet Payment Platform OPP) is a secure web-based electronic invoicing and payment information service available 

to all Federal agencies and their suppl ier t1{ the U.S. Treasury's Financial Management Service. IPP allows Fecleral 

agencies and their suppliers to exchange electronic purchase orders, blanket POs, invoices, and payment information 

in one easy to access web portal. This service is free of charge to government agencies and their suppliers, 

indudin g services and support 

The preferred method for invoicing is through IPP. The IPP wet:6~e address is httos:lfwMy.ioo.gov. Contractor 

assistance with enrollment can be obtained by contacting the Bureau of the Public Debt's IPP Team at 304-480-8000, 

Option 7 or IPP Production Help desk via email ippgrouC@OOs.frb.oraorphone(866)973·3131. 

II the Contractor is unable to utilize IPP for submitting payment requests, invoices may be submitted electronically to 

the e·mail address shown in Block 18a, page 1 after completing the IPP Waiver Form and submitting H via e·mailto 

contractadministration@OOd.lreas.gov (see IPP Waiver Attachment). Adobe Acrobat Portable Document Format 

(PDF) and Microsoft Word are accelXable formats. Invoices shall contain th e information required in FAR 52.212· 

4(9). 

PAYMENT AND INVOICE QUESTIONS 

For payment and invoice questions, go to httt:§:lJw.wJ.ippgov or contact the Accounting Services Division at (304) 

480-8000 option 7 orvia email at AccountsPayable@bpd.lreas.gov 

OVERPAYMENTS 

In accordance with 52.212·4 section (i) 5 CNerpayments Accounts Receivable Conversion 01 Check Payments to 

EFT: If the Conlractorsends the Govemment a check to remedy dupl icate contractlinancing or an overpayment by 

the governmen~ ~will be converted into an electronic funds transfer (EFT). This means ttle GovemmentYliIi copy the 

check and use the account information on ~ to electronically debt the Cont racto~s accounl for the amount of the 

check. The deM from the Contracto(s account wil usually occur within 24 hours and will be shown on the regular 

account statement 

The Contractorwill not receive the original check oock. The Government shall destroy the Contractor's original check, 

but wi ll keep a copy of it. If the EFT cannot be processed lor technical reasons, Ihe Contractor authorizes the 

Government to process the copy in place of the original check 

MARKING OF SHIPMENTS: 

The Contractor shall ensure the order number (Block 4) isctearly visible on all shippiniiservice documents, 

containers, and invoices 

1052.210-70 CONTRACTOR PUBLICITY {AUG 2011) 

The Contractor, or any entity or representative acting on beha~ of the Contractor, stlall nol refer to the equipment or 

services fu rnished pursuantlo the provisions of this contract in any ne'IYS release or commercial advertising, or in 

connection with any ne'IYS release or commercial advertising. wiIIloot first obtaining explic~ written consent to do so from the Contracting OffICer. Should any reference to such equipment or services appear in any news release or 

commercial a<t.terlising issued by or on behalf of the Contractorwilllout the required consent tile Govemment shall 

TP~FP·12-C-0017 
326 


consider institution of all remedies availa~e under awlicable law, including 31 U.S.C 333, and lIlis contracl Further, 

any violation of lIlis p-ovision may be considered durir.g the evaluaton of past pelformance in future competitively 

negotiated acqutsitions. 

1052.201-70 CONTRACTING OFFICER'S REPRESENTATIVE (CORI APPOINTMENT AND AUTHORITY (JUN 

2012) 

(a) The CORs are: Sarita Frattaroli, 202435-7465, Sarita,Frattarolj@cfpb.goY 

Yu Wen Ling, 202435-9451, YuWen.Ling@cfpb.gov 

(b) Performance of ;wI\( under lIlis cootract is subject to lIle lechnical direction ofllle COR identifie<1 above, 

or a representatrw designated in writing. The lerm ·technical direclion" indJdes, withoul limitation. direction to lIle 

contractor that directs or redirecls the labor effort, shifts the;wl\( belWeen;w1\( areas or locations. andJorfills in 

details and otherwise serves to ensure lIlal tasks outlined in the ;wl\(statement are accomplisOOd satisfactorily 

33 

(c) Technical direction must be within the scope ofllle contractspecification(s)hYo1\( statement The COR 

does not have authority to issue technical directioo that 

(t) Constitutes a change of assignment or addijionat work outside the contract specification(s)'wol\( 

statement; 

(2) Constitutes a change as defined in the clause enttled "Char.ges·; 

(3) In any manner causes an increase or decrease in the contract price, orllle time reC?Jired for contract 

performance; 

(4) Changes any ofllle terms, coooitions, or specifkation(syYiorl< statement of the contract; 

(5) Interferes with lIle contractOi's right to perform under the terms and conditions 01 the contract; or (6) Directs, supervises or otOOrwise controls the actions ofllle contractOi's employees 

(d) Technical direclion may be oral or in writing. The COR must confirm oral direction in writing within five 

;wr1<days, with a copy to the Contracting Officer. 

(e) The Contractor shall procee<1 prompUywith performance resuHing from the technical direction issued by 

lIle COR. If, in the opinion of the contractor, any direction ofllle COR or the designated representative falls within the 

limitatons of (c) above, the contractor shall imme<1iately notify the Contracting Officer no later than the beginning of 

the next Government ;wI\( day 

(f) Failure of the Contractor and the Contractir.g Officer to agree that technical direction is within the scope of 

lIle contract shall be subject to the terms 01 the clause entitled ·Oisputes.· 

52.217~ OPTION TO EXTEND SERVICE (NOV 1999) 

The Government may reC?Jire continood performance of any services within the limits and at the rates specified in the 

contract These rates may be adjusted only as a resuH of revisions to prevailir.g laoor rates provided by the Secretary 

of Labor. The option provisioo may be exercised more than once, but lIle total extensioo of performance hereunder 

shall not exceed 6 months. The Contracting Officer may exercise the option by written notice to the Contractorwithin 

30 days before the contract eXpiration date. 

52.211--9 OPTION TO EXTEND THE TERM OF THE CONTRACT (MAR 2000) 

(a) The Government may extend the term of this contract by wriUen notice to the Contractorwilllin the final 

30 days of eacll contract period; provided, that the Government grves the Contractor a prelilllnary written notice of its 

intent to extend at least 30 days before the contract expires. The preliminary notice does not commit the Government 

to an extension. 

(b) lIthe Government exercises this option, too extended contract shall be coosidered to include this option 

clause 

(c) The total duration 01 this contract, including the exercise 01 any options under lilts clause, shall not 

exceed !I months. 

RIGHTS IN DATA - SPECIAL WORKS (DEC 2007) 

(a) Definitions. As used in this clause--

"Data' means recorded information, regardless ofform orthe medium on...mich ij may be recorded. The term includes 

technical data and computer software. The term does not include information incidental to cootract administration, 

such as financial, administrative, cost or pricing, or management information. 

TP~FP·12-C..()017 
327 


Un li m~ed rights" means the rights olthe Govemment to use, disclose, reproduce, prepare derivative works, distribute 

copies to the c, and perform publicly and display p.iblicly, in any manner and 10( any purpose, andto have or 

perm~ others to do so. 

(b) Allocation of Rights. 

(1) The Government shall have-

(i) Unlimited rights in all data delivered under this contract, and in al l data first produced in the 

performance of this contract. except as provided in paragraph (c) of this clause for copyright 

(ii) The right to limit assertion of copyright in data first produced in the performance of this contract 

arld to obtain assignment of copyright in that data, in accordance with paragrap'1 (c)(l) of this clause 

(ii i) The right to lim~ the release and lISe of certain data in accordance with paragral*1 (d) of this 

clause 

(2) The Contractor shall have, to the extent permission is granted in accordance with paragraph (c)(I) of this 

clause, the right to assert claim to copyright subsisting in data first produced in the performance of th~ 

contract. 

(c) Copyright-

(1) Data firs! produced in the perfoownoo of this contract. 

(i) The Contractor shall not assert or authorize others to assert any claim to copyright subsisting in 

any data first produced in the performance of this contract without prior'M'itten permission of the 

Contracting Officer. When copyright is asserted, the Contractorshal l affix the appropriate copyright 

notice of 17 U.S,C. 40t or 402 and acknowledgment of Government sponsorship (including contract 

number) to the data when delivered to the Govemment as well as when the data are published or 

depos~ed for registration as a published WOtX in the U,S, Copyright Office, The Contractor grants to 

the Government and others acting on its behal, a paid-up, nonexclusive, irrevocable, worlctMde 

license for all delivered data to reproduce, prepare derivative works, distribute copies to the pu~ic. 

aoo perform pu~ic y and display publicly, by or on behalf of the Govemment 

(ii) If the Govemment desires to obtain copyright in data first produced in the performance of this 

contract and permission has fiat been granted as set forth in paragrapl1 (c)(I)(i) of this clause, the 

Contracting Officer shall direct the Contractor to assign (with or without registration), or oliain the 

assignment of, the copyright to the Government or its desrgnated assignee 

(2) Data not tnt produced in the petformance of/his contract. The Contractor shall not, without piorwritten 

permission of the Contracting Officer, incorporate in data delivered under this contract any data not first 

produced in the performance of this contract and which contain the copyright nolice of 17 USC. 401 or 402, 

unless the Contractor identifies such data and grants to the Government or acquires on its behalf, a license 

olthe same scope as set forth in subparagraph (c)(l) of this clause 

(d) Release and use restrictions. Except as otherwise specifically provided for in this contract, the Contractor shall not 

use, release, reproduce, distribute, or publish any data first produced in the performance of this contract, nor authorize 

others to do so, without written permission of the Contracting Officer. 

(e) Indemnity. The Contractor shall indemnify the Govemment and ~s officers, agents, and employees acting forthe 

Government against any liability, including costs and expenses, incurred as the resuH of the violation of trade secrets, 

copyrights, or right of privacy or publicity, arising out of the creation, delivery, pu~ cation , or use of any data furnished 

urlder this contract; or any libelous or other unlal'lful matter contained in such data. The provisions of this paragraph 

do not apply unless the Govemmenl provides notice to the Contractor as soon as practicable of any claim 0( su~, 

affords the Contractor an opportunily under applicable laws, rules, or regulations to participate in the defense of the 

claim or sud, and obtains the Contractor's consent to the settlement of any claim orsu~ other than as required by final 

TPIU:FP·12~-OO17 
328 


decree of a court of competent jurisdiction; and these provisions clo not apply to material furnished 10 the Contractor 

by the Governmentand incorporated in data to wfl ich this clause applies. 

PERFORMANCE EVALUATION 

10 

This contract is subj-ect to a performance evaluation '<ia The Contractor Performance Reporti1 g System (CPARS) at 

lWtW.cparscsddisa.mil FolIOYr'ing the end of each contract period and at contract completion, a completed 

Government evaluation shall be fOlWarded to the Contractor. The Contractor may ubm~ written comments, if any, 

wi\I1in th e time period specified in the evaluation transmittal. The Contractors comments shal be considered " the 

issuance of the final evaluatKln document. My disagreement beM'een the parties regarding the evaluation shall be 

forwarded to the Bureau Chief Procurement Officer (SCPO). The final evaluation of the Contractor's performance is 

the decision of the SCPO. A copy of the fi nal performance evaluation rep:lrtwill be sent to the Contractor and to the 

Government's past performance database atWNW,ppirs.gov. 

PUBLIC-RELEASE CONTRACT VERSION REQUIREMENT 

The contractor agrees to sUOOlit within ten oosiness (10) days from the date the contract is awarded (exclusive of 

Saturdays, Sundays, and federal holidays), a text-based .p:ilfile of the fully executed contract ortask orderwith all 

proposed necessary redactions, iocluding redactions of any trade secrets or an y commercial or fi nancial information 

that ij believes to be prMleged or confidential busin ess information, forthe purpose of pu~ c disclosure atthe sole 

discretion of the Consumer Financial Protection Bureau (CFPB). The contractor agrees to provide a detailed written 

statement specifying the basis for each 01 its Jl(op:lsed redactions, including tM applicable exemj::tion under the 

Freedom of Information Act (FOlA), 5 U.S.C. § 552, arld, in the case of FOIA Exemption 4, 5 U,S,C. § 552(b)(4), shall 

demonstrate why the information ts considered to be a trade secret or commercial orfJlancial informaUon that ts 

privileged or confidential. Information provided by the contractor in resp:ll1se to this contract requirement may itself be 

subject to disclosure under the FOIA. The CFPB will carefulty consider all of tM contractor's proposed redactions arld 

associated grounds for nondisclosure prior to making a final determination as to what information in the fulty executed 

contract may be prope~y withheld. In the event that the CFPB disagrees with the contractor's suggested redactions, 

the CFPB wi ll provide the contractor with notice prior to p:lsting the contract 

TPIU:FP·12~-OO17 
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11 

52.21Hi CONTRACT TERMS AND CONDITIONS REQUIRED TO IMPLEMENT STATUTES OR 

EXECUTIVE ORDERS - COMMERCIAL ITEMS (MAY 2012) 

(a) The Contractor shall oorTllly with the folowing Federal Acquisition Regulation (FAR) clauses, lIotl ich are 

incorporated in this contract by reference, to implement provisions of lawor Executive orcSers applicable 10 

acqui ~ions of commercial ms 

(1) 52.222-50, Combating Trafficking in Persons (Feb 2009) (22 U.S,C. 7104(g)) 

_ Merrlilte I (Aug 2007) of 52.222·50 (22 USC 7104!gll 

(2) 52.233-3 Protest After Award (AuG 1996) 131 V,SC. 3553), 

(3) 52233-4 Applicable Lawlor Breach of Contract Claim (OCT 2(04) (Pub l. 108-77, 108-78) 

(b) The Contractor shall coll\'lly with \he FAR clauses in this paragraph (b) thai the Contracting Officer has 

indicated as being incorporated in \!1is rontract by reference to inplement provisions of lawol Executive orders 

applicable 10 acquisitions of commercial ~ems: 

]_ (1) ~ Restrictions on Subcontractor Sales to the Government (Sept 20(6), with Alternate I 

(Oct 1995) (41 U.SC 2530 and 10 US.C 2402) 

_ (2) ~ Contractor Code of Business Ethics and Conduct (Apr 2010)(Pub. L tl0-252, Title VI, 

Chapter 1 (41 US.C. 251 note)) 

_ (3) ~ Whisflel)ower Protections under the American RecollSf)' and Reinvestment Act of 2009 

(June 2010) (Sectioo 1553 of Pub. L. 111-5). (Applies to contracts funded by the American Recovery- and 

Reinvestment Act of 2009,) 

] _ (4) 52.204-10, Reporting Executive Compensation and First-Tier Suocontract Awards (FEB 20t2) (pub. 

L. 109-282) (31 U,S,C. 6101 note). 

_ (5) 2UQill, American Recovery and Reinvestment Act-Reporting Requirements (JuI2010) (Pub. L 

111-5). 

]_ (6) 52.209--6 Protecting the Government's Interest When Subcontracting with Contractors Debarred, 

Suspended, or Proposed for Debarment. (Dec 2010) (31 U,S,C, 6101 note) 

_ (7) 52.209-9, Updates of Publ icty Avai lable Information Regarding Responsibitity Matters (FEB 2012) (41 

USC. 2313). 

_ (8) 52.209-10, Prohibition on Contracting with tnverted Domestic Corporations (MAY 2012) (sectioo 738 of 

Division C of Pub. L, 11 2-74, section 740 of Division C of Pub. L. 11 I-I 17, section 743 of Division D of Pub. L, 111-8, 

and secUon 745 of Division 0 of PUb. L. 110-161) 

_ (9) 52,219-3, Notice of HUBZone Set-Aside or Sole-Soorce Award (NOV 20t 1) (15 U,S,C. 657a). 

_ (10) 52.219-4, Notice of Price Evaluation Preference for HUBZone Small Business Concern s (JAN 2011) 

(~the offero r elects to waive the preference, ~ shall so indicate in its offer) (15 U.S.C 657a) 

_ (11) (Reserved] 

_ (12Xi) 52.219-6, NoUce of Total Small Business Set-Aside (NOV 201 1) (15 U,S,C. 644). 

_ ~i) Merna!e I (NOV 2011) 

_ Oii) AHernate II (NOV 2011) 

_ (13Xi) 52.219-7, Notice of Partial Small Business Set-Aside (June 2003) (15 US.C. 644) 

_ Oil AHernate I (Oct 1995) of 52.219-7 

(iii) AHerna!e II (Mar 2004) of 52.219-7 

- _ (14) 52.219-8, Utilization of Small Business Concerns (Jan 2011) (151J S c. §37(dl!2) and (3)) 

_ (15Xi) 52.219-9, Small Business Subcontracting Plan (Jan 2011) (15 US.C 637!d)/4l) 

_ Oil Mernate I (Oct 2001) of 52.219-9. 

(iii) Merna!e II (Oct 2001) 0152.219-9 = [IV) Alternate III (Jul2010) of 52,219-9 

_ (16) 52.219-13, Notice of Set-Aside of Orders (NOV 2011)(15 US,C. 644(r)) 

]_ (17) 52,219-14, Limitations on Subcontracting (NOV 2011) (15 U.S.C 637(a)(14)). 

_ (18) 52.219-16, Liquidated Damages-Subcontracting Plan (JAN 1999) (15 U.S.C, 637(d)(4XF)(i)). 

_ (19Xi) 52.219-23, Notice of Price Evaluation Adjustment for Small Disadvantaged Business Concerns 

(OCT 20(8) (10 U,S,C. 2323) (dthe offeror elects to waive th e adjustment, ~ shall so indicate in its offer) 

_ Oil Merna!e I (JUNE 2(03) of 52.219·23 

_ (20) 52.219-25, Small Disadvantaged Business Participation Prtlgram-Oisadvantaged Status and 

Reporting 

(DEC 2O tO) (Pub. L. 103-355, section 7102, and 10 USC. 2323) 

_ (21) 52.219-26, Small Disadvantaged Business Participation Prtlgram-Incentive Subcontracting (OCT 

2000) (Pub. L. 103--355, section 7102, and 10 USC. 2323) 

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330 


(22) 52.21!1-27, Notice of Service-Disabled Veteran-Owned Small Business Set-Aside (NOV 2011) (15 

U,S,C. 657(I). 

]_ (23) 52.219-28, Post Award Small Business Program Rerep-esentation (APR 2012) (15 U,S,C. 

632(a)(2)). 

_ (24) 52.21!1-29, Notice of SeI.Aside for Economicaly [)jsaMntagedWomen..{Nmed Small Business 

(EOWOSB) Concerns (APR 2012) (IS U.S,C. 637(m)). 

12 

_ (25) 52.21!1-30, Notice of SeI.Asic!e forWomen..(),yned Small Business ('WOSS) Concerns Eligible Under 

theWOSB Program (APR 2012) (15 U,S,C. 637(m}). 

]_ (26) 52nH Convict Labor (JUNE 2(03) (EO. 11755) 

X (27) 52.222·19, Child Labor-Cooperation IYith Authorities and Remedies (MAR 2012) (E.O. 13126). 

=x= (28) 52.222·21 , Prohibition of Segregated Facilities (FEB 1999). 

X (29) 52222·26, Eq ual Opportunity (MAR 2007) (E.O. t 1246). 

=x= (30) 52.222·35, Equal Opportunity for Veterans (SEP 2010)(38 U.S.C. 4212). 

J_ (31) 52.122·36, Affirmative Action forWorl<ers with Disabilities (OCT 2010) (29 USC. 793) 

]_ (32) 52.222-37, Employment Reports on Veterans (SEP 2010) (38 U,S.C. 4212) 

_ (33) 52.222-40, Notificatioo of Employee Rights Underlhe Natonal Laboo' Relatons Act (DEC 20(0) (E.O. 

13496) 

_ (34) 52.222-54, Empoyment Eligibility Verificatioo (JAN 2009). (Executive Order (2989), (Nol applicable 

10 the acquisition of commerciany available off-the-shelf items or certain other types of commercial items as 

prescribed in 22,1803,) 

_ (35Xi) 52.223-9, Estimate of Percentage of Recovered Malerial Content for EPA--Designated Ilems 

(MAY 2008) (42 U.S.C. 6962{c)(3)(A)(ii)), (Not awlicable to the acquisition of commercially available off-the-shelf 

items,) 

_ Oil AHernate I (MAY 2008) of 52.223-9 (42 US.C. 6962(i)(2){C)), (Not applicable to the acquisition of 

commercially available off-the-shelf Hems,) 

(36) 52.223-15, Energy Efficiency in Energy-Consuming Products (DEC 2007) (42 US.c. 8259b). = (37Xi) 52.223-16, IEEE 1680 Standard for the Environmental Assessment of Personal Computer Products 

(DEC 20(7) (E.O (3423) 

_ Oil AHernale I (DEC 2007) of 52.223-16. 

]_ (38) 52.223-18, Encouraging Contractor Policies to Ban Text Messagifig While Oriving (AUG 201 I) (EO. 

135(3) 

_ (39) 52.225-1 , Buy American Act-8upplies (FEB 2009) (4 1 U.S.C IDa-10d) 

_ (40Xi) 52.225-3, Buy American Act- Free Trade A[1eements-lsraeli Trade Act (MAY 20(2) (41 

U,S,C.cIlapter83, 19 U,S,C, 3301 note, 19 U,S,C. 2112 nole, 19 US.C. 3805 note, 19U5.C. 4001 note, Pub. l. 103-

182, 108-77, 108--78, 108-286, 108-302, 109--53, 109-169, 109-283, 110-138, 112-41 , and 112--42) 

_ 0i) AHemate I (MAR 20(2) of 52.225-3 

_ (ii i) Alternate II (MAR 2012) of 52.225-3 

_ (rv) AHernate III (MAR 2012) of 52.225-3. 

_ (41) 52.225-5, 52,225-5, Trade Agreements (MAY 2012) (19 U.S.C, 2501 , ef seq., 19 U.S.c. 3301 note). 

] _ (42) 52.225-13, Restrictions on Certain Foreign Purchases (JUNE 2008) (E,O.'s, proclamations, and 

statutes actninistered by the Office of Foreign Assets Control oflhe Department of the Treasury). 

_ (43) 52.226-4, Notice of Disaster or Emergency Area Set-Aside (NOV 2007) (42 US.C. 5150) 

_ (44) 52.226-5, Restrictions on Subcoolracting OUtside Disaster or Emergency Area (NOV 2007) (42 

US C. 5150). 

_ (45) 52.232-29, Terms for FinanCing of Purchases of Commercial Items (FEB 2002) (41 U.Sc. 255{f), 

10 U.SC. 2307(f»). 

(46) 52.232-30, Installment Payments for Commercial Items (OCT 1995) (41 U.S.G. 255(f), 10 US.C 

2307{f») -

_X_ (47) 52.232-33, Payment t7t Electronic Funds Transfer-Central Contractor Registration (OCT 2003) 

(31 U.S.c. 3332). 

_ (48) 52.232-34, Payment by Electronic Funds Transfer-Other than Central Contraclor Regislrabon 

(MAY 1999) (31 U.S.C. 3332). 

_ (49) 52.232-36, Payment by Third Party (FEB 2010) (31 U.S.G. 3332). 

_ (50) 52.239-1 , Privacy or Security Safeguards (AUG 1996) (5 US.c. 552a) 

_ (51 Xi) 52.247.04, Preference for Privalely OMled 

_ Oil AHernate I (Apr 2003) of 52.247.04 

(c) The Contractorshall comply with the FAR clauses in this paragrap'l (c), applicable to commercial 

services, thai Itle Contracting OffiCer has indicated as being incorporated in this contract by reference to impement 

pmvisions of lawor Execulive orders applicable to acquisilioos of corrvnercial items 

_ (I) 52.222--41, Service Contract Act of 1965, (Nov 2007) (4 1 US.C 351 , el seq) 

TP~FP·12-C-0017 
331 


13 

(2)52.222-42, Statement of Equivalent Rates for Federal Hires (May 1989) (29 US.C 200 and 

- 41 U.S,C. 351, el seq.) 

_ (3) 52.222-43, Fair Labor Standards Act and Service Contract Act-Plice AdlllStmen! (MuHipie Year and 

Option Contracts) (Sep 2009) 129 U,S,C. 206 and 41 U,SoC 351 e/ seq.). 

_ (4) ~ Fair Labor Standards Act and Service Contract Act-Price Adjustment (Sep 2009) 

(29 US.C 200 and 41 US.C 351 el seq.) 

_ (5) ~ Exemption from Application ofltle Service Contract Act to Contracts for Maintenance, 

Calibration, or Repair of Certain Equip-nenl-Requirements (Nov 2007) (41 USC 351 el seq ) 

_ (6) ~ Exemption from Application ofl!le Service Contract Act to Contracts for Certain Ser.icesRequirements (Feb 2009) (41 U.SoC 351 ef seq) 

_ (7) 52.226-6 Promoting Excess Food Donation to NonprofitOrganizations (Mar 2009) (Pub. L. 110-247) 

_ (8)52.237-11 Accepting ar.d Dispensing of $1 Coin (Seli 2008) (31 U.S.c. 51 12(pl(l lJ 

(d) ComplrollerGeneral Examination of Recad. The Contractor shall comply with the p-ovisions of this 

paragraph (d) if this contract was awarded using other than sealed bid, is in excess of the simplified acquis~ion 

tIlreshold, and ooes not contain the clause at 52.2t5-2, Audit and Records-Negotation. 

(1) The Com~rolierGeneral of the Un~ed Stales, or an authorized representative of tile Com~roller General, 

shall have actes5 to and right to examine any of tile Contractor's directty pertinent records inllOlving transactons 

related to this contract 

(2) The Contractor shall make avaitable at its offices at all reasonable tmes the records, materials, and other 

eWience for examinabon, aud , or reprodoction, until 3 years after final payment under this contract orfor any shorter 

period specified in FAR Subpart 4.7, Contractor Records Retention, of the other clauses of this contract. If this 

contract is completely or partially terminated, the records relating to the war« terminated shall be made available for 

3 years after any resulting final termination settlement Records relating 10 appeals under the disputes clause or 10 

I~ig atio n or the settlement of claims arising under or relating to this contract shall be made available until such 

appeals, litigation, or claims are finally resolved 

(3) As used in this clallSe, records include boo~s, documents, accounting procedures and practices, and 

other data, regardless oftype and regardless of form This does not require the Contractorto create or maintain any 

record thatlhe Contractor does not maintain in the ordinary course of business or pursuant to a provision of law 

(e)(I) Notv.ithstanding tile requirements of the clauses in paragraJils (a), (b), (c), and (d) of this clause, the 

Contractor is not required to ftcw down any FAR clause, oIherthan those in paragraphs (e)(I)(i) through (xi) of this 

paragraJil in a subconlractforcommercial ~ems. Unless otllerNise indicated below, the extent oflhe flcMr down shall 

be as required by the clause----

Wl ~ Contractor Code of 8usiness Ethics and Conduct (Apr 2010) (Pub. L. 110-252, Trtle VI, 

Chapter 1 (41 USc. 251 note)) 

(ii) ~ Utilization of Small8usiness Concems (Dec 2010) (15 US.C. 637(d)(2) and (3)), in all 

subcontracts Ihat offer further subcontracting opportunities. lIthe subcontract (except subcontracts to small business 

concems) exceeds S650,000 (SI ,5 million for construction of any public facility), the subcontractor must include 

52.219-8 in iowerter subcontracts that offer subcontracting opportunities 

(iii) [Rese~dJ 

(iv) 52.222-26 Equal Opportun~y (Mar 2007) (E.O. 11246) 

(v)~ Equal OpportunrtyforVeterans (Sep2010) (38lJSC 4212) 

(vi) 52.222-36 Affirmative Act~n for Workers with Disab~ities (Oct 2010) (29 U.S.C 793) 

(vii) ~ Notrtication of Employee Rights Underlhe Natonal Labor Relatons Act (Dec 2010) (E.O. 

13496). FIcMr down required in accordance with paragraph (f) of FAR Clause 52.222-40 

(viii) 52.222-41 Service Contract Act of 1965 (Nov2007) (41 USC, 351 el seq.). 

(ix) 52.222·50, Combating Trafficking in Persons (Feb 2009) (22 U.SC 71041ql) 

_A1temate I (Aug 2007) of 52.222-50 (22 U,S.C, 71041q)) 

(x) 52.222-51 Exem~ion from Application of the Service Contract Act to Conlracts for Maintenance, 

calibration, or Repair of Certain Equipment-Requirements (Nov2007) (41 US.C, 351 et seq.). 

(xi) ~ Exem~ion from Appication oflhe Service Contract Act to Contracts for Certain Services· 

Requirements (Feb 2009) (41 U.SC, 351 et seq.) 

(xii) 52.222·54 Employment Eligillity Verification (JAN 2009). 

(xiii) 52.226-ll Promoting Excess Food Donation 10 Nonprof~ Organizations (Mar 2009) (Pub. L 110-247) 

Fk:lwdown required in accordance with paragraph (e) of FAR clause~. 

(xiv) 52.247-ll4 Preference for Privately ONned U.S.-Flag Commercial Vessels (Feb 2006) (46 US.C 

Appx. 1241 (b) and 10 U,S.C. 2631), Fk:lw down required in accordance with paragraph (d) 01 FAR 

clause~ 

IU: ·1 2~..oot7 
332 


14 

(2)While not required, lIle contractor may include in its subcontracts for commercial nems a minimal number 

of add~ional clauses necessary to sabsfy Is contractual obligations 

Alternate I (feb 2000). As prescribed in .1.UQ!.(b)(4)(i), delete paragraph (d) from the basic clause, redesignate 

paragraph (e) as paragraph (d), and revise the reference to "paragraphs (a), (b), (e), or (d) of this clause" ... the 

redesignated paragraph (d) to read "paragraphs (a), (b), and (e) ofltlis clause" 

Al/ema/e 1/ (Dec 2010), As pmscribed in l11Q!(b)(4)Oi), substitute thefollov.ing paragraphs (d)(l ) and (e)(I) for 

paragraphs (d)(I) and (e)(I) of the basic clause as fo llows: 

(d)(l) The Comptroller General of the Un~ed States, an appropriate Inspector General appointed under section 3 or 

8G or the Inspector General Act of 1978 (5 U.S.C. App.), or an authorized representative of either of the foregoing 

officials shall have access to and right to--

(i) Examin e any of the Contractor's or any subcontractors' records that pertain to, and involve transacbons retabng to, 

this contract; and 

(ii) tnterview any officer or emptOye€ regarding such transactions 

1'1 

(t) Notwithstanding the requirements of the clauses in paragra~s (a), (b), and (c), of this clause, the Contractor is not 

required to flowdOWTl any FAR clause in a subcontract for commerc ial items, other than-

(i) Paragraph (d) of this clause. This paragra~ nows d(Mll'l to all sulxontracts, exce/X the authority of the Inspector 

General under paragra~ (d)(I)(i) does not now down; and 

(ii) Those clauses listed in this paragaph (e)(l). Unless otherwise indicated below, the extent of the fk::woown shall 

be as required by the clause--

(A) 2UQlli, Contractor Code of Business Ethics and Conduct (Apr 2010) (Pub. L. 110·252, Title 

VI, Cha/Xer 1 (41lJSC 251 note)). 

(8) 2UQill, Wh s~eblower Protections Under the Ameocan Recovery and Reinvestment Act of 

2009 (June 2010) (Section 1553 of Pub. l. 111-5) 

(C) ~ Utilization of Small Business Concerns (Dec 2010) (15 US.C. 637(dl(2) and 13», in al l 

subcontracts that oller further subcontracting opportunities. If the subcontract (except subcontracts to small 

business concems) exceeds 5650,000 ($1 .5 mill ion for construction 0( any public fac ility), the subcontractor 

must include 52.219-8 in lower tier subcontracts that oller subcontracting opportunities 

(0) 52.222·26 Equal Opportunity (Mar 2(07) (E.O. 11246) 

(E) 52.222-35, Equal Opportunity forVelerans (Sep 2010) (38 U.SC 4212) 

(F) ~ Affirmative Action fOo" Workers wth Disablities (Oct 2010) (2911 SC 7931. 

(G) 52.222-40, Notification of EmploYe€ Rights Under the National Labor RelationsAct (Dec 2010) 

(E.O. 13496). Flowd(Mll'l required in accordance with paragraph (f) of FAR clause 52.222-40. 

(H) 52.222·41 Service Contract Act of 1985 (Nov 2007) (4 1 U.S.C 351, et seq) 

~) 52.222-50 Combating Traff c~in g in Persons (Feb 2009) (22 US.C 7104fg)) 

(J) 52.222·51 Exemption from Application of the Service Contract Act to Contracts for Maintenance, 

calibration, or Repair of Certain Equip:nent-Requirements (Nov 2007) (41 U.SC 351 et seq.). 

(1<) 52.222-53, Exemption from Application olthe Service Contract Act to Contracts for Certain 

Services-Requirements (Feb 2009) (41 lJ.S C 351 eI seq.). 

(l) 52.222·54, Employment Eligibility Vertication (Jan 2009) 

(M) ~ Promoting Excess Food Donation to Nonprofit Orga nizations. (Mar 20(9) (Pub. L 

110-247) Flow OO\Yll required in accordance with paragraph (e) of FAR cJause 52.226-6. 

(N) ~ Preference for Privatety ONned US.-Flag Commercial Vessels (Feb 2006) (46 lJ S C. Appx. 12411bl 

and 10 U.S.C. 2631 ) Flowdown required in accordance with paragraph (d) of FAR clause 52.247-64. 

CONTRACT DOCUMENTS EXHIBITS AND An ACHMENTS 

DOCUMENT/EXHIBIT! An ACHMENT TITLE 

Attachment 1 - Pay Day lending Perfonnance Work Statement 

IPPWaiver Form 

TP IU: FP·1 2~-OO17 
333 


Payday Lending Data Project 

Performance Work Statement 

15 

1.0 OVERVIEW I BACKGROUND. Ol JIiy 21, 2010, President 00000 si9fled the DJdd-Frank Wall 

Street Reform aoo Const.mer Protection Act (the "Act'), which created the Coost.mer Finarcial Protection 

Bureau (CFPB). Under the Act, part of CFPB's mission is to determine whether and 00w to develop 

policies regardirg COrlSlJTlef finardal prodlds am sefVices, such as 5oort-term, small dollar "payday" 

loans. Accordirgly, \he Government seeks a contractor to provide an analysis of payday loan usage 

accom~nied wrtll irldicalors of borrowers' overall finarK:ial health. This analysis shall incll.de the 

provision of data to CFPB detailir,g fXlyday loan usage p:!ltems over a specified period of lime. Payday 

loan usage data shall be matched w~h oltler data sources thai track COOSl..fref finarcial well-beirg, su::h 

as cred~ reportir19 agercy (eRA) reports 

2.0 OBJECTIVE. ms data collection will allow CFPB to better understaoo 

the distriMoo of payday loan usage patterns amorg oorrowers, 

patterns of default on payday loans, 

row different levels of usage are correlated w~h charges in other financial measures such as 

credit scores, bank accourt status, and overall creditworthiness, ard 

row payday loan oorrowers' indcators of cred~ worthiness and overall financial heaHh 

compare to similarly-s~uated rouserolds that do not use payday loans 

3.0 SCOPE. The cortractor shall provide CFPB a nationally-representative dataset of payday 

oorrowers ottaining loans through the internet and slorefrort channels from a diverse variety of payday 

lenders. The usage data for 1M sample of oorrowers shall be for a period of at least 12 !T'(lnths from lhe 

date a oorrower first is reJXIrted as usirg a payday loan and shall detail the size of loans originated, 

whether and when a loan is repaid, renewed, or in default, \t1e overall ntrnber of loans applied for ard 

taken by a given oorrower over this tme period, and the time period between loans. Information 

obtained through surveys of payday borrowers who self.report their use of payday loans is not 

adequate for this analysis. 

In add~ion, the cortractor shall match rts payday borrower records wrth addrtional data available th"ough 

cred~ rep:xting agencies and other lhird parties to develop a data set that includes other measures of 

finarcial well-being such as credrt scores, red~ ut~lzat io n and delinquency, and bank account status (ie: 

overdrafts andlor involuntary accollll closures) before, during, and after the 12 mon\t1 period of payday 

loan usage. 

Finally, the contractor shall perform an analysis of similarly s~ualed houselllids that-based on the 

contractor's records-are not payday loan borrowers dlJirlg the stlXly lime period. The contractor 

shall develop a data set of these Illuserolds thai measures changes in financial well·beirlgthroug, 

cred~ scores, credit utillzation ard delirK1uency, and bank accolJ1t status to compare with the analysis 

of payday loan borrowers described atme 

The final metlYldology for ths analysis will be developed in consultation w~h CFPB staff and require 

the approval of the CFPB's Office of Research 

4.0 PERIOD OF PERFORMANCElDELIVERY REQUIRED. The contractor shall electroOcally deliver 

a surmlary of data findings and the lXlderlyirg de-de rt ~ied data in a spreadsheet-corrpati~e format to 

CFPB w~hin five morths. Dataset will be in a format thai is readily assessa~e through software sl£h as 

SAS or STATA. The contractor shall also be available f()( an additional month to answer clarifyirg and 

technical questons from CFPB staff aboU the report and accomparfjing data. Add~ionally, there will be 

two option periods in whK:h the Contractor may be required to provide a data refresh at six and 12 rrorths 

after the initial report is provided 

BPD-CFP-12-C1.(X))7 
334 


16 

S.O CONTRACTOR TRAVEL. Contractor will be feqJired to \ravel 10 CFPB for ore meeti ~ at the 

beginning 01 the five month work period of this project to develop a final mett'OOology f()( tI1 is data 

analysis, in consuHation with CFPB staff 

6.0 DATA RIGHTS. The Government has ur m~ed rights to all docllTlentsimaterial delivered to the 

CFPB IJlder this cootract. All dOOJments and data summaries delivered to the CFPB under this contract 

shall be Goverrmefll owned ard are the pwperty of the Government with all rights aoo privileges 01 

ownershi.cVcopyrigrl belongirg exclusive~ to the Government. These documents ard materials may rot 

be used or sold by the contractor without written permission from the Contracting Officer. Al l materials 

supplied to \he Goverrmert shal l be the sole lX"operty of the Govemmerrt and may oot De lISed for any 

other purpose. This right does not atrogate any other Government rights. 

7.0 QUALITY ASSURANCE (QA). n~ government shall evaluate the contractor's performaoce 

lflder the contract in accordarce with ltle standards out1ined in Ire Performance Requirements Sunvnary 

(PRS). The PRS defines lhe performarce o~ectives, performarce slarxlard, lhe mettod of surveiltarce 

and Ire incentivesldisirceriives 

8.0 PERFORMANCE REQUIREMENTS SUMMARY (PRS). The contraclor service requiremerlls are 

slJl1rTlarized into performarce o~eclives lhal relate directly to mission essential items. The performarce 

starxlard il"ieny descrit:oes the minirrum acce.ctab'e levels of service reqlired for each requirement. 

These slarxlards are critical to mission success. 

BPD-CFP-12-C1.(X))7 
335 


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336 


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TlOCfp·12<:<))1 i 
337 

Corelogic Information Solutions Inc. 


AMENDMENT OF SOUCITATlONIMODIFICATlON OF CONTRACT 11. CONTRACTIO CODE rA:E 0, PAGES 

1 2. AMENOMENTIMODIFICATION NO. 13. EFFECTIVE DATE 4. REOUISITIONIPURCHASE REO. NO. r PROJECT NO. Iff .ppIicsbIe) 

0002 04/17 /2013 

6. ISSUED BY CODE IBPD-RDILLON 7. ADMINISTERED BY Iff albar thlJn Item 6) CODE IBPD 

Bureau of the Public Debt Bureau of t he Public Debt 

Divison of Procurement Di vision of Procurement 

Avery 5F Administration Branch 

200 Third Street Avery SF 

Attn: R. Dillon 200 Third Street 

Parkersburg WV 26101 Parkersburg WV 26101 

8. NAME AND AOORESS OF CONTRACTOR (No .. _. """Y, St" .... ZIPCOdeI (x) 9A. AMENDMENT OF SOLICITATION NO 

rCORELOGIC INFORMATION SOLUTIONS INC 

4 FIRST AMERICAN WAY 9B. DATED (seE (TEM 11) 

SANTA ANA CA 92707-5913 

x lOA MOOIFICATION OF CONTRACT/ORDER NO. 

TPD-CFP-12-C-0010 

lOB. DATED (SEE ITEM 13) 

CODE 167200760 I FACILITY CODE 08/02/2012 

11. THIS ITEM UNL APPLIES TO AMENDMENTS OF $OuCllATIONS 

DThe_numberedsoiicilal",,~amencledBS .. lforth,,"omI4. 1hehoOJranddaiespocifiedfOlrecoiplofOff... D~oxIanded, D~noIox1enc1ed 

OffersmUSlllCknowledgerecoiptollhisamendmeni prior 10 1M hoOJr and dale spocifiedinIMsoii:ilalionor as amended, by one oflhe following melhods: (.)By comp~1ing 

lIams8andl5,andreltming __ cop~oIIMamendmenl;(b)8yad<nowledg01gleceipi oflhisamendment"'eac!1copyoflMoffersubmilled;or (c)By 

separaIe leIIer or leIegtam which includes. ,.,.....,.10 1M solicilation and amendmenl num~. FAILURE OF YOUR ACKNOVvl.EOOEMENT TO BE RECEIVED AT 

THE PLACE DESIGNATED FOR THE RECEIPT OF OFFERS PRIOR TO THE HOUR AND DATE SPECIFIED MAY RESULT IN REJECTION OF YOUR OFFER Kby 

vir1IJeoflhisamendmenlyou_lOcf1angeanoller.lreadysubmilled, suchcf1angemaybemadebyl.legramorleller,proyidedeac!1le1egtamorlell.,mal<es,.,.....,. 

10 1M soiicilation andlhisamendmanL and ~ received ptiorlOIMopen~g hour and dale spocified 

12. ACCOUNnNGAND APPROPRIATION DATA (I/required) 

See Schedule 

11. THIS ITEM ONLY APPLIES TO MODIACATION OF CONTRACTSIORDERS. IT MODIAES THE CONTRACT/OROER NO. AS DESCRIBED IN ITEM 14, 

~ A. ~~&~q~ ~Ef~ ISSUED PURSUANT TO: (Spec;fy .ufhclity) THE CHANGES SET FORTH IN ITEM 14 ARE MADE IN THE CONTRACT 

C. THIS SUPPLEMENTAL AGREEMENT IS ENTERED INTO PURSUANT TO AUTHORITY OF 

D. ulHER (SpecifyfypeofmooificalionanctaufflclifyJ 

E.IMPORTANT: Contracior l!Jisnol Disrequi1edlOsignlhisdooJmenlandrelum 

14. DESCRIPTION OF AMENDMENTIMOOlFICATION (Otganized by UCF section headings, including soiicifalionlconfracl subjed matlerwhare feasible.) 

The purposes of this modification are to: 

1. Appoint Jessica Russell as the Contracting Officer's Representative (COR) . Jessica may 

be reached at 202-435-7771 or via email at Jessica. Russell@cfpb .gov . 

2. Appoint Xiaoling Ang as the Alternate COR. Xiaoling may be reached at 202-435-7686 or 

via email at xiaoling.ang@cfpb.gov. 

Period of Performance: 08/02/2012 to 08/01/2017 

Exc:eples provided her.", alilerm, and c:cnd~~ns of 1M dooJmenl ,.,.,anced in 110m 9A or lOA, as he18lofore changed, 18mains II1changed and in full force and effect 

15A. NAME AND nne OF SIGNER (Type or plinlJ 16A. NAME AND nne OF CONTRACTING OFFICER (Type or plinl) 

158. CONTRACTORIOFFEROR 

NSN754O<l1·152.s070 

Pl8'Iiouseditionurwsab~ 

JACOB C. OBERLIN 

15C. DATE SIGNED 16B. UNITED STATES OF AMERICA 16C. DATE SIGNED 

__ --=-...,...?'Ju 4.17,2013 

r~otCMltlCtitr!l~ 

STANDARD FORM 30 (REV, 1~) 

Prescribed by GSA 

FAR (48 CFR) 53.243 
338 


• 

DEPARTMENT OF THE TREASURY 

BUREAU OfTHE PUBLIC DEBT 

PARKERSBURG, WV 26106-1328 

'2 AugusI2012 

Corewgic Information Solutions, Inc. 

Attn: Mr. Dave Hun 

4 First American Way. 

Santa Ana, CA 92707·5913 

Subject: TPD-CFP-12-C-0010 

Dear Mr. Hun: 

Congratulations! Enclosed is contract number TPD-CFP-12-C-0010 for Loan-Level Mortgage 

Dalasets in support oflbe Consumer Financial Protection Bureau (CFPB). 

Please review the enclosed contract award and ifin agreement, please complete blocks 30a, 30b 

and 30e on Page I of the Standard Form 1449. By signing the SF 1449, you acknowledge and 

accept the terms and conditions of this contract. After signing the document, please provide a 

copy of the signed form via email to carev.grow@.bpd,treas.gov. 

Please nole thaI due to lhe nature of the proposals received, the Indefinite-Delivery IndefiniteQuantity terms and conditions were remo\'ed upon award. 

After award, any questions or issues related to this procurement will be handled by the Contract 

Administration Branch at contractadministration@bpd.treas.gov. When sending an e-mail to this 

address, please include the award number in the subject line of the e-mail. 

Ms. Xiaoling Ang has been designated Contracting Officer's Representative (COR) for this 

contract. A copy of our letter so designating Ms. Ang is enclosed for your information. It 

contains information on her duties and the scope of her authority in this capacity of which you 

should be aware. Ms. Ang may be reached at 202-435·7686 or via e-mail at 

xiaoling.ang@cfpb.gov. 

If you have any questions concerning the award, please contact Ms. Carey Gropp, 304-480-8559. 

Enclosures 
339 


~ 

A, .. , .... 1<1 .. 11 .. II1II 

11M G .. , ...... 

_101100 OC IOU.! 

t:OWoCII:e ~11~ """"lOIS IOC 

__ 

• ttUT IIDltM 'A' a.mt1-:»t 

· .• ··JI. WI 1. 2' 

Q----_ .. - -,. 

- __ SIS.' 
340 


2 of 13 

~~ " SOEru..E<:F~S " ~ " ~ " " ~~, .~ " 

Government Technical POe : Mr . Daniel Grantham 

Tel : 202- 435- 7666 

E-J:lail : d~niel gr~nth~ro@cf[X> gov 

Suppl emental Term::;, Condition::; and Clause.s are 

att~ched hereto ~nd hereby incorporated. 

Invoice.s are to be p~id a.s ~ prcduct Net 30 day.s 

from receipt/acceptance . Invoice::; ... ill be 

.submitted on an annual ba.si.s. 

lony que.stion.s related to thi::; a ... ard will be 

handled by the Contract Admini.stration Branch at 

conte actadmini.str ation@bpj . trea.s. gob . "''" .sending an e-mail to thi.s addre.s.s, plea.se include 

the award number in the .subject line . 

Note : The ,FP amoun t.s identified in each CLIN are 

not dependent upon the numbe r of e r PB ~er.s .since 

all querie.s by CFrB u.ser.s ... ill be made again.st 

BPD/C,PB .server asset.s . 

Credit Card Vendor: NO 

Accounting Info : 

crp55 77srxXXX - 20 12- 61 000 \-CFP401 0000-2513- 0000000 

-:o:.x-XX -xxxxxxxxx -xxxxxxxxx-xxxxxxxxx 

Period of Perfonnance : 08/02/2012 to 08/01/2017 

Continued ... 

o RECEIVED OIl<SPECTEO o ACCEPIED . .<NO COHFOIlMS 10 THE romRACT. EXC8'T AS NOlEO 

ll!> SK;N~TURE OF .oJJiHORIZEOGOI'ERNMENI REPPESEN1~TrlE Il1CD.O.1E IN PflNlEO NAME .... O I~le OF AUIHQRI.ZEO GOVERliMENI RePflEseNl~TO/E 

)1. ""'l NG -'OORESS OF AUTff:)RI.ZEO GOVE""":MT REPIlESENT~TO/E l~. lElEPttOIE NJIj(j£R Of /<UTHO RI.ZEO GOVERNMENlI'IEPfiESENIATIVE 

l~ E-MAL OF AAHOR~EO GOVER""ENT REPRESENT~T"'E 

II SHf'NltoIOCR VOOCI£R NltoIOCR ~~OUNIVERFE;D 36 P~YI.ENI 31 CHECK NJ_R 

~ECTfOR 

OPAATlAl D~' 

OCOIoIFtE/€ OPAAT~ 0'-

I'" WII.lIJCHERNIJMOCR 1"1 pmsy 

'j. I CERTfY THISACCOUNT IS CORRECT 00 PflOI'"ER f{)R P~YMENI '1. RECEIVEO B"I" (1'00) 

llt> ReCEN'£DA'(t.ocfl>O.O) 

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342 


SUPPLEMENTAl TERMS, CONDITIONS AND CLAUSES 

SECTION 508 COMPLIANCE 

All electronic and information technoklgy (EIT) procured through this contract must meettne appli ca~e accessibi y 

standards at 36 CFR 1194, unless an agency exception to this requirement exists. (36 CFR 1194 implements Section 

508 of the Rehabi ~a ()n Act of 1973, as amended. 

tn accordance w~h the above, in addition to the Technicat Requirements, contraclorsJvendors must ensure thai atl EtT 

that they provide either. (1) meets the technicat provisions of the Section 508 Access Board Standards applicable to a 

grven procurement (see bebw); or (2) uses designs orteclmobgies as aHemalives to those prescribed in the 

specified technical provisions, provided they res uH in substantially equNalent or greater access to and use of a 

product for peopte with disabMies 

The following standards have been determined to be applical)e to this contract 

_ _ 1194.21 Software applica~ons and operating systems 

L- 1194.22Wetrbased i'ltranet and intemet information and appncations 

__ 1194.23 Telecommunications products. 

__ 1194.24 Video and muHimedia products 

__ 1194.25 SeH-contained, closed products. 

__ 1194.25 Desktop arid portable computers 

__ 1194.31 Functional Performance Criteria 

__ 1194.41 Information, Documentation arid Support. 

The standards do not require the instaUation of spec~ic accessibility-related software or the attachment of an assislive 

technology device, oot merely require that the EIT be compati~e with soch software and devices so that itcan be 

made accessible if so required by the agency in the future,' 

PUBLIC-RELEASE CONTRACT VERSION REQUIREMENT 

The contractor agrees to subm~, within ten business (10) days from the date the contract is awarded (exclusrve of 

Saturdays, Sundays, and federal holidays), a text-based .p::fffile of the fully executed contract with all proposed 

necessary redactions, including redactions of any trade secrets or any commercial or financial information thatl 

believes to be privileged or confidential business information, for the purpose of pu~ic disclosure at the sole discretion 

of the Consumer Financial Protection Bureau (CFPBj. The contractor agrees to provide a detailed written statement 

specifying the basis fo r each of its proposed redactions, l1cluding the applicable exemption under the Freedom of 

Information Act (FOtA). 5 U.SC. § 552, and, in the case of FOIA Exemption 4, 5 U.S.C § 552(b)(4), shall 

demonstrate why the info rmation is considered to be a trade secret or commercial or financial information that is 

privi leged or confidential. Information provided by the contractor in response to this contract requirement may itself be 

subject to disclosure under the FOIA. The CFPB will careful y consider the entire contractor's proposed redactions 

and associated grounds for nondisclosure prior to making a final determination as to what information in the fully 

executed contract may be property withheld. In the event that the CFPB disagrees with the contractor's suggested 

redactions, the CFPB will provide the contractor with notice prior to posting the contract. 

SOFTWARE FEDERAL DESKTOP CORE CONFIGURATION (FDCC) 

AI software which is designed to run on Windows Vista or XP desktops must fu nction without modification to th e 

Federal Desktop Core Configuration (FOCC) security configurations developed by the National lnsmute of Standards 

aoo Technology (NIST), the Department of Defense (DoD) and the Department 01 Homeland SeCUrly (DHS). 

Software and hardware products that are designed to operate in environments other than the FDCC desldop must 

have a standard configuration guide published on the NIST website, or the vendor must supply a recommended 

configuration guide for al l configurable security settings 

52.212-4 CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (fEB 2012) 

(a) Inspection/Acceptance. The Contractor shan only tender for acceptance those ~ems that conform 10 the 

requirements of this contract. The Government reserves the right to inspect or test any supplies or services 

Page (4 
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that have been tendered for accelXance. The Govemment may requre refXIiror replacement of 

nonconforming suppUes or reperformance of nonconforming services at no increase in contract price. If 

repair/replacement or reperformance wil l not correct the defects or is not possible, the Govemment may 

seek an equ~able p1ce reduction or adequate consideration for accelXance of nonconforming supplies or 

services, The Govemment must exercise ~s post-acceptance rights-

(1) Within a reasonable time after the defect was discovered or should have been discovered; and 

(2) Before any substanlial change occurs in the condition of the item, unless the change is due to the 

defect in the ijem 

(b) ASSignment. The Contractor or its assignee may assign its rights to receive payment due as a result of 

performance of this contract to a tenk, trust company, or other financing institution, including any Federal lending 

agency in accordance with the Assignmentof Claims Act (31 USC. 3727). HO'M'!ver, wtlen a third party makes 

payment (e.g., use of the Governmentwide commercial purchase card), lt1e Contractor may not assign its rights to 

receive payment under this contract 

(c) Changes. Changes in the terms and condibons of lt1is contract may be made only by written agreement of 

lt1e parti€s. 

(d) Disputes. This contract is subject to lt1e Contract Disputes Act of 1978, as amended (41 U,S.C. 601-613). 

Failure of lt1e parties to this contract to reach agreement on any request for equitable adjllStment, claim, appeal or 

action ariSing under or relating to this contract shall be a dispute to be resot.oed in accordance with the clause at FAR 

52.233-1, Disputes, ...mich is incorporated herein by reference. The Contractor shall proceed diligently with 

performance of this contract, pending final resoluton of any dispute arising under the contract. 

(e) Definitions. The clause at FAR 52.202-1 , Oefinnions, is incorporated herein by reference. 

(D Excusable delays. The Contractorshall be liable for defauH unless nonperformance is callSed by an 

occurrence beyond the reasonable control of the Contractor and without its fault or negligence such as, acts of God or 

the public enemy, acts of the Govemment in either its sovereign or contraclllal capacity, fires, floods, epidemics, 

quarantine restrictions, strikes, unustJalty severe 'M'!ather, and delays of common carriers. The Contractorshal notify 

the Contracting Officer il writing as soon as ~ is reasonably possible after the commencement of any excusable 

delay, setting forth the full particulars in connection therewith, shall remedy such occurrence with all reasonable 

dispatch, and shall promptly gr.re written notice to lt1e Contracting Officer of the cessation of such occurrence. 

(g) Invoice. The Contractor shaD submn an original invoke and three copies (or electronic invoice, if authorized,) 

to the address designated in the contract to receive invoices, An invoice must include--

(i) Name and address o(the Contractor, 

(i i) Invoice date and number, 

(iii) Contract number, contract line ~em number and, if applicable, the order number, 

(iv) Description, quantity, unit of measure, un~ price and extended p1ce of the items delivered; 

(v) Shipping number and date of shipment, including the bill of lading number and 'M'!ight of shipment d shipped 

on Govemment bill of lading; 

(vi) Terms of any discount for prompt payment offered; 

(viij Name and address 01 official to wtlom payment is to be sent; 

(viii) Name, Utle, and phone number of person to be notdied in event of defective invoice; and 

(bc:) Taxpayer Ident~ication Number (TIN). The Contractor shall include its TIN only if requi'ed else...mere in this 

contract. 

(x) Electronic funds transfer (EFn banking information 

(A) The Contractor shal include EFT banking inforrnation only if required elsev.f1ere in this contract. 

(B) II EFT tenking information is not requred to be on the ilvoice, in orderforthe invoice to be a proper 

ill\lOice, the Contractor shall have submitted correct EFT banking information in accordance with the app~cab e 

solicitation provision, contract clause (e.g., 52.232-33, Payment by Electronic Funds Transfer--Central Contractor 

Ragistration, or 52, 232-34, Payment by Electronic Funds Transler-.Qtherthan Central Contractor Registration), or 

applicable agency procedures 

(C) EFT banking information is not required if the Govemment waived lIle requirement to pay by EFT 

(2) Ill\IOices will be handled in accordance with the Prompt Payment Act (31 US.C. 3903) and Office of 

Management and Budget (OMB) prompt payment regulations al5 CFR 1315 

(h) Patent indemnity. The Contractor shall indemnify the Government and its officers, employees and agents 

against liaDlity, including costs, for actual or al leged direct or contributory infringement of, or inducement to infringe, 

any United States or foreign patent trademark or copyright arising out o(the performance of this contract provided 

the Contractor is reasonably noMed of such claims and proceedings. 

(i) Payment, (1) Items accepted. Payment shall be made for items accepted by lt1e Government that have been 

delivered to the delivery destinations set forth in lIlis contract. 

(2) Promptpayment, The Government wi ll make payment in accordance with lt1e Prompt Payment Act (31 

U,S,C. 3903) and Office of Management and Budget (OMS) prompt pay regulations at 5 CFR 1315. 

(3) Electronic Funds Transfer (EFT) If the Govemment makes payment by EFT, see 52.212-5(b) for the 

appropriate EFT clause. 

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344 


(4) Discount. In connection with any discount offered for early payment, time shall be computed from the date of 

the invoice. For the purpose of computing the discount earned, payment shal l be considered to have been made on 

the date which appears on the payment check or the specified payment date ~ an electronic funds transfer payment is 

made 

(5) Overpayments. If the Contractor becomes aware of a duplicate contractfmancing or rwo;ce payment or that 

the Government has otherwise overpak! on a contract financing or invoice payment, the Contractor shall-

(i) Remit the overpayment amount to the payment office cited in the contract along with a description of the 

overpayment including the-

(A) Circumstances of the overpayment (e.g., duplicate payment, erroneous paymen~ liquidation errors, 

date(s) 01 overpayment): 

(B) Affected contract number and delivery order number, if applica~e; 

(C) Affected contract line ~em or sub~ne ~e , ~ applica~e; and 

(D) Contractor frint of contact 

(ii) Provide a copy olthe remittance and supporting documentation to the Contracting Officer. 

(6) Interest. 

(i) All amounts that become payable by the Contractorto the Government under this contract Shall bear 

simple interest from the date due until paid unless paid wiI!1in 30 days 01 becoming due. The interest rate shall be the 

interest rate esta~ished by the Secretary of the Treasury as provided in Section 611 of the Contract Disputes Act of 

1978 (Public law 95-563), ...mich is applicable to the period in which the amount becomes due, as provided in (i)(6)(v) 

of this clause, and then at the rate applicable for each six·month period as fixed by the Secretary until the amount is 

paid 

(ii) The Government may issue a demand for payment to the Cootractor u~n finding a debt is due under the 

contract 

(iii) Fila/decisions. The Contracting Officerwill issue a final decision as required by lll1.1~-

(A) The Contracting Officer and the Contractor are unable to reach agreement on the exisleoce or amount 

of a deb! within 30 days; 

(B) The Contractor faits to liquidate a debt p<eviously demanded by the Contracting Officer within the 

time~ne specified in the demand for payment unless the amounts were not repaid because the Contractor has 

requested an inslallme!1t payment agreement or 

(C) The Contractor requests a defermenl of collection on a debt previously demanded by the Cootractin g 

Officer (see 32.607-2). 

(iv) If a demand for payment was previously issued for the debt, the demand for payment included in the final 

decisKln shal identify Ihe same due dale as the original demand for payment. 

(v) Amounts shall be due at the earliest of the following dates 

(A) The date fixed under this contract 

(6) The date olthe first lYritten demand for payment including any demand for payment resutting from a 

defauK termination 

(vi) The interest charge sllall be computed for the actual number of calendar days involved beginning on the 

doo date and ending on--

(A) The date on wI1ich the designated office receives payment from the Contractor; 

(6) The date 01 issuance of a Govemment check to the Contractor from which an amount otherwise 

payable has been withheld as a credit against the contract debt; or 

(C) The date on ...mieh an amount withheld and applied 10 Ihe contract debt would otherwise have become 

payable to the Contractor. 

(vii) The interest charge made under this clause may be reduced under the procedures prescribed ., 32.608-

J. of the Federal Acquis~ion Regulation in effect on the dale olthis contract 

U) Riskof loss. Unless the contract specifically provides otherwise, risk of loss or damage 10 the supplies 

pmvided under this contract shall remain with the Contractor until, and shall pass to the Government u~n 

(1) Delivery of the suppli~ to a carrier, if trans~rtation is I.o.b. origin; or 

(2) Delivery of the supplies to the Government at the destination spec~ied in the contrac~ ~ transportabon is 

I.o.b. destination 

(k) Taxes. The contract price includes all awlicable Federal, State, and kx:al taxes and duties. 

(I) Temlinalkm for fhe Government's convenience. The Government reserves the right to terminate this contract, 

or any part hereof, for s sole convenience. In the event of such termination, the Contractorshal immediately stop all 

woll< hereunder and shal immediately cause any and all of its suppliers and subcontractors to cease work. Subject to 

the terms of this contract, the Contractor shall be paid a percentage of the contract price reflecting the percentage of 

the woll< performed prior to the notice of termination, plis reasonable charges the Contractor can demonstrate to the 

satisfaction of the Government using its standard record keeping system, have resufted from the termination. The 

Contractor shall not be required to comply with the cost accounting standards orcontractcosl principles for this 

purpose. This paragraph does not give the Government any right to audit the Contractors records. The Contractor 

sha~ not be paid lor any woll< performed or costs incurred ...mich reasonabty coukl have been avoided. 

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345 


(m) Terminafion forcause. The Government may terminate this contract, or any part hereof, for cause in tile 

event of any default by the Contractor, or if the Contractorfa~s to comply with any cootract terms and conditions, or 

fails to provide the Government upon request with adequate assurances of future performance. In tile event of 

termination for cause, the Government shatl not be liable to the Contractorfor any amount for suppUes or services fIOt 

accepted, and the Contractor shaD be liable to the Government for any and all rights and remedies .crovided by law. If 

ij is determined that the Govemment improperly terminated tIlis contract for default, such termination shall be deemed 

a termination for convenience. 

(n) Tille. Unless specified elsel'h1ere in tIlis contract, title to items furnished undertllis contract shall pass to the 

Government upon acceptance, regardless of when orwhere tile Govemment takes p,ysical possession 

(0) Warranty. The Contractorwarrants and impnes that tile ~ems delivered hereunder are mercllantable and fil 

for use for the particular purpose described in this contracl 

(p) Limitation of liability. Except as otherwise provided by an express warranty, the Contractorwill not be liable 

to the Government for consequential damages resuHing from any defect or deficiencies in accepted items 

(q) Other compliances. The Contractor shall comply with al appicable Federal. State and local lav.s, executive 

orders, rules and regulations applicable to its performance under this contract. 

(r) Compliance with laws unique to Govemmentcontracfs, The Contractor agrees to comply with 31 U.SC. 1352 

relating to limitations on the use of appropriated funds to influence certain Federal contracts: 18 U.S.C, 431 relating to 

officials not to benem: 40 USC, 3701 et seq" Contract Wolk Hours and Safety Standards Act: 41 USC. 51·58 Anti· 

Kickback Act of 1986: ~ and 10 U,S.C. 2409 relating to whistieblawer protections: 49 U.S,C, 40118 Fly 

American; and 41 U.SC. 423 relating to procurement integrity 

(s) QrJerof precedence. My inconsistencies in this sok:nation or contract shall be resolved by giving 

precedence in the follOl'o1ng order 

(1) The schedule of supplies/servees 

(2) The Assignments, Disputes, Payments, Invoice, Other Compliances, alld Compliance with Lav.s 

Unique to Govemment Contracts paragraphs of this clause 

(3) The dause at52,212·5 

(4) Addenda to this solicitation orcontract, including any license agreements for computer software 

(5) Solicitabon provisions if this is a solicitation. 

(6) Other paragraphs of this clause 

(7) The Standard Form 1449. 

(8) Other documents, exhibits, and attachments 

(9) The spec~icalion 

(t) Central Contractor Registratioo (CCR) 

(1) Unless exempted t1f an addendum to this contract, the Contractor is responsit::le during performance and 

through final payment of any contract forthe accuracy and completeness of the data within the CCR database. alld for 

any liability resutting from the Govemment's reliance on inaccurate orincomplete data. To remain registered in the 

CCR database aflerthe innial registratioo, the Contractor is required to reviewalld update on an annual basis from 

tile date of initial registration or subsequent updates its information in tile CCR database to ensure n is current, 

accurate and complete Updating information in the CCR does not alter the terms and conditions of this contract and 

is not a subst~utefor a propeny executed contractual document. 

(2j(i) If a Contractor has legally changed its business name, "doing business as" name, ordivisioo name 

(l'h1ichever is shown on the contract), or has transferred the assets used i:\ performing tile contract, but has not 

completed the necessary requirements regarding novation and change~·name agreements in FAR Subpart 42.12, 

the Contractor shall provide the resp:!nsible Contracting Officer a minimum of one business day's written not~K:ation 

of its intention to tAl change tile name in the CCR database; (B) comply with the requirements of Subpart 42, 12: and 

(C) agree in writing to the timeline and procedures specihed by the responsible Contracting Officer. The Contractor 

must provide with the notification sulli::ient documentation 10 support the legally changed name 

(ii) If the Contractorfails to compy with the requirements of paragraph (tX2Ki) of this clause, or fails to 

perform the agreement at paragrap, (tX2)(i)(C) of this dause, and. in the absence of a .crope~y executed novation or 

change-<lf-name agreement the CCR information that shows the Contractor to be otherthan the Contractor indicated 

in the contract will be consklered to be incorrect I:1formation within the meaning of the "Suspension of Paymenr 

paragrap, of the electronic funds transfer (EFT) clause oftllis contract 

(3) The Contractor shal not cIlange tile name or address for EFT payments or manual payments, as 

appropriate, in the CCR record to reflect an assignee for the purpose of assignment of claims (see Subpart 32.8, 

Assignment of Claims). Assignees shal be separately registered in the CCR database. lnformabon provided to the 

Contractor's CCR record that indicates payments, including those made by EFT, to an uttimate recipent other than 

that Contractor will be considered to be incorrect information within the meaning of the "SUspension of paymenr 

paragrap, of the EFT dause of this contract 

(4) Offerors and Contractors /My obtain information on registration and annual confirmation requirements via 

CCR accessed through htt,OJ.lAVlfW.acquisifkln.govor by cal~ng P!88-227·2423 or 269·961·5757 

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ADDENDUM TO 52,2124, CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (FEB 2012) 

ELECTRONIC INVOICING AND PAYMENT REQUIREMENTS 

Internet Payment Platform OPP) is a secure web-based electronic invoicing and payment information service available 

to all Federal agencies and their supplier by the U,S. Treasur(s Financial Management Service. IPP allows Federal 

agencies and theirsuppliers to exchange electronic purchase orders, blanket POS, in~ces, and payment nformation 

in one easy to access web portal. This service is Iree 01 charge to government agencies and their suppliers, including 

services and support 

The prelerred method 101 invoicing is IIlrough IPP. The IPP webs~e address is https:lfwMy, ipp,gov, Contractor 

assistance 'Nith enrollment can be obtained by contacting the Bureau of the Public Debfs IPP Team at 304·480·8000, 

OpUon 7 or IPP Production Help desk via email ipooroup@bosJrb,orgorphone(866)973-3131 . 

II the Contractor is unable to utilize IPP lor submitting payment requests, invoices may be submitted electronically to 

lIle e·mail address shown in Bbck 18a, page 1 after completing the IPP Wa'Ner Form and subrrltting ~ via e·maill0 

contractadministration@OO:l.treasgov. Adobe Acrobat Portable Document Format (PDF) and Microsoft Word are 

acceptable lonnats. Invoices shall contain the inlormation required in FAR 52.212·4(g) 

Under this contract, lIle fomo'Ning documents are required to be submitted as an attachment to the invoice 

None applicable 

PAYMENT AND INVOICE QUESTIONS 

For payment and l1voice quesUons, go to https'lfwMy,loogov or contact the Accountirog Services DMsion at (304) 

480-8000 option 7 or via ema~ at AccountsPayable@bpd,tleas,gov 

OVERPAYMENTS 

In accordance with 52.212·4 section (i) 5 Overpayments Accounts Receivable Conversion of Check Payments to 

EFT II the Contractor sends the Government a check 10 remedy duplicate contra ct financing or an overpayment by 

lIle government ij 'Nill be converted into an electronic funds transfer (EFT). This means the Government 'Nil l copy the 

check and use the account inlormation on ~ to electronically debt the Contracto(s account fOI the amount of the 

check. The deMlrom lIle Contractor's account 'Ni l usually occur within 24 hours and 'Ni ll be shown on the regular 

account statement 

The Contractor'Nili not rece'Ne the original check tack. The Government shall destroy the Co trac to s original check, 

but 'Nill keep a copy of it II the EFT cannot be processed lor technical reasons, the Contractor authorizes the 

Government to process the copy in place of the onginal check 

MARKING OF SHIPMENTS 

The Contractor shall ensure the contract number and delivery order number is clearly visible on al shippingfservice 

documents, containers, and invoices 

1052.201·70 CONTRACTING OFFICER'S REPRESENTATIVE (COR) APPOINTMENT AND AUTHORITY (JUN 

2012) 

(a) The COR is identified in the SF 1449, Bbck 20 

(b) Performance 01 war\( under this contract is subject to the technical direction of the COR identified above, 

or a representat'Ne designated in writin g. The tenn 'technical direction" ilcludes, without lim~ at ion , direction to the 

contractor that directs or redirects the labor ellort, shifts the war\( between war\( areas or k>caUons, and'orlins in 

details and otherwise serves to ensure that tasks outlined in the war\( sta tement are accompished sa tisfactorily 

(c) Technical direction must be within the scope of the contractspecification(s)/work statement The COR 

does not have authority to issue technical direction that 

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(1) Gonstftutes a change of assignment or additional work outside the contract specilication(s}lwork 

statement 

(2) Gonst~utes a change as defined in the clause enMed Changes~ 

(3) In any manner causes an increase or decrease in the conlract price, orilla time required for contract 

performance; 

(4) Changes any ol\!le terms, conditions, or speciflCation(s}lwork statement of the contract; 

(5) Interferes with tM contracto(s right to perform under the terms and conditions of the contract or 

(6) Directs, supervises or otherwise controls the actions of the contracto(s employees 

(d) Technical direction may be omlor in writing. The COR must confirm oral direction in writing within five 

workdays, wi\!l a copy to the Contracting Officer 

(e) The Contractor sha. proceed prompUywith performance resuHing from the lecllnical direction issued by 

the COR. If, in the opinion olthe contractor, any direction of the COR or the designated representative falls within the 

limitations of (c) above,the conlractor shall immediately notify the Contracting Officer no later than the beginning 01 

the next Govemmentwork day 

(I) Failure of the Contractor and the Conlracting Officerto agree that technical direction is within tIle scope of 

the contract shall be subject to Ihe terms of the clause ent~led ·Oisputes.' 

1052.210-70 CONTRACTOR PUBLICITY (AUG 2011) 

The Contractor, or any entity or representative acting on behaJ of the Contractor, shall not refer to Ihe equipment or 

services fumished pursuant to the provisions of this contract in any ne'IYS release or commertial advertising, or in 

connection with any news release or commercial advertising, without first ottaining eJ(pIicit written consent 10 do so 

from tIle Contracting OffICer, Should any reference to such equipment or services appear in any news release or 

commercial advertising issued by or on behalf of the Contraclorwithout the required consent,the Government shall 

consider institution of all remedies available under applicable law, including 31 U,S,C. 333, and this contract, Further, 

any Wllation of this provision may be considered during the evaluaUon of past perlormance in future compeUtively 

negotiated acquisitions. 

52.217~ OPTION TO EXTEND SERVICE (NOV 1999) 

The Govemment may require continU€d performance of any services within the imits and at the rates specified in the 

contract These rates may be adjUsted only as a resuft of revisions to prevailing labor rates PfcMded by the Secretary 

of labor. The option provision may be exercised IOOre \!lan once, but the total extension of performance hereunder 

shaft not exceed 6 months. The Contracting Officer may exercise the option by written notice to the Contractor within 

30 calendar days before the contract expiration date 

52.217-9 OPTION TO EXTEND THE TERM OF THE CONTRACT {MAR 2000) 

(a) The Government may extend the term of this contract by written notice to tIle Contractorwi\!lin the final 

30 calendar days of each contract period; Pfovided that the Government gives the Contractor a preliminary written 

notice of its intent to extend at least 30 calendar days before the contract expres The preliminary notice does not 

comm~ the Government to an extension. 

(b) lIthe Governmentexercises this o~ion, the eJ(tendedcontract shall be considered to include this option 

clause 

(c) The total duration of this contract, including the exercise 01 any options under this clause, shall nol 

exceed five (5) years. 

CONTRACT TERM 

The period 01 performance is a 12'lOOnth base period and foor (4) t2'lOOnth OIXiOn periods. 

PAST PERFORMANCE EVALUATION 

This contract is subject to a performance evaluation via The Contractor Performance Reporting System (CPARS) at 

WHN.cpars,csd,disa,mil, Following the end 01 each contract period and at contract completon, a completed 

Government evaluation shall be forwarded to tIle Contractor. The Contractor may submit written comments, ~ any, 

within the time period specified in the evaluation lransmiUal The Contractor's comments shall be considered in the 

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348 


issuance of the final evaluation document Any disagreement between the parties regarding the evaluation shall be 

forwarded 10 Ihe Bureau Chief Procurement Officer (SCPO) The final evaluation of the Conlractor's pertormance is 

the deciskln 01 the SCPO. A copy of the final pertonnance evalualion report will be senl lo the Contractor and 10 Ihe 

Govemment"s past pertormance database atVNNIppirs.gov 

52.212-5 CONTRACT TERMS AND CONDITIONS REQUIRED TO IMPLEMENT STATUTES OR 

EXECUTIVE ORDERS - COMMERCLAL ITEMS (APR 2012) 

(a) The Contractor shall complyw~h the folkJ,ving Federal Acquisition Regulation (FAR) ctauses, ...mieh are 

incorporated in this contract by reference, to implemenl provisions of law or Executrve orders applicable 10 

acquis~io s of commercial ~ems 

(1) 5?n2-5O, Combating TraffiCking in Persons (Feb 2009) m U.S.C. 7104(gl) 

_ AlterMte I (Aug 2(07) of 52.222-50 (22 U.S C. 71041ql). 

(2) 52.233-3 Protest After Award (AuG 1996) (31 U.S.C. 3553), 

(3) 52.233-4 Applicable Lawlor Breach of Contract Claim (OcT 2004) (Pub L. 108-77. 108-78) 

(b) The Contractor shall colTJjlly with the FAA clauses in this paragraph (b) that the Contracting Off(:er has 

indicated as being incorporated in this contract by relerence to implement provisions ollawor Executive orders 

applicable to acquisitions of commercial ~ems: 

]_ (1) 52.203-6, Restrictions on Sulx:ontractor Sales to the Government (Sept 2(06), with Alternate I 

(Oct 1995) (41 U.S.C. 2530 and 10 US.C. 24021. 

_ (2) ~ Contractor Code ol8usifl€ss Ethics and Conduct (Apr 2(10) (Pub. L. 110-252, Title VI, 

Chapter 1 (41 U.S.C. 251 note)) 

_ (3) ~ Whisfle!)OY/ef Protections under the American Recovery and Reinvestment Act 01 2009 

(June 2010) (Section 1553 of PUb. l. 111-5). (Applies to contracts funded by the American Recovery and 

Reinvestment Act of 2009.) 

]_ (4) 52.204-10, Reporting Executrve Compensation and First-Tier Sulx:ontract Awards (FEB 2012) (Pub 

L. 109-282) (31 U.S.C. 6101 note) 

_ (5) 52.204-11 American Recovery and Reinvestment Act-Reporting Requirements (JuI2010) (Pub. l. 

111-5). 

]_ (6) 52.209-6 Protecting the Government's Interest When Subcontracting with Contractors Debarred, 

Suspended, or Proposed for Debarment (Dec 2010) (31 USC 6101 note) 

]_ (7) 52.209-9, Updates 01 Publicly Available InfOfmaton Regarding Responsibility Matters (FEB 2012) (41 

US C. 2313). 

_ (8) 52.209-10, Prohibition on ContractinglYith Inverted Domestic Corporations (section 740 of Division C 

of Pub. l. 111-117, section 743 of Oivision D 01 Pub.l 111-8, and section 745 of Division 0 of Pub. l 110-161). 

(9) 52.219·3, Notice 01 HUBZone Set-Aside or Sole-Source Award (NOV 2011) (15 U.S.C. 657a) = (IO) 52.219-4, Notice of Price Evaluation Preference IOf HUBZone Small Business Concerns (JAN 2011) 

(~the ofIerorelecls to waive the preference, ~ shall so indicate i'l its offer) (15 USC 657a) 

_ (11) (Reserved] 

_ (12)(i) 52.219.0, Notice of Total Small Business Set-Aside (NOV 2011) (15 U.S.C. 644). 

_ Oi) Mema!e I (NOV 2011) 

_ Qii) A~emate II (NOV 2011). 

_ (13)(i) 52.219-7, Notice of Partial Small Business Set-Aside (June 2003) (15 USC 644) 

_ Oi)Memate I (Oct 1995) 0152.219-7. 

_ Qii) A~emate II (Mar 2004) of 52.219-7 

]_ (14) 52.219-8, Utilization of Small Business Concerns ( (3)) 

_ (15)(i) 52.219-9, Small Business Subcontracting Plan ( 

_ (ii) Anemale I (Oct 20(1) of52.219-9. 

_ (iii) Altemate II (OcI200l) of 52.219-9 

(iv) Allernafe //I (JuI2010) of 52.219·9 

- _ (16) 52.219-13, Notice of Set-Aside a/Orders (NOV 2011)(15 U.S.C. 644(r)) 

_ (17) 52.219-14, limitations on Subcontracting (NOV 2011) (15 U.S.C. 637(a)(14)) 

_ (18) 52.219-16,liquidated Damages-Subcontracti'lg Plan (JAN 1999) (15 U.S.C. 637(d)(4XFXi)) 

_ (19Xi) 52.219-23, Notice of Price Evaluation Adjustment for Small Oisadvantaged Business Concerns 

(OCT 2008) (10 U.S.C. 2323) (d the offeror elects to warve the adjuslrl1ent, ~ sI1al so indicate in its offer). 

_ Qi) Memate I (JUNE 2(03) of 52.219-23. 

_ (20) 52.21lJ-25, Smal Disadlrantaged Business Participation Program-Disadvantaged Status and 

Reporting 

(DEC 2010) (Pub. L. 103-355, section 7102, and 10 USC. 2323) 

(21) 52.219-26, Smal Disadlrantaged Business Participation Program-lrlCenlive Subcontracting (OCT 

2000) (PUb. L 103-355, section 7102, and 10 USC. 2323) 

Page ( 10 
349 


_ (22) 52.219-27, Notice of Service-Oisabled Veleran-Owned Small Business Set-Aside (NOV 201 1) (15 

USC.657(f) 

]_ (23) 52,219-28, 52.219-28, PostAward Small Business Program Rerepresentation (APR 2012) (15 

USC.632(aX2)) 

_ (24) 52.219-29, Notice of Set-Aside for Economically DisadvantagedWomen-O.vned Small Business 

(EOWOSB) Concerns (APR 2(12) (15 U.S.C. 637(m)). 

_ (25) 52.219-30, Notice of Set-Aside forWomen-ONned Small8'Jsiness ('WOSB) Concerns Eligible Under 

tile WOSB Program (APR 2012) (15 USC. 637(m)) 

_X_ (26) 52.222-3, Convict labor (JUNE 2003) (E.O. 11755). 

]_ (27) 52222·19, Child labor-Cooperation.,.,;th Authorities and Remedies (MAR 2012) (E.O 13126) 

] _ (28) 52.222-21 , ProhiMion of Segregated Facil ities (FEB 1999). 

]_ (29) 52,222·26, Equal Opportunrty (MAR 2007) (EO. 11246) 

X (30) 52.222-35, Equal OpportunrtyforVeterans (SEP 2010)(38 U,S.C 4212) 

=X= (31) 52,222-36, Affirmative Action for Workers with Disabilrties (OCT 2(10) (29 U,S,C. 793) 

X (32) 52,222-37, Employment Reports on Veterans (SEP 2010) (38 US,C, 4212). 

=X= (33) 52222-40, Notification of Employee Rights Under the National labor Relations Act (DEC 2010) 

(EO 13496) 

_ (34) 52.222-54, Employment EligiDlity Verification (JAN 2(09). (Executive Order 12989). (Not applicable 

to the acquis~ion of commerciany available off-{he-she! items or certain other types of commercial items as 

prescribed in 22,1803,) 

_ (35)(i) 52.223-9, Estimate of Percentage of Recovered Material Content for EPA-Designated Items 

(MAY 2008) (42 US.C 6962(c)(3)(AXii)) (Not applicable to the acqu~ tion of commercially available off th sh ~ 

ijems,) 

_ (ii) AHem ale I (MAY 2(08) of 52.223--9 (42 US.C. 6962(i)(2){C)). (Not applicable 10 Ihe acquis~ion of 

commercially available off-tile-shelf items.) 

_ (36) 52.223--15, Energy Efficiency in Energy-Consuming Products (DEC 2(07) (42 U.SC. 8259b) 

_ (37)(i) 52.223-16, IEEE 1680 Standard for the Environmental Assessmentof Personal ComJllller Products 

(DEC 2(07) (E.O. 13423). 

_ (ii) AHem ale I (DEC 2007) of 52.223--16. 

_X_ (38) 52.223-18, Encouraging Contractor Policies to Ban Text Messaging While Oriving (AUG 2(11) (E.O. 

13513) 

_ (39) 52.225-1 , Buy American Act-8upplies (FEB 2(09) (41 U.S.C, 10a-IOd). 

_ (40)(i) 52.225-3, Buy American Act-free Trade Agreements-lsraeli Trade Act (MAR 2(12) (4t US.C 

chapter83, 19 U.S.C 3301 nole, 19 U,S,C 2112 nole, 19 U.S.C 3805 note, 19 U.S.C 4001 nole, PUb. L 103--182, 

Pub. L 108-77, t08-78, 108-286, t08-302, 109-53, t09-169, 109-283, 110-138, and Pub, l 112-41) 

(ii) Afternale I (MAR 2012) of 52.225-3 = (iii) Alternate II (MAR 2012) of 52.225-3. 

(rv) AHem ale III (MAR 2012) of 52.225-3 = (41) 52.225-5, Trade Agreements (MAR 2(12) (19 U,S.C. 2501 , et seq" 19 US.C, 3301 note). 

]_ (42) 52.225-t3, RestrttioflS on Certain Foreign Purchases (JUNE 2(08) (E,O, 's, proclamations, and 

statutes adml:listered by the Office of Foreign Assets Control of the Department oltlle Treasury). 

_ (43) 52.226-4, Notice of Disaster or Emergency Area Set-Aside (NOV 2007) (42 U,S.C. 5150) 

_ (44) 52.226·5, Restricbons on Subcontracting Outside Disasler or Emergency Area (NOV 2(07) (42 

U,S,C. 5150). 

_ (45) 52.232-29, Terms for Financl:lg of Purchases of Commercial Items (FEB 2(02) (41 USC 255(1), 

10 U.S.C, 2307(f)) 

_ (46) 52.232-30, Installment Payments for Commercial Items (OCT 1995) (41 U.S.C. 255(f), 10 USC 

2307(f)) 

J_ (47) 52.232-33, Payment by Electronic Funds Transfer-Central Contractor Registration (OCT 2003) 

(31 U.Sc. 3332) 

_ (48) 52.232-34, Payment by Electronic Funds Transfer-Otherthan Central Contractor Registration 

(MAY 1999) (31 US.C 3332) 

_ (49) 52.232-36, Payment by Third Party (FEB 2010) (31 U.S.C. 3332) 

_ (50) 52.239-1 , Privacy or Security Safeguards (AUG 1996) (5 U,S,C, 552a). 

_ (51)(i) 52 247~4, Preference for Privately OWned 

_ (ii) Altemate I (Apr 2003) of 52.247-64 

(c) The Contractorshall comply with the FAR clauses in this paragraph (c), applicable to commercial 

services, that \I1e Contracting Officer has indicated as being incorporated in th ~ contract by reference to implement 

provisions of lawor Executive orders applicable to acquisitions of commercial ~ems 

_ (1) 52,222-41 , Service Contracl Act of 1965, (Nov 2(07) (4 1 US.C, 351, el seq.). 

Page I It 
350 


_ (2) 52.222-42, Statement of Equivalent Rates for Federal Hires (May 1989) (29 U.S.C 206 and 

41 U.SC 351, at seq.) 

_ (3) 52 222-43, Fair labor Slandards Act and Service Contract Act-Plice Adjustmenl (Multiple Year and 

Option Contracts) (Sap 2009) (29 USC. 206 and 41 USC 351 at seq.) 

_ (4) 52.222-44, Fa~ labor Standards Act and Service ContractAct-PMce AdjllSlmenl (Sep 2009) 

129 U,S.C, 200 and 41 U,S.C, 351 et seq.) 

_ (5) ~ Exemption from Appijcabon of tMe SelVice Contract Act to Contracts for Maintenance, 

Calibration, or Repair of Certain Equipment-Requirements (Nov 2007) (41 USC. 351 et seq.) 

_ (6) 52.222-53, Exemption from Application of the SelVice Contract Act to Contracts for Certal'1 Ser'licesRequirements (Feb 2009) (41 U.S.Q. 351 e/ seq,) 

_ (7) 52.226-€ Prorrotng Excess Food Donation to NonprofitOrganizations (Mar2009) (Pub. l. t 10-247) 

_ (8) 52,237-1 1 Accepting and Dispensing of $t Coin (Sept 2008) (31 U,S,C. 5t 12Ip){t)) 

(d) ComplrolJerGeneral Examinalt)n of Rerord. The Contractor shall comply with the provisions of this 

paragraph (d) n this contract was awarded using other than sealed bid, is in excess of the simplified acquisition 

threshold, and ooes not contain the clause at 52.215-2, Audit and Records-Negotation. 

(1) The ComptroOerGeneral of the United States, or an authorized representative of the ComptroOer General, 

sha~ have access to and right to examine any of the Contractor's directly pertinent records invoMIl9 transactions 

related to this contract 

(2) The Contractor shall make available at its offices at all reasonable times the records, materials, and other 

evidence for examination, audit, or reproduction, unt~ 3 years after final payment under this contract orfor any shorter 

period specified in FAR Subpart 4.7, Contractor Records Retention, of the other clauses of this contract. If this 

contract is completely or partially terminated, the records relating to the mrk terminated shall be made available for 

3 years after any resulting final termination settlement Records relating to appeals under tMe disputes clause or to 

litigation or the settlement of claims arising under or relating to this contract shall be made available until such 

appeals, litigation, or claims are finally resolved 

(3) As used in this clause, records include books, documents, accounting procedures and practices, and 

other data, regardless oftype and regardless of form. This does not require the Contractorto create or maintain any 

record that the Contractor does not maintain in ttle ordinary course of business or pursuant to a jXOVision of law. 

(e)(I) Notwithstanding the requi'ements of tMe clauses in paragraphs (a), (b), (c), and (d) of this clause, the 

Contractor is not required to flow dClMl any FAA clause, other than those in paragraphs (e)(I)(i) through (xi) of this 

paragraph in a subcontract for commercial ~ems. Unless otherwise indicated below, the extent of the now OOwt1 shal 

be as required by the clauseW)52.203-13, Contractor Code of 8usiness Eth(:s and Conduct (Apr 2010) (Pub. l. 110-252, Title VI, 

Chapter 1 (41lJ.SC.251 note)). 

(ii) 52.2t9-8 utilization of SmaD 8usiness Concerns (Dec 2010) (15 U.S.Q. S371d)(21 and (3)), in all 

subcontracts that offer further subcontracting opportunities. lIthe subcontract (except subcontracts to smal rosiness 

concems) exceeds $650,000 ($1 .5 million fo r construction of any public facility), the subcontractor must include 

52.219-8 in lower tier subcontracts thatoffet subcontracting opportunities 

(iii) [Reserved) 

(iv) 52.222-26 Equal Opportunity (Mar 2007) (E.O. 11246). 

(v) 52.222-35, Equal Opportunity lor Veterans (Sep 2010) (38 U.S,C, 4212), 

(vi) 52.222-36 Affirmative Actkln for Workers with Disabnmes (Oct 2010) (29 U.S.C. 793). 

(vii) 52.222-40 Notification of Employee Rights Under the Nationallalxlr Relatons Act (Dec 2010) (E.O. 

13496). Flow down required in accordance with paragraph (f) 01 FAA clause 52.222-40 

(vii) 52.222-41 Service ContractAct of 1965 (Nov2007) (41 USC. 351 el seq.) 

fix) 52.222-50, Combating Trafficking in Persons (Feb 2009) (22 U.SC. 7104(9)) 

_AHernate I (Aug 2007) of 52.222-50 (22 USC. 71041gl). 

(x) 52.222-51, Exemption from Appication of the Ser'lice ContractAct to Contracts lor Maintenance, 

calibration, or Repair of Certain Equipment-Requirements (Nov 2007) (41 U.S.C 351 et seq) 

(xi) , Exemf:(ion from Appication of the Ser'lice Contract Act to Contracts for Certain Ser'licesRequirements (Feb 2009) (41 US.C 351 et seq.) 

(xii) 52.222-54, Employment EligiD ~y Verif(:ation (JAN 2009) 

(xiii) 52.226-€ Promoting Excess Food Donation to Nonpro ~Organizatio s (Mar 2009) (Pub. l. 110-247) 

FlowdClMl required in accordance with paragraph (e) of FAA clause 52.226-6. 

(xiv) 52.247-{'4 Preference for Privately Owned U,S,-Flag Commercial Vessels (Feb 2006) (46 U.S,C. 

Appx. 124 t(b) and 10 U.S.C. 2S31)' Flow down required in accordance with paragraj:t (d) of FAR 

clause~ 

(2)While not required, the contractor may include in its subcontracts lor commercial items a minimal number 

of additional clauses necessary to sabsfy IS contractual obligations 

Page) 12 
351 


CONTRACT DOCUMENTS, EXHIBITS, AND ATTACHMENTS 

DOCUMENTlEXHIBITI ATTACHMENT TITLE 

License Agreement 

Technical Requirements 

Page I t3 
352 


MASHR LIc[NSE AGR£WENT 

This Master License Agreement is entered irto between CoreLogic Sohtions, LLC, a California limited liability company 

('-core Logic'), and The Bureau of the Public Debt rBPD"), on behalf of the Consumer Finaoce PrCl:ection Bureau("CFPB" 

and with BDP, '-cltltomerl (collectil'ely, the "Parties; or indil'idually, a "Pan;"). This Master License Agreement is 

efTectil'e upon the date of laS! sigmture CEfTectivc Date') 

For good and I'aluable consideration, the receipt and adequacy of which art hereby acknowledged, the Panies agree as 

follows: 

I. Definitions 

Unless the oonteXi of a proI'ision herein otherwise requires, words importing the singular slIIU include the plural and I'ice· 

\'e1'3a, The words -inc we,~ "inclllles" or "incl~" shall mean inclllle \I;tOOUllimitation, includes without limitation or 

inclOOing without limitation, As \tied in this Agreement (as dermed below), the following terms have particular meanings as 

defmed below, 

1.1 ~Agrefmfnt" means this IIlaster License Agreement, together with all related statements of work (each a "SO\V"'), 

exhibits, ordersand amendmentsL2 ~ConfKlfnti31 Information" means (i) information disclosed by a Party rel:Jling to the Services (as defined below), 

product development strategy aoo activity, marketi~ strategy, corporate assessments aoo strategic plans, either present or 

futae; pricing, firraneial and statistical information, accounting information, identity of and inform:Jlion regardi~ the Parties 

to this Agreement, suppliers, employees, im'estOiS, or customers; software, SOO"ce code, >":I'stems, processes, designs, 

schematics, methods, techniques, algorithms, formulac, inventions, diSCOHries, policies, guidelines, procedures, practices, 

disputes or litigation; (ii) other confKlel1ial, proprietary ortrade secret inform:Jlion disclosed by that Party that is idenlified in 

writing as such at the time of its disclosure; (iii) other confidential proprietary or trade seaet information disclosed by that 

Party; (iv) information relating to that Part~'s employees, contractors or customers, such as social security number 

,'erifiC3tion which, if released, weuld cause an unlawful or actienable im'asion of privacy; (\') the terms of this Agreement; 

and (I'i) any compilation or summary of inform:Jlion or data that is itself confidenlial 

1J ~£nd US(' ~ m~ans, if sp.-cifically authori~d in the Permitted Applications of a particular SOW, an iOOil'idual or 

entity determined b)' Customer to haI'e a lrgitimate business need to use the Services or Customer'S products that incorporate 

or rely on the Services. End Users shall only access the Services or Customer's products on a restricted basis, as authorized 

in the SOW, using an assigned password or other SOOJrity mechanism to ~vent umuthoriud access. 

1,4 ~PermiUed Affiliatf" means, if specifiC3lly authorized in the Permitted Application'; of a particular SOW, an entity 

identifIed in the Permitted Applications of a particular SOW as authorized to access the Services. 

1.5 ~Permitttd Applications" means the aul00..ized use of the Services set fonh in the a[lllicable SOW 

1.6 ~Permitted Proussor" means, if ~cifically autOOrized in the Permitted Applicationsof a particular SOW, an entity 

independent of Customer that processes data on behalf of Customer aoo that 1m been approved in adl'an;;e in writing by 

CoreLogic to prol'ide processing services using the Services set forth in sIK:h SOW. 

1.7 ~Permitttd Users" means, if applicable, End Users, Permilled Aff~iates, and Permilled Processors collectil"ely. 

1.8 ~Sel"l' ices " means the software applications, models, ana ~1ic:s, data, reports, scores, images and any applicable user 

manwls and any cther sm'ices rrovided by CoreLogic to Customer as ~cified in each SOW. The Services include any 

oomctions, bug fL>:eS, enhancements, updates or other modifIcations to the Services 

2. Agreement Structure 

This Agreemel1 contains terms and ooooitioru appliC3ble to all SOWs When fully executed by authorized signatoriesefthe 

Parties, each SOW sets forth the specific Services, delivery metOOds, fees, Permitted AppliC3tions and any ether terms 

appliC3ble tothe ~cific Services provided under such SOW aoo attaches to this Agreement 

Paget of8 COl->'FlDEt-'TIAL 
353 


11 Ucrnst Grant. Subject to the terms and conditions of this Agreemen~ CoreLogic grants to Customer a oonexclusil-e, non-uWlSferable, limited license to use the Services set forth in each '!I)W solely for the Permitted Applications 

for each of the Sen'ices. There are no implied licenses Wlder this Agreement, Wld any rights not expressly granted to 

Customer are reserwd by Core Logic for its own use and benefit 

12 Ucrnst Restric lions. Customer represeltS and warmnts to CoreLogic that it shall comply, Wld ensure thai its 

Permitted Users comply, with the following: 

(a) Custom~r shall oot use the St"'ices for purposes other than the Permitted Applications and shall ensure 

compliance w~h such terms by its Permitu:d U5eJS, if applicable 

(b) Unless expressly authorized in the Permitted Applications: (i) with the exception of Permitted U5eJS, Customer 

shaU not share the StIVices with any parent, subsidiary, affiliate or oIher third party, irw::hxling any third parties involved in 

any joint Hnture or joint marketing arrangements with Customer; and (iiij Cll';tomer shall nOl use or store the SeIVices 

outside the United States 

(e) Unless expressly aulloized in the Permitted Applications, Customer shall not: (D disclose, use, dissemina\1:, 

reproduce or publish any portion of the S¢Jvices in any manner or permit the same; (ii) comingle, process or combine any 

portion of the Services or permit any portion of the Services to be comingled, processed or combined \I;th OIher data or 

software from any OIll!:r source; (iii) allow acx:ess to the Sen'ices through any terminals located ootside of Cll';tomer"s 

operations or facil~ es; (iv) use the Services to create, emarw::e or structure any dataoose for resale or distribtdion; (v) 

redistrib\1e the Sen'ices or Customer"S products O'ICr the Internet; or (vi) use the Services to mate models, anal}1ics, 

derr.,atin products or other derivative works. 

(d) Notwithstanding anything to the contrary, the Parties un:lerstand and agree that the information provided by the 

federal Goverrunent in response to a consumer's request on til!: IRS Form 4~T, the Social Stcurity Administration form 

SSA-89 or any similar Government request form constitutes ''transaction and experience information" as described in Section 

603(dX2XA)(i) of the Fair Cn:dit Reporting Act, 15 USC. § 1681 et seq. (the MFCRAj, and oot consumer report 

information as defined in FCRA Section 6OJ(d). Moreover, the Parties mderstand and agree that, when CcreLogic provides 

Services to Customer by delivering the information obtained from the federal Government pursuant to such forms, CoreLogic 

acts only as a oonduit bo!tween the federal Governmert and ClNomer with respect to such information and that CoreLogic 

does not assemble or evalwte stK:h information for the pwpose of providing the information to Customer or to any other third 

party, Customer shall not use the &rvices: (i) as a factor in establishing an iOOividml's eligibility for credi~ insurWlce, or 

emplo}ment; (ii) in connection with a determination of an indil'iduars eligibility for a license or other benefit grnnted by a 

gOI'emmental authority; (iiD in connection with lDlderwriting individml insuraoce; or (iv) in any way that would cause the 

&rvices to constitute a ~consWl1er report" lDlder the FCRA or similar Ule, or by any other autlx>r~y having jurisdiction 

over the Parties, 

(e) Customer shall not use the Services in Wly way that: (i) infringes CoreLogic's or any third party's copyright, 

patenl, trademark, trade secret or other intellectual property or rrlllrietary rights or rights of plblicity or privacy; (ii) violates 

any law, statute, ordinaoce orregulation; or (iii) is defamatory, trade libelous, mJa\\fully threatening or unlawfully harassing, 

If the Permitted Applications include direct marketing use, Customer shall comply with any applicable non-solicitation laws 

and regulatiOllS. 

(0 Customer shan (i) obtain any necessary licenses, certificates, permits, approvals or other aUiOOrizations 

required by federal, state or local statute, law or regulation applicable to Customer's use of the Sen'ices; and (ii) only allow 

authJrized End Users to access the SeIVices. Customer shall maintain the confidentiality of any usemames and passwords 

issued by CoreLogic and Customer shall not permit =names or passwords to be shared amongst its employees. CoreLogic 

may prohibit COOCIlITt11l sessions with the same username and password 

(g) Customer shall nOl disassemble, decompile, manipulate or rmrse engineer CoreLogic's Confidential 

Informatiooor any portion of the Services. Cuslomer shall take all necessary steps to prel'ent IUlaUthoriZed use or disclosure 

or disassembly, decompiling, manipulation (I meNe engineering of Core Logic's Confidertial Information or Wly portion of 

the Services. 

(11) All prodoct names set forth in the SOWs are registered or common law trademarks or smice marks 

(coHectil'ely "Trademarks") of CoreLogic or its affiliates or data providers and no right (I liceme to use the Trademarks is 

COl>'FlDEt-'TIAL 
354 


granted WIder this Agreement. Except as may be authorized in prior IITiting by CoreLogic, Customer shall not use the 

Trademarks in any ool'ertising or promotioml material nor shall Customer disclose Cor~Logic as a data Xl\lce to any third 

party, except that such. disclosures may be made as required by federal, state or local goI'emmeJ1 

regulations. Notwith.standir.@theal)(we,unlessexpresslyauthcrizedinanapplicableSOW,Customershllloot remove, alter 

or obscure any Trademarks or proprietaJy notices cootained in tile Services or other materials prm'ided by CoreLogic, and 10 

the extent any Trndemarb appear in tile Services, Cllitomer shill have a limited license to use such Trademwks in 

acoordaoce \\;tII the terms and conditions of th.is Agreement and solely as they appear in tile Services. 

, Oeher.' ofDnta and Fonnal 

Customer acknowledges that tile anilability of data elements in the Services yaries substantially from area·lO{lrea, aoo 

circumstances may exist or arise which ~event CoreLogic from providing such data or achiel'ing complete repres.:ntaliCfl of 

all data elements in tho: Services. Notwithstanding anythi~ to the contrary, CoreLogjc may limit or discontinue tile provision 

of the Services for geographic locations where (i) CoreLogic is restricted by rules, regulations, laws or gOl'emmental entities; 

(ii) CoreLogic has Ifu:ontinued the collection of data; or (iii) CoreLogic is prohibited by third party providers. CoreLogic 

and Customer shall renegotiate the Fees (as &fined below) in good faith according to the prevailing pricing models if 

CoreLogic matelially modifies the content or growaphic cO\'erage of the Services pr(Wided to Customer. Customer 

acknowledges and acceptS Con:Logic's use of offsrore or onshtte subcontractors to provide the Services. CoreLogjc may 

discontinuo::, upgrade or clIange the produ;;tion, support, &lil'el}' and maintenance of any Sen'ices ifCoreLogic develops an 

upgraded version or OIherwise can no longer PflWi<!e such Services 

5.~ 

5.1 Feu. Customer shall pay CoreLogic the fees sc:t forth in each SOW ("Fees"') in accordance with the Prompt Pay 

Act At the end of each CoreLogic billing cycle, CoreLogic may invoice Customer for all Fees iocurred by Customtl during 

s~h billi~ cyck: 

5,2 ~xes, Fees are exclusin of sales, use, ad I'alorem, persomJ propffiy, and other taxes, which are the responsibility 

of Customer. CoreLogic shall charge Customer applicabk: sales tax; prol'Kled, howmr, trot Customer may provide 

CoreLogic witll a resak: or exemption certificate in order to ooIify CoreLogic how to appropriately inl'oice Customer for any 

applicablela"(eS, Cu&omer shall me all other ta,!(e5. 

6, Reoor1ingj Audits [Intentiomllyomitted.] 

7. ~rm' rminalion 

7.1 Term ~nd Termination. The term of this /l-iaster LiceJ"6e Agreement commences on the Effectil'e Dolte ard 

continues until all SOWs are terminated. The term of each SOW is as specified in each S\K!h. SOW 

7.2 meets of Trrminalion. Upon termination of this Agreement or a SOW, allliceJ"6e rights granted by CoreLogic to 

Customer pursuant to tile Agreement or such. SOW terminate and Customer shall pay CoreLogic in full for all Services 

accessed or delil'ered 

7J Rfllirn or IHstruction of ~btn ial s. Within 15 days of termination of this Agreemenl or a SOW by either Party, 

wtless otherwise provided in a SOW and if requo::sted by CoreLogic, Customer shall: (i) return all Services and CoreLogic's 

Confidential Information (including all copies of tile same) (the "Materials"") to CoreLogic at the address set forth on the 

signatW'e page of this AgreemeJ1 or as specified by CoreLogic and cenify by an officer of Customer trot Customer 1m 

retwned all Materials; or (iD destroy alllluterials and certify by an officer of Customer trot such Materials hal'e been 

destroyed. If such Materials ate not returned or destroyed in accordance with the above, Customer shall proI'ide CoreLogic 

or its designee access to Customer's premises for the retriel'Sl of all such Materials, and Customer shall pay the actual costs 

as reawnably incWTed by CoreLogic to retriel'e such Materials. Customer shall contirwe paying CoreLogic fees ordinarily 

and reasonably charged by CoreLogic for the Services after the termination of this Agreement. Wltil such. time as Customer 

relllm'; to Con:Logic or destroys such. IIhterials 

8, Third Part" Ust 

Customer warrants that its Permined Users' use of the Services shall be in compliance with this Agreement and Customer 

shall be liable for any use of the Services by its I'.!rmitted Users. Customer shall not pr01lide or cause to be proI'ided the 

Sen'ices to a processor. unless it is exrx-essly al.fhorized in the Permitted Applicalions of a SOW or otherwise authorized in 

hgeJofS COl-.'FlDEt-'TtAL 
355 


writing in advance by CoreLogic and th: processor enters into an agreement agreeing to be bowld by th: tenns of this 

Agreemenl and th: applicable SOW, naming CoreLogic as an express third ~l1y bereficiary and ackoowledging that the 

processor shall only use th: So!l\'ices to fulfill its processing obligation to Customer. 

9, Co nfilitnti alitl' 

9,1. Obligatio ns. Neither Party shall use, disseminate, reproduu orpo!rmit to be used, disseminated or reproductd, or in 

any way disclcu the other Party's Confidential Information to any person or entity except as required by law or as 

specifically po!rmitted in this Agreement Abselll prior written COI\'leIU of the other Pany, each Party shall disclose 

Confidential Information only to those of its employees and independ~nt cootractOiS who hal'e p-tviously agreed to be: bouOO 

by the terms aoo coooitionsofthis AgreemelU and its in-house and outside legal counsel who need to know slk:h information 

Each Party shlll treat all Confid~n ia l Information disclosed to it in connection lIith this Agreement as strictly confidential 

using commercially reasonable measures at least «Iual to those USl:d by su::h Party with respeer to its own Confidential 

Information 

9.2 pt io s. The restrictions on use aM disclosure of Confidential Information sct forth in Seaion 9.1 shlll not 

apply to any particular Confidential Information when and to the extent that the Confidential Information (i) is or becomes 

generally available to the [)lblic thr~ 00 fault of the r«:eiving Party (or anyone acting on its behaU); (ii) was previously 

rightfully koollTI to tt.:: reeeiving Party free of any obligation to keep it oonfidential; (iii) is subsequently disclosed to tt.:: 

receiving Party by a third party who may rightfully transfer and disclose the information w~hOUl restriction and free of any 

obligation to keep it oonfidential; (iv) is independently del-eloped by the receiving Party or a third party witlllut reference or 

access to the disclosing Party's Conlidential lnformation; or (v) is ott.::rwise agreed upon by the: Parties not to be subject to 

the restrictions sct forth in Seetion 9. 1. The receiving Party may disclose Confidential Information if required to do so as a 

maner of law, regulation or cem orda, provided that (i) the receiving Party shan use all reasoroble efforts to provide the 

disclosing Party with at leasllO days prior notice of su;;h disc1osure, (ii) the reeeiving Party shall disclose only that portion of 

the Confidential Information that is legally required to be: furnished, and (iii) the receiving Party shall use reasonable efforts 

to se~k from the party to which the information must be disclosed oonfid~n ial treatment of the disclosed Confidential 

Information Notwithsta d~ that portions of the Sel\'ices may be: deril'td in woole or in part from publicly available 

SOU'"Ce$, the Sen'ices and any of CoreLogic's databases used in deriving the Services are )X"oprictary, copyrighted and trade 

secrets of CoreLogic and, for the avoidance of doutt, the reSITictions on use aM disclosure of the: Services are not subjeet to 

the exceptions oontained in this Section9.2 

10. Cll umfr Prilarv 

Customer ackoowledges the Services may oontain public reeord data and trot this information may be cOI"lSidered sensitive 

information by some consumers. Customer shan oot: (a) broadcast or othelV/ise make pub~c the name, a<klress or other 

information abou! an individual cOllSwner; or (b) utilize in any manner the name, mailing aciaess, e-mail address or 

telephone number of a consumer that is designated in any results obtained \IS~ the So!l\'ices as request~ protection from 

so~citation 

11. CortLogic In<iemnifirutionj Di im s; Injunrlion 

II.I Intellrctual Proptrty Indemnific ation CoreLogic shall indemnify, defend and hold Customer harmless from all 

third party claims, losses, liabilities, costs and expenses auributable to any allegalion of intellectual property infringement in 

the United States arising OUI of this Agreement, pro~ided that: (D Customer gil'es CoreLogic prompt written notice of any 

soch allegation, The Department of Justice shall represent the gOl'emmenl against any such claims in accordance with 28 

U.SC. 516. Notllithstanding the abo~e, this warrant)' does not apply and CoreLogic shall ha\'e 00 obligation 10 indemnify 

Customer if an allegation arises from the combination or use of the Sell' ices with any ott.!r software, data, or materials not 

fumis[);!d by CoreLogic, if modifications are made 10 the S¢IVices without CoreLogic's written autOOrization, or if the 

Sen-ices are used in violation of the terms and conditions of this Agreement THIS SECTION SETS FORTH 

CORELQGIC"S El\!JlRE LIABILITY TO CUSTm,fER AND cusrm,fER'S SOLE REtlffiDIES WITH RESPEcr TO 

ANY INTELLEcrUAL PROPERTY THIRD PARTY CLAIMS 

I L2 Infrin gement. If in Core Logic's sole discretion the Services violate a third party's intellectual property rights, 

CoreLogic may: (i) procure the right for Customer 10 cOr1inue using the Services; (ii) modify the Services to reMer them no 

10!l';er subject 10 any s\ICh claim or action; or (iiD replace the So!rvices lIith equally suitable, fWlctionally equil'alenl, noninfringing sen-ices. 

11.3 Umitations on Se r. icrs. [Intentionally omitted] 

COl'.'F1DEt-.'TtAL 
356 


IIA Warranty and Disdaimer. CoreLogic warrWllS that the Services are merchantable and frt for the panicular 

purpose described in each SOw. CORELCXiIC DISCLAThiS ANY OTHER WARRANTY OR REPRESENTATION OF 

ANY KIl\1D, EITHER EXPRESS OR Il ... IPUED. 

11.5 Injundion. Customer acknowledges that the Services are valwble commercial )l"000cts, the development of which 

ulI'olved til! expenditure of substantial time Wld money, Any \'iolation of the Permined Applications or Corelogic's 

intellectual property righlSshall be governed by 28 U.S.C. § 1498. 

12. CortLogic's Umitation or Liability 

NOTWITHSTANDING ANYTHING TO THE CONTR.6..RY IN THIS AGREEMTh'T, EXCLUDING CORELOOICS 

INTELLECTUAL PROPERTY [NDEMNlFlCATlON OBLIGATIONS CONTAlNED IN PARAGRAPH 11. 1 ABOVE, 

CORELCXiIC"S TOTAL LIABILITY AND aJSTO!l{I;R"S EXCLUSIVE REMEDY UNDER OR RELATED TO THIS 

AGREEMENT IS LIMITED TO DIRECT MONEY DAMAGES NOT EXCEEDING THE GREATER OF THE AMOm.,rr 

PAID BY CUSTOllffiR TO CORELCXiIC DURlNG THE THREE MONTHS PRECED[NG THE CLAIM OR $10,00) 

THIS W.fIT [S CUMULATIVE AND ALL PAY!I'IENTS UNDER THIS AGREEMENT ARE AGGREGATED TO 

CALCULATE SATISFACTION OF THE UlIfiT THE EXISTENCE OF MULTIPLE CLAIMS OOES NOT ENLARGE 

THE LIMIT NOTWITHSTilJIDING ANYTHING TO THE CONTRARY IN THIS AGREElIiENT, CORELOOIC 

SHALL HAVE NO LIABILITY UNDER OR IN ANY WAY RELATED TO THIS AGREEMENT FOR ANY LOSS OF 

PROFIT OR REVENUE OR FOR ANY CONSEQUENT[AL, [},'OIRECT, INClD8HAL, SPECIAL, pm.,1JTlVE, OR 

£"'\'EMl'LARY DAMAGE$, EVEN [F CORELOO[C IS AWARE OF THE FOSSIBILITY OF SUCH LOSS OR 

DAM,AGES 

U. Customer's Indfmnifkation nn\(:ntionallyomined,j 

14. Gtnerllf Prolisio ~ 

14.1 Federa[ Acquisition Regu[ations, Federal Acquisition Regulations ('FAR") Sections 52.2 12· 1, 52.212-4, 52.212-

3 and 52.212-5 are hereby incO!pOl1lted 

14.2. Agency. The Parties adnowledge drat this is a business relationship based on the e.xpress proI'isions of this 

Agreement and 00 partnership, joint wllure, agency, fiduciary or employment relationship is interoed or created by this 

Agreeme .... Neither Party is the legal representative or agent of, nor lias the power or right 10 obligate, dired or supervise til! 

daily affairs of the other Party, 800 neitll!r Party 0011 act or r~)l"esent or hold itself out as soch. The rigJus, duties, 

obligations aoo liabilities of the Parties shan be semal and not joint, each party being ilXIividw1ly responsible only for its 

obligations as set forth in this Agreemert 

14.3 Smrability. If Wly of the provisions of this Agreemelll becomes invalid, illegal or menforceable in any respect 

W1der Wly law, til! validity, legality and enforceability of the remaining provisions shaU not in Wly way be affected or 

impaired. 

14.4 Wainl'. Any waim is only valid to the extent expressly set forth in writing. No waiver by eitll!r Party of any 

breach by til! other Party of Wl)' of til! prol'isions of this Agreemert is deemed a waiver of Wly preceding or succeeding 

breach of til! same or Wly other provision 

14.5 Sul"linl The following sections suryive termination of this Agreement and continue in full effect W"ltil fully 

satisfied: 3.2 (License Restrictions); 5 (Fees); 6 (Reporting; Audits); 7.2 (Effects ofTermination); 7.3 (Return or Destruction 

of Materials); 8 (Third Party Use); 9 (Confidentiality); \0 (Consumer PriYacy);; 11.4 (Disclaimer); 12 (CortLogic's 

Limitation of Liability);; Wld 14 (General Prol'isions) 

14.6 Emution. This Agreement or Wly SOW rna)' be executed in Wly number of counterparts, each of which is deemed 

Wl original, Wld all taken together constitute one and the same instrumenl. If this Agreement is executed in counterparts, no 

signatOl)' is bound Wltil all Parties have duly execlled this Agreement and all Parties ha\'e recei\'ed a fully executed 

Agreement. Any signature transmitted by facsimile or e·mail (in .pd~ .tif, .jpeg, or a similar format), or a pootocopy of such 

transmission, is deemed 10 constirute tl".! original signature of such Party 10 this Agreement. The indil'iduals signing below 

reiXesent that they are allhorized to do so by and onbeha[f of the Party for woom the)' are signing. 

14.7 Gonrning Law; Forum; Jury Trial; Attorneys' Fen. The interpretalion and construc\ion of this Agreemenl is 

governed by the lawsofthe United States 

hgdofS COl'.'FlDEt-.'TtAL 
357 


..• " j., 6816 'I, i 

IU UocutnIabItAca. UocoOllOII&bIeKlS~lbt~by'AIlS12 l-4(!). 

14.9 AII!c .. leD.t N'd!).cr tilt)' Jball wipl 01' QUSfo:r IhiI A~ On'\1 tljho III cbUp:Iou u ~ ApcOllftll 

'IIitA:I~t !he prior wri1Ia consiliI o(the OtMr tarty, 'IIfIich 1haIJ 1101 bot 1WtI\I000ty whhllt\d, 'OIIdil. 0\' okby<d. Any 

IIIIlIIhori=4 lilSifm'4/OI' tnllll{ershall bcvok!. l1I1s ",f'WMII{ WNil .... d 11_ co IhI bdlefit aftbt Pm u6lhtit 

mp«lrMpMlillcdJ~Md lICt"IiltOd us", .. 

14.10 HtdeH. Adj 8Il11ce ot o6et CIO/MIalClbl nq,irtd 01' perNItollaia IMr Apmca! U slClidttdy a/YeG If 

okli.cnd .. pmoc.« ICmI ~)' OAt ofd\o! fGlIo".nc 1Mbods: (I) ktlllllle 01' (b) CO!n .. erdany ~ ~ SUYiI:t 

,.;th Indi,,!erpabnitia. Nolit.cIlll CIatJoI\\CfIlliU be UIltlll kaddrwor Dllli1e lot.Vt.4in 1IK:1i~ 1tAcs. Ntldtu 

' \6 CeroJ..oel$ sMlI be "lillo' FIrst AnIcrican Wl'J. $inti Au, CIIIilmrit. 9l107"Fr.ctiadlc (7U) 216-6S~. *1 10 !h. 

~D of 1M f~ btIow, willi. cow I~ Coulotlc', ~1 " Il1o IiIm, Iddrew mlJttd A\Ieatlon; !ApI ~ MySIICb 1ICI.iec00~b ~proptrlydo!lvndllof~)IIIc_patoDaIIy4eliwn4. Q~ WI! 

br IicaiIrak, or (iii) GIll builMsi dI:Ilftl' ic is leM by co.,wd;!]1y IKOpized IMIlliPIICf'ike. A PIIIy IIIq cbu:e iCJ 

IIWra.1 ~ 'IIri&n aoIiu P..ctlIO ~ oW httj befctt ct.t ~daleor IIdI dIa!p. 

14.11 CiAOka btCWeu SOW 1M A&nc1i0llt, If til .. , iI • ~ict baiWl;tIIlbe tum. of thh Mutu L/«ftse 

~elllCfllwt tlletUIMtild oolllikloru illthld¢4 Wl'llltn o.lWIieWle sow, IbiJ ~1tcI ~ ~looMlsurJe» 

o:pIicilly uat&d. oj),~ il 1hc: IPpIUb" sow, lad iIId!Lt we 1M CIfIft)cdo, «nDi ,"d OlIlfitiom ill well SOW apply 10 

IbISOWonly. 

14.12 Il~J'inIDIiIkrs. tfwl llP~!IIo ~,orexllJeCticm_ tulUdioaartto:dy ror~cniemirA 

IMII ~~t DO dT«:t upon ~ 01 iT:terpm:lioll ()fddJ Ap~.enL Thc Ma actr.owiqe 1II.1hi$ ApIMlll '111' 

pt6pNtci by boI' hnlosJolMIf. 

Itll £aIitt AtreclltD.(, Willl/tSPt:l to the SenoIc. pr<Mded IIHkr dUI ~ Ibis ACOC/IIUI~ C()MU, ~ doo 

h4ert1 ~~IIIM Ret\lllllol\ w.sriN1CII d.t ~ ~_ bcNc:JI !M Paniu .itA ~CJ til pritr 1M 

c()1I~acretmer.u&r.d ~ ofNPtI!ItJ, NOlllOdiftarilWlOthit~II( dl'oc:Uw_ n. 

wrilins -1Iifd by bGdI P3r1ic. 

THI. tARTIES Jf",V£ RRA.1). UNDtJtSTOOD AND AGREED TO THE TUMS M'D (OriD-IT/ONS or mlS 

ACJt.E:£,'I1tN'l'. 

IUR£..\UOPTm; 'UWC tllIT, ON IUfAL1 or nu: CONSUMU ,mANCB rROTtC'nON' BUREAU 

("CUSTOMtR'") 

'1: " ! 

~ 

tL,,-=--L -

, JA<.D]!; 03Gtl-U,.J 

Tidc:u,,,,,'T'n-AG-TlI>Jl:r <fI-.FIl£'{L 

Dale: 8("'/1'2... 

Adilftss: 

lJ.11IkJ 

COlELOG1C SOumOIiS,UC 

l"CORELOGlc-) 

it> 

~=~Y~J~ , .. , _-=fO+(.:.. ..... +-I""1 'I..=--

Ad~ 4 fits!,u,ericaa Wq 

$ala Au. ClNbJia m01 

'''''''''00 
358 


STAH~IENT Of WORK 1 

This Slllltmenl ofWorl.: I esow Ii is b.!tween CoreLogic Solutions, LLC, a California limited liabilil)' Ctlmpany 

("Core Logic"), and The Bureau of the Public Do!bt (~BPD), on behalf ohlle Consumer Finaoce ProteClion Bureau 

("CFPB" and with BDP, "Customer"XCtlllectil'e!y,!he ~Panies," or irdil'idwHy, a "Party"). This SOW I is subject 

10 !he allacred Master LiCl!M! Agreement of even date here\\;!h, and all subsequent amendmeltS, exlubits, or 

attaclnnents ("Agreement") between the Parties This SOW I is effectil'e upon the date of last signature ("SOW I 

Effective Date"). The Parties agree as follows 

I. SERVIC!:S, IlWVERY & r[ES: CoreLogic shall provide OIstomer with the Services listed below via the 

specified dtlil'ery method. Customer shall pay 10 CoreLogic the Fees set forth below. If the chart below 

iooicates that an exhibit is anached, the additional terms aoo conditiOO'; set forth in the exhibit awly to the 

Sc:rvice 

Mlnn, FffS& Additional Information 

A. LOA." U:V[I, i\JORTGAGE DATA Deliwtyvia Secure File Transfer Protorol \SFJlY) 

II. ADDITIONAL FIE & DELIVERY I,'ifORMATlON: 

A. L~an J.A>nl Mortgagt [bla: The Loan Level Mortgage Data Services shall oonsisl of the data elements 

shown on the attached Loan Level Mortgage Data Exhibit (Technical Requirements). 

R. Feu: Customer shall pay CoreLogic the Fees set forth in the oonlr3ct. 

IU. PER.\1tlTE1) '\pPUCATIOl>iS: Customer and Permitted Users ~ifled below shall use the Services solely for 

the applicatiOO'; specifled below in accordance 1I;!h the terms and oonditions of !his Agrcement 

A. euslomer's Ust: 

In accordance with the terms of the Agreement, Customer may use !he Loon Level Mortgage Data for 

Customer's internal bu;iness pmposes of risk malllgement and portfolio analysis. Customer may also 

use the Loan Level Mortgage Data, alone or 1I;lh other information Customer creates or obtains from 

other oota providers, 10 create analysis, reports, aoo research for both internal and external use 

("Customer's Rep:xtsi. Customer may publish Cu;lomer's Reports on Customer's website, in 

academic Journals, po~cy report<; and other media and may acknowledge CoreLogic as a SO\[CI! of 

data used in Customer's Reports. Any such publications shall only ioclOOe immaterial portions of !he 

Services, in aggregate form, and will include no loan Iml data 

Customer srnll not attempt, directly or indirectly, to rev~ engineer, deaoonymize, decompile, or 

disassemble the Loan Lml Mongage Data Services. 

CoreLogic shall retain all righ~ title aoo interest in and to ~ Loan LmJ Mortgage Data. Customer 

slJill retain all right, title and interest in and 10 the Customer's Reports. Prm'ided Cllitomer has 

complied with all terms of the Agreement and this Section lIlA, Section 7.3 (Return or Destruction 

of Materials) of the Agreement shall not apply to the Loan Lel'el Mortgage Data Cmtomer has 

iocorporated into the Customers Reports following termination or expiration of this SOW. 

Except as expressly provided in this SectionIII.A, Customer shall not otoowise smliceme, resell, or 

prm'ide the Loan Lel'el /l-btgage Data in whole or in part to any third party. 

IV, Sow TtR.\1 A;\TI R£J\"[WAL: The term of this SOW I is for twelve (12) months, commencing on the SOW I 

Effeclil'e Date. Thereafter, the term of this SOW may be renewed by Customer for four (4) additional tweln 

(12) month terms 

V. EXEUlT10)i': This SOW I may be executed in any number of CO\IJ.teIpar\s, esch of which is deemed an 

original, aoo all taken together constirute one and the same instrument If this SOW I is executed in 

counterparts, no signalory is bound Wltil all Parties hav e duly executed this SOW 1 and aU Partres hav e 

Pagel of8 COl>'FlDEt-'TIAl. 
359 


-- AU!. 2. 201112: 5IPI -_. --10. 6616 P. r 

rc~ I fully e~6CIlteO sow I. Tho ~~ a.:I:nowlcdge tMIl1!j >.ipalur~ Inn$mill:d by facsjl'llil~ or 0-

!lUi1 (m .pdf, ,II' Jpo," ot I ttlll;11Ir fimIIaI). or~ PM!I\CCPy cfs.eh lRumislic .... i$ dc~cd 10 corwilttc me 

ori~ sipatliro ottuch p!lt)' 10 !hi, SOW I. ~ Individual, Psnin& bollow ttjlfCSi:I'II dw Ibey ar; ~udIOriu:I 

10 do SI) by MId 011 bebllf oflht PlIny t'ot whollllbc)' IR :Ii;nm" 

THE rAlTl!S HAVE RE ... o. UND£ASI'OOD ANt) "GRElD '1'0 TIlE tUMS M'D CON'llm()NS OF 

TH!SSOWI. 

THE BUREAU orrnt lU8UC DEBT, ON 

BElIALl1 (W11{E CONSUM£R nNANCF: 

PRoncrloN BUIEAU rcuSTOM~ft·) 

COnLOGiC SOltmONS, LI..C 

("COUI.OGIC") 
360 


TECHNICAL REQUIREMENTS 

TECHNICAL REQUIREMENTS 

TPD-CFP-12-C-0010 

Appro~ate support levels will be provided wHh respect to the data (i.e., 

res~nse, etc.) 

SlA, JXliri.of contact, time for 

Datasets include loan-level data that allows CFPS to idertify relationships be\W"een loan featlJ'es and 

defauH risk 

Datasels combine origination data w~h Klan performaoce data 

Datasets contain at leasl25 million active loans as of 12131f2011 

Datasets are timet)' (Data will be provided less than 45 caleooaf days aller each month's end) 

Datasets contain data integrity arK! support 

Full rights to publish research, analyses. reports, and otherworl< based on these datasets are provided; 

No advance nobce of advance review of, or permission for publicatioo is r.ecessary; 

Right to reference use of the dataset in publications and other public commlXlications using the data is 

fYOVided; 

Right to publish research, analysis, reports, and other work sl.l\lives the license (i.e., CFPB has Itle right 

to publish data ottained after the license has expired); 

Righi to merge the data w~h all other datasets witl"oul affecting any CFPB usage or publication rights is 

provided~ and 

No use restrictions are provided 

If, and when, any newfields are added to the dataset the CFPB data dictionary will be up:::lated and a 

clear exptanatiOO of charges/updates will be provided; aro 

CFPB access to the web.t:esed p:)rtal is provided 

CFPB has the ability to include custom fields in the datasets 

Datasets will be made availatje in standard formats (e.g. csv, tat).del m~ed text, XML) that are natively 

compatible for Ioadirg into SAS SeNer, PostgreSOL, and MS SOL Server errvironments; 

Datasets will be made availa~e in a user.friendly web interface; 

Datasets will be made availatje to CFPB via OOrMlOfl fi le transfer protocols (e.g., SFTP);aro 

If alAhentication is required for accessing the prodLd, CFPB will te provided required crederiials. 
361 

Experian 


DEPARTMENT OF THE TREASURY 

BUREAIJ OF THE I'UBUC DEBT 

PARKERSBURG, VN 26106-1328 

Expenan Information SolutiOI'\$, Inc 

1410 K Sl!et\ NW, Suite SO l 

Washingt<:n, DC 20005 

14 September 2012 

Subjett Callrael NlfllberTPD.cFP-1H:'OOI6 

Coogratulatimsl Enc!C«d is the cauract a\\lIId ftT Corruner Credit Infamaticn Pane! in 

.UPJmt ofme CorIsumef Financial PrOle.:ticn Bureau (CFPB) 

Please lel'iew the endC«d cermet award and if in agreement, please eanplete t:ioc~ 30a, JOb 

and30c at Page I ofme Slalliard Fam 1449. B)'si~ the SFI449, yOllacknowledgeand 

acoepI the lenns and conditions oflhis cootract. After si~ the document, please jKOIJide a 

ropy of the signed fonn lia email 10 carev.grrop?bpd.treas.gcw. 

Please nc(c thata Subcoonacting Waiver has been grued and therefore FAR 52.219-9 Alt Il 

and FAR 52.219.16 hal'e been renJO\'ed from the Supplemer!lal Terms, Ccndtions and Claw;es. 

After f1111IId, anyqu$ion> or isslltS relaled 10 !lis procurernenl will be hamted byrne Cattracl 

AdrrriniSirabon Br.mch &1 «mIUICti!dmim\lraticnl1bpcitrea<_@(IV. When sending an e-mail to this 

adt.tess, please ioclllde the order Il.IIl1ber in the subjet\ line of the e-mail. 

The follQll,ing are allhorized to place ordefs again>1 subject cootracI: Any I'.1II!alIIed Cortracting 

Oflicu (CO) for the Bmrou of the POOlic Debt (BPD), Division of Procuremert, may place 

ordefs again>1 this cm/I3ct. The cm/I3ct hclder sha!1lr)1 provide anyjl"oducts or seMces 

"ithot« rMI1ng an awarded ordeJ signed by the CO 

Ms. Xiaoling Arg tos been designated Contracting Oflker's RepTesentatil'e (COR) for tIlis 

COTIDld. Ms. Ylil Wen ling bas been designated Altemate COR fC( iii! cootract. A ropy of 

QUI leners so designating Ms_ Arg and Ms_ Ung are erdosed for}l:lll" infC(lll3.tion. They cordain 

infocmatioo on their dulies and the scope of their aillhority in !lis ca!Dcity of .. ruch yOll shoold 

be aware. Ms. Arg may be leached at 202-435-7686 (If lia e-mail at xia<iing.ang1icfub.gO'l. 

Ms. Ling may be leached al ZOZ-41'i-9251 or lia e-mail at l'llhwen.li ng'itcfOO gov. 

Endos\l'es 
362 


SOLiOTA nONICOHTRACTIOROER FOR COMNERCIAllnNS 1''''''-'SOiHlN ..... rm r.e, ·1 OI'F<ROR rOCOWUT£ILOCKS ll, 11, lJ, 24,' JO 1 l' ,~~ 1:- d-~~ ji SCOOTlllON 

..... 

8EIl 

TPD-CFP- 12- C- OOI6 ~ .. BPD-CFP- 12- CI - 0004 f,i"~ •• 09/24/201 07/03/2012 

, FOR10llC1TAOON ~ 

~= OOTSON I'~- ""'_'""I r Off8!rueo.ThlOCl<l.IlIE 

IN'ORJtO,TIOMCA" ET 

1,S9.{OS'l {;(U IBPD-CGROPP ,I TNSo.coo:sollON1S II:! Vlf6J1l1.;-JWOR O~_ ,~ 

Bure"u of Public Debt D!>Iou9JS1/ES5 I'OIEH-CMIIWSIOIU~ 

D(VIOOO)a.ol(U_m::I'OI~ 

Divi~ion of Procurement DIUIlONEs,,",u -,--"""""'" !Wre561450 Avery 5F ~ 0_ 

200 Third Street O~ O~, llZESTAIf:lOllO $7 , 00 

Attn

Puker~burg 

: C. Gr0rP 

WV 26101 -

-~ 

" WJ\'8!'I"ORFalWTJlol. r,Osc:c>JN1,.,...,S rlo IIllWG 

~"'.ES$(I.00<1S /30 PROHPT PAY 0". T>lSC<.:mRO(1I$' 

IIlJW<.:RWllfUR 

O~~ Di'oISI,jCfRlIIll I" .rnmaSCUOT.TIOO 

IJFI.-Q On , .. ,j DElMRTO COCE ICFPB IIALl11NSTEmlS'l C(fi ~PO 

IT" Bureau of the Public Debt 

Attn : Ms . Xiaoling ling Di vi.5ion of Procurement 

1700 G Street NIl' drnini~tration Branch 

Wa~hington OC 20552-0003 very 5F 

200 Third Street 

Parkersburg W 26101 

" . CCJITI'O.CTORI {;(U r08642530 ]':1 "' .... noENT ...... ~.~S'I C(fi ~RCI ASol APB .-

EXPERIAN INFORMATION SOWTINS INC- l Rc/ASO/APB 

475 ANTON BLVD RC/ASD/APB, AVERY 3G 

OOS1A MESA CA 92626-7036 PO BOX 1328 

CCOUNTSPAYABLE@BPD . TREAS .OOV 

PARKERSBURG W 26106- 1328 

~~ 

W"I CHEOCI' ISIrrr~ ISO'FSU/T _1'OT5'JO< .tUJ1ESS'" CfFEll I'" iU8illTtNC:ICESTO/olOeS_LNiI..OO<",lIIl.el1lil..OO< B8.~ 

,SCI£CI<ID ocrE«l.OI 

" " " " " , ~~ SQ£OO..ECfSiJ'f'<ffiSEJMoEi ~" ~ 

-~ .~ 

he purpcn!e of thi.s firm- filled- price (FFPI 

Indefinite Delivery/Indefinite Quantity (I0IQ) 

ward i~ to provid€ a ConSUI'Ll€r Credit Information 

aMl in support of the ConsUI'Ll",r Financial 

rQtection Bureau (eFPB) in accordance wi th the 

ttached Statement of Work (SOW) . 

he Contractor ~h~ll provide ~",rvices only as 

uthorized by task order, and in accordance with 

the IDIQ contract . 

W~ RMM , 1l!Vor AlIKh Addlm,'SMels IS /leceSSlry) 

15 ACCO\.III"'GMON'PROPII"T(lNOATA r 10I.o.tA.....slO .... OUNT 11«_ l!ao"", 

S€e schedule $0.00 

011. SOlCIIAT(lN NCORPOAAIESBYREfERENct FAAl1111-1, ~l'l~ F.o.RIlll2-3 MO~ 111lAReATTACHEO AOOENO DME DAAENOUTIACHEO 

GlARe DARe NOT ATI.o.cMEO 1iil 11b CONIR.'':;UUU;MASE OIlOER NCOI>PORATES 8'Y REFE~Nct FAA 1111~ FAA ill1lllSATTACHEO 1OOEN()o' 

~18 COlfrR.I<:TOR lSREOO RfOTOSGNHIISOOQJIoIENI NlDRfTUlIN 

COP ES 10 ISSU NG OFF(E CONTR.I<:TOR AGREES 10 FUIINISHMC:> DE,N'ER 

AU rT£MS SET FORT~OR omER~s£ OENTfEOI-OOVE NlO ON IWY 1OO!T1ON.>l 

SH:OISSU8.lOCI TO THE TER~ANOC(lNorrI,)NS ~ECI'IfO 

I-IJIHORllEDfOR lOc.o.t RH'ROOUCllON 

PRO\fIO\JSED'H',lN ISNOTUsoaE 

j3O<0ATES~EO 

o 19 AWAAIl OF CONTRACT OFFER 

OAIEO YOUR OFFER ON SOLClTAII(lN 1f!.00< It 

rlQ!llfi(;.oIIY .ooo~IONSOR ClWlGES VlHCH AAE SEI fORTH 

HEREIN. IS .l<:CEPlEOAS 10 rTtlolS 

ISA R. STANLEY 

IT.oJIOARDFORM ImIRE'I. 11I011) 

I'n Kribod bycso. ·F/Jt(E CfR)63212 
363 


- Dir ector, 

IGo",~'m' POe/COR ; Ms . Xiaoling ling 

202- 435- 7666 

xiaoling . ang@cfpb . gov 

IGo",,~'m' Alternate PCC/COR ; Ms . Yuh \Olen Ling 

202- 435- 925 1 

yuhwen .ling@cf[:b . gov 

Condition~ and Clau~e~ are a ttached hereto 

lnvoice~ are to be ~ubmitted 

on a task order basis. Invoices wi ll be 

will be handled by the Cont ract 

I""iei"'''ioo Branch at 

loo"",,,,,,,,ioi,,,,,,i,o",,,. treal!. gov . When 

an e-mail to this address, please i nclude 

the ta~k 

31. QUNIIITY .. COll.!ON 11 HAS BEEN 

o RECEIVEO o INSPEcn:o o ACCEPiEQ 1<NO CONFORMS 10 TIE CONIRACT. EXCEPT ASHOTED 

2 of 18 

J1b SIGH~TURI' Of .o.JJIHORI/EOGOI'5lNMENI REPRESENTATM; 1310 DAlE 31< PIlNIUl NAME.o:IO mtE Of AlJIHORllUl GOVERNMENT RE_SEm~TIVE 

.12. IoIAI. NG p.f()IlESS OF AiJlHORilID GOVERNMENT REPfIE5ENTAlI'IE III TELEPHONE II.It.ftR ~ AlJTHORllUl GOVERliMENT REPRESENT~TIVE 

Jig E-MAl Of .o.JJIHOR[EQ GOVER'iMENT REPfIESENT~I"' E 

13 SHP ...... BER YO\.ICIERN~IlER II AAlOUNTVERfEO ~ P~YMENI 31CIECKII.I~ 

RI:;ClfOR 

OPAATlAl OF .. .<t 

OC(lMFl.E1E O PAAWl 0'-

Illi ~\QIJCIERNUh1 BE R 100 P.o.(IBY 

." 1 CEI!TfY THIS,o,cCQUIT IS COR'lECT AJI;) PROPEl! FOR PAVMENT '1. RECEI'IED BY rPftt1tJ 

41. S!GNAIURI'ANOml OfCE~II'YHG~fn~ <1< o.o.lE 
364 


CEI'O~l'OCI./I08ITEII3!(;COI<TIN1!8l 

CONTINUATION SHEET PD-CFP- 12-C- 0016 

IWOEOFOFFffilRORCCI<TI!.cTa! 

EXPERIAN INFORI1ATION SOWTINS INC- l 

-~ IAI 

~ 

18 1 

h~ ov~rall lIIinimlllll for thi5 cont ract i5 : 

1, 622 , 800. 00 

h~ minimUIII i5 guarant~ed 

he overdl maximum for this contract is: 

8, 426, 650. 00 

he minimum aI:lount for an order against this 

ontract is: $6, 000. 00 

he maximum aI:lount for an order against this 

ontract is: $8, 426, 650 . 00 

Period of P~rformanc~ : 09/ 24/ 2012 to 09/ 23/ 20 17 

0001 Base Period - CFPB CoIll'lUI:ler Credit Information 

Panel 

Refer to Attachment I - IDIQ Price Schedule 

Award Type : Indefinite- quantity 

Min . Qty : N/ AI Max . Quantity : N/ A 

Mi n. Amt : $1 , 622, 800 . 00 1 Max . Amount : 

5, 287, 050. 00 

Minimum Guaranteed : Y 

Penoo of P~rformanc~ : 09/ 24/ 2012 to 09/ 23(2013 

0002 ~~ion Perioo I - eFPB Con."lumer Credit 

Information Pan~ l 

Refer to Attachment I - IDIQ Price Schedule 

J\<Iard Type : Ind~finite quantity 

Min . Qty : N/AI Max . Quantity: N/ A 

Min . Amt : 50. 00 1 Max . Amount : 

784 , 900 . 00 

Minimum Guaranteed : N 

Amount : $784 , 900 . 00 IOption Line It~IlI ) 

Perio::1 of Performance : 09/ 24/2013 to 09/23/ 2014 

0003 Op~ion P~riod 2 - eFPB Con5um~r Credi t 

Information Panel 

Refer to Attachm~nt I - IDIQ Price Schedule 

J\<Iard Type : Indefinite- quantity 

Min . Qty : N(AI Hax . Quantity: N/ A 

Mi n. Amt : SO .OOI Max . Amount : 

784 , 900. 00 

Minimum Guaranteed : N 

Amount : $784 , 900. 00 IOption Line Item) 

Continued ... 

• -s.1S<1l<I ,·,\281 

!8 

~ 

- _ _ 0 

.~ 

Ic) ID lEi IF) 

5, 287, 050 . 00 

0. 00 

0. 00 

CIPl1O'IIlFORllnli'-\li) 
365 


CEHO <:1'CIlO.OIEIIl88"'C(JNIIjIJ8) 

CONTINUATION SHEET PD-CFP- 12-C- 0016 

_OI'OI'fCllORORCOITR4C1OR 

EXPERIAN INFORMATION SOWTINS INC- l 

-~ lA' 

~ 

1" 

Periocl of Performance : 09/24/2014 to 09/23/2015 

0004 ~~ion P,.riod 3 - CFPB Consumer Credi t 

Information Panel 

Refer to Attachment I - IDIQ Price Schedule 

Award Typ,. : Ind,.finite- quantity 

Min . Qty : N/lIl Max . Quantity: N/ll 

Min . Amt : SO.OOI Mall . A!lIount : 

784 , 900.00 

Minimum Guaranteed : N 

Amount : $784 , 900 . 00 IOption Line Item) 

p,.riod of h>rfonnanc,. : 09/24/2015 to 09/23/2016 

0005 Option Period 4 - CFPB Consumer Crem t 

Information Pand 

Refer to Attachment I - IDIQ Price Schedule 

Award Type : Indefinite- quantity 

Min . Qty : N/A) Max . Quantity : N/ll 

Min . Amt : SO.OOI Mall . Amount : 

784 , 900 . 00 

Minimum Guaranteed : N 

Amount : $784 , 900.00IOption Line Item) 

Penod of Perform~nce : 09/24/2016 to 09/23/2017 

h,. total amount of award : S8, 426, 650 . 00 . The 

obligation for this award is ~het.m i n boll 26 . 

• -s.1S<1l<I,·,\281 

18 

~ 

- _"0 .~ ,e, [0 ''I 1" 

0. 00 

0.00 

CJPlIO'IIlF<.lRllnli'-\li) 
366 


TERMS, CONDITIONS AND CLAUSES 

SOFTWARE FEDERAL DESKTOP CORE CONFIGURATION (FDCC) 

AI software wtll::h is designed to run on Windows Vista or XP desktops must function without modification to the 

Federal Desktop Core Configuration (FDCC) security configurations developed by the National Institute of Standards 

arod Technology (NIST), the Department of Defense (DoD) and the Department of Homeland Security (DHS). 

Software and hardware products that are deSigned to operate in environments other than the FDCC desktop must 

have a standard configuration guide published on the NIST website, or the vendor must supply a recommended 

configuration guide for all configurable security settings. 

PUBLIC-RELEASE CONTRACT VERSION REQUIREMENT 

The corrtrutor agrees to submit, within ten business (10) days from the date the contract is awarded (exclusrve of 

Saturdays. Sundays. and federal holidays). a text·based .p:!ffile of the fully executed contract or task orderw~h all 

proposed necessary redactions, including redactons of any trade secrets or any commercial or financial infonnation 

that ~ believes to be privileged or confidential business information, for the PJrpose of public disclosure at the sole 

discretion of the Consumer Financial Protection Bureau (CFPB). The contractor agrees to provide a detailed written 

statement specifying the basis for each of its proposed redactions, including the applicable exemiXion under tile 

Freedom of Infonnation Act (FOIA), 5 U.S.C. § 552, and, in the case of FOIA ExemiXklO 4, 5 U.S.C. § 552(b)(4), shall 

demonstrate 'Nhy the info nnation is considered to be a trade secret or commercial or financial infonnation that is 

privileged or confidential lnfonnation provided by the contractor in response to this contract requiremenl may itself be 

subject to disclosure under the FOIA. The CFPB Ylill carefully consider all of the contractor's proposed redactions and 

associated grounds for nondisclosure priorto making a fi nal delermination as 10 wIlat information in the fu ~ executed 

contract may be propeny withheld. In the event that the CFPB disagrees with the corrtractor's suggested redactions, 

the CFPB will provide the contractor with notice prior to posting the contract 

PRODUCT PROVISIONS 

Page 15 

TP[).CFP-12-C-0016 
367 


52.212-4 CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (FEB 2012) 

(a) Inspection/Acceptance The Contractor sha~ only tender lor acceptance those nems that conform to the 

requirements olthis contract. The Government reserves the right to inspect or test any supplies or seNices 

that have been tendered for acceptance. The Government may require repair or replacement 01 

nonconforming supplies or reperformance of nonconforming sel\'ices at no increase in contract price. II 

repair/replacement or reperformance 'Nil l not correct the defects or is not possible, the Government may 

seek an eq ~able pice reduction or adequate consideration for accejXance 01 nonconforming supplies or 

seMces. The Government must exercise its post-acceptance rights-

(1) Within a reasonable time after the delect was discovered orshould have been discovered; and 

(2) Before any substantial change occurs in the cond~i<m of the item, unless the change is due to the 

defect in the item 

Page 16 

TPD-CFP-12-C-0016 
368 


(b) ASSignment. The Contractor or its assignee may assign its rights to receive payment due as a resuH of 

performance of this cootractto a bank, trust company, or other financing institution, including any Federal lending 

agency in accordance with the Assignmentof Claims Act (31 U.S,C. 3727). rio'M!ver, wtlen a third party makes 

payment (e.9., use of the Governmentwide commercial purchase card), lIle Contractor may not assign its r;ghts to 

receive payment under this contract 

(e) Changes. Changes in the terms and conditions of this contract may be made only by written agreement of 

lIle parties. 

(d) Oispu/es. This contract is subject to lIle Contract Disputes Act of 1978, as amended (41 U,S.C, 60t-613). 

Failure of the parties to this contract to reach agreement on any request for equitable adjustment, claim, appeal or 

action arising under or relating to lIlis contract stlall be a dispute to be resolved in accordance with the ctause at FAR 

52.233·1, Disputes, wtlich is incorporated herein by reference. The Contractor shal proceed diligently with 

performance of this contract. pending final resolubon of any dispute arising underthe contract. 

(e) Definitions. The clause at FAR 52.202·1, De in~io , is incorporated herein by reference 

(n Excusable delays. The ContractorshaU be liable for delauH unless nonpelformance is caused by an 

occurrence beyond the reasonable control of the Contractor and without its fauH or negligence stich as, acts 01 God or 

the public enemy, acts of the Government in either its sovereign or contractual capacity, fires, floods, epidemics, 

quarantine restrictions, strikes, unusually severe weather, and delays of common carriers. The Contractorshal l notify 

lIle Contracting Officer in writing as soon as ~ is reasonably possible after the commencement of any excusable 

delay, setting forlt1 the lul l particulars in connection therewith, shall remedy such occurrence with all reasonable 

dispatch, and shall prom~ y give written notice to the Contracting Officer of the cessation of such occurrence 

(g) Invoice. The Contractor shall submn an original invoice and three copies (or electronic invoice, ~ authorized,) 

to the address designated in the contract to receive invoices. At! invoice must include--

(i) Name and address of the Contractor, 

(i i) InV{lice date and number, 

(iii) Contract number, contract line item number and, if applicable, the order number, 

(iv) Description, quanbty, ~ of measure, unn poce and extended pice of lIle nems delivered; 

(v) Shipping number and date of shipment, including the bill of lading number and weight of shipment ~ shipped 

on Govemment bill of lading; 

(vi) Terms of any discount for t:rom~ payment offered; 

(vii) Name and address of official to whom payment is to be sent; 

(viii) Name, title, and pllone number of person to be notified in event of defective invoice; and 

(ix) Taxpayer Ident~ication Number (TIN). The Contractor stlall include its TIN only rt required elsewtlere in this 

contract. 

(x) Electronic lunds transfer (EFn banking information 

(A) The Contractor shal incll.'de EFT banking informabon only I required else'lYhere in this contract 

(B) If EFT banking information is not required to be 00 the inV{lice, in order lor the invoice to be a proper 

invoice, the Contractor shall have submitted correct EFT banking information in accordance with the applicable 

solicitation p-oviskln, contract clal/Se (e.g" 52.232-33, Payment by Electronic Funds Transfer--Central Contractor 

Registration, or52. 232-34, Payment by Electronic Funds Transfer-Other than Central Contractor Registration), or 

applicable agency procedures. 

(C) EFT banking information is not required if the Government waived the requirement to pay by EFT 

(2) Invoices will be handled in accordance with the Prompt Payment Act (31 U.S.C. 3903) and Office of 

Management and Budget (OMB) prompt payment regulations at 5 CFR 1315. 

(h) Patent indemnify. The Contractorshall indemnify the Govemment and its officers, employees and agents 

against liability, including costs, for actual or al leged direct or contributory infringement of, or inducelll€nt to infringe, 

any United States or foreign patent, trademark or copyri h~ arising out of the performance of this contract. provided 

the Contractor is reasonably Mbfied of such claims and proceedings. 

(i) Payment. (t) l/ems arxepled. Payment shall be made for items accepted by the Govemment that have been 

delivered to the delivery destinaUons setforlt1 in lIlis contract. 

(2) Promptpayment. The Government wi ll make payment in accordance with the Prompt Payment Act (31 

USC. 3903) and Office of Management and Budget (OMB) prompt pay regulations at 5 CFR 1315 

(3) Electronic Funds Transfer (EFT). If the Govemment makes payment by EFT, see 52,212-5(b) for the 

appropriate EFT clause 

(4) Discount. In connection with any discount offered for early payment, time shall be computed from the date of 

the invoice. For the purpose of computing the discount eamed, payment shall be considered to have been made on 

the date wtlich appears on the payment check or the specified payment date rt an electronic funds transler payment is 

made. 

(5) Overpayments. lIthe Contractor becomes aware of a dupl icate contract financing or inV{lice payment or that 

the Government has otherwise overpaid on a contra ct financing or invoice payment, the Contractor shall-

(i) Remit the overpayment amount to the payment office cited in the contract along with a description of the 

overpayment including thePage (7 

TPD-CFP-12-C-0016 
369 


(A) Circumstances of the overpayment (e.g. , duplicate payment, erroneous payment liquidation errors, 

date(s) of overpayment); 

(8) Affected contract number aoo deMry order number, if appicable; 

(C) Affected contract line aem or subtine nem, d applica~e; and 

(0) Contractor po4nt of contact 

(ii) Provide a copy of the remittance and supporting documentation to the Contracting Officer 

(6) Interest. 

(i) All amounts that become payable by the Cootractor to the Government under this contract shall bear 

simple ilterestfrom the date due until paid unless paid wi1Ilin 30 days of becoming due. The interest rate shall be the 

interest rate established by the Secretary of the Treasury as provided in Section 611 of the Contract Oisputes Act of 

1978 (Public law 95.-563), ...mich fs applicable to the period il which the amount becomes due, as provided il (i)(6)(v) 

of this clause, aoo then at the rate applicable fo r each six·month period as fixed by the Secretary until the amount is 

paid 

(ii) The Government may issue a dt!mand for payment to the Cootractor upon finding a dett is due under the 

contract 

(iii) Finaldecisions. The Contracting Officerwill issue a final decision as required by 33.211 if-

(A) The Contracting Officer and the Contractor are unable to reach agreement on the exisler.ce or amount 

of a debt within 30 days; 

(8) The Contractor fa il; to liquidate a debt previously demanded by the Contracting Officer wi1Il in the 

tmeine specified il the demand for payment unless the amounts were not repaid because the Contractor has 

requested an installment payment agreement or 

(C) The Contractor requests a deferment or col lecton on a debt previously demanded by the Cootractilg 

Officer (see 32.607-21 

(iv) If a demaoo for payment was previously issued for the debt. the demand for payment included in the final 

decision shal identify the same due date as the original demand fO( payment 

(v) Amounts shall be due at the earliestol the following dates 

(A) The date fixed under this contract 

(8) The date of the first written demand for payment inciooing any demand for payment resulting from a 

de/auH termination 

(vi) The interest charge shall be computed for the actual number 01 calendar days involved beginning on the 

due date and ending on--

(A) The date on which the designated office receives payment from the Contractor; 

(8) The date of issuance 01 a Govemment check to the Contractor from which an amount otherwise 

payable has been withheld as a credit against the contract det:t; or 

(C) The dale on which an amount withheld and applied to the cootract debt would otherwise have become 

payable to the Contractor. 

(vii) The interest charge made under this clause may be reduced under the procedures prescribed in 32.608-

~ of the Federal Acquisnion Regulatioo in effect on the date of this contract 

U) Risko/loss. Unless the contract specifically provides otherwise, risk 01 loss or damage to the supplies 

provided under this contract shall remain with the Contractor until. and shall pass to the Government upon 

(1) Delivery of the supplies to a carrier, ~ transportation is I.o.b. origin; or 

(2) Delivery of the supplies to the Government at the destination specified in the contract ~ transportabon is 

I.o.b. destination. 

(k) Taxes . The contract price includes all applica~e Federal, State, and local taxes and duties 

(I) TerminatiJn for the Government's convenience. The Government reserves the right to terminate this contract, 

or any pari hereof, for its sole convenience. In the event of such termination, the Contractorshall immediately stop all 

work hereunder and shal ilMlediately cause any and all of its suppiers and sub:::ontractors to cease work. Subject to 

the terms of this contract, the Contractor shall be paid a percentage of the contract price reflecting the percentage of 

the work performed prior to the notice of terml1ation, pkJs reasonable charges the Conlractorcan demonstrate to the 

satisfaction of the Government using its standard recom keeping system, have resu~ed from the termination. The 

Contractor shall not be required to comply with the cost accounting standards or contract cost principles for this 

purpose. This paragraph does not give the Government any right to aud~ the Contractors records. The Contractor 

shaD nol be paid for any work performed or costs incurred ...mich reasonably couk! have been avoided 

(m) TerminatiJn forcause. The Government may terminate this cootract, or any part hereof, for cause in the 

event or any defa u~ by the Contractor, or ~ the Contractorfais to comply wi1Il any contract terms and conditions, or 

fails to provide the Government upon request wi1Il adequate assurances of future performance. In the event of 

termination for cause, the Government shall not be liable to the Contractorfor any amount for supplies or services not 

accepted, and the Contractor shal be liable to the Government for any and all rights and remedtes provided by law. If 

n is dele/mined that the Government improperly terminated this contract for default. such termination shall be deemed 

a termination for convenience 

Page (8 

TPD-CFP·12-C-0016 
370 


(n) Tille. Unless specified elsel'rflere in this contract title to items furnished under this contract shaD pass to the 

Government upon acceptance, regardless of when orwhere the Government takes p,ysical possession 

(0) wananty. The Contractorwarrants and impijes that the ~ems delivered hereunder are merchantable and fit 

for use forthe particular purpose described in this contract 

(p) Limitation of liability. Except as otherwise provided by an express warranty, the Contractorwill not be liable 

to the Government fo r consequential damages resuHing from any defect or deficiencies in accepted ~ems 

(q) Other compliances, The Contractor shall comply with aU appticable Federal, State and local lav.s, executive 

orders, rules and regulations appmcable to its performance under this contract 

(r) Compliance with Jaws unique 10 Govemmenlcontracls. The Contractor agrees to comply with 31 U.SC. 1352 

relating to limitations on the use of appropriated funds to ilfluence certa" Federal contracts; ~ relating to 

officials not to benel~: 40 US C 3701 el seq, Contract Work Hours and Safety Standards Act: 41 USC. 51 ·58 Anti· 

Kickback Act of 1986; 41 U,S.C, 265 and 10 U,S.C 2409 relatng to whislleblawer protections; 49 U.S,C. 401 18, Fly 

American; and 41 U.S g to procurement integnty 

(s) CXderof precedence, Any inconsistencies in this solicMon or contract shall be resolved by !Ping 

precedence in the follOl'.in g order 

(1) The schedule of supplies/services. 

(2) The Assignments, Disputes, Payments, Invoice, Other Compliances, and Compliance with Lav.s 

Unique to Government Contracts paragraphs of this Clause 

(3) The clause at 52,212·5 

(4) Addenda to this solicitation or contrac~ including any license agreements for computer software. 

(5) Solicitation provisions if this is a solicitation 

(6) Other paragra phs of this clause 

(7) The Standard Foon 1449 

(8) Other documents, exhibits, and attachments 

(9) The specrtication 

(t) Central Conlractor Registratioo (CCR). 

(1) Unless exempted by an addendum to this contract, the Contractor is respon i~e during performance and 

through final payment of any contract forthe accuracy and completeness of the data within the CCR database, and for 

any liability resutting from the Govemment's reliance on inaccurate or .,complete data, To remain registered in the 

CCR database after the innial registration, the Contractor is required to review and update 011 an annual basis from 

the date of initial registration or subsequent up:lates its informatKln in the CCR database to ensure n is current 

accurate and complete. Up:lating information in the CCR does notalter the terms and conditions of this contract and 

is not a bst~utefor a propeny executed contractual document. 

(2)(i) If a Contractor has legally changed its btlSiness name, 'doing 'oosiness as" name, or division name 

(I'rflichever is shown on the contract), or has transferred the assets used il performing the contract, but has not 

completed the necessary requirements regarding novation and cha ge~·name agreements in FAR Subpart 42. t2, 

the Contractor shall provide Ille respJnsible Contracting Officer a minimum of one business day's written notWication 

of its intention to (A) charoge the name in the CCR database; (6) comply with the requirements of Subpart 42, 12; and 

(C) agree il writing to the timeline and procedures specified by the responsible Contractng Officer. The Contractor 

must provide with the not~ication sufficient documentation to support the legally changed name. 

(ii) If the Contractorfails to comply with the requirements of paragraph (t)(2Ki) of this clause, or fails to 

perform the agreement at paragraph (t)(2)@C)ofthisdause, and, il lhe absence of a propel1y executed novation or 

change<lf·name agreement the CCR information that shews the Contractor to be other than the Contractor indicated 

in the contract will be considered to be inconect information within the meaning 01 the "Suspension of Paymenr 

paragraph of the electronic fu nds transfer (EFT) clause of this contract 

(3) The Contractor shall not cIlange the name or address for EFT payments or manual payments, as 

appropriate, in the CCR record to reflect an assignee for the purpose of assignment of claims (see Subpart 32.8, 

Assignment of Claims). Assignees shal be separately registered in the CCR database.l nformabon provided to the 

Contractor's CCR record that indicates payments, including those made by EFT, to an ultimate recipent other than 

that Contractor wi ll be considered to be incorrect information within the meaning of the 'Suspension of paymenr 

paragra ph of the EFT ctause oflhis contract 

(4) Offerors and Contractors may obtain information on registration and annual confirmation requirements via 

CCR accessed through http.s'/ilvwlv.acquisiticngovor by cal~ng 1--888--227·2423 or 269·961 ·5757 

Page (9 

TP[).CFP·12-C-0016 
371 


ADDENDUM TO 52,2124, CONTRACT TERMS AND CONDITIONS - COMMERCIAL ITEMS (FEB 2012) 

ELECTRONIC INVOICING AND PAYMENT REQUIREMENTS 

Internet Payment Platform OPP) is a secure web-based electronic invoicing and payment information service available 

to all Federal agencies and their supplier by the U,S. Treasur(s Financial Management Service. IPP allows Federal 

agencies and theirsuppliers to exchange electronic purchase orders, blanket POS, in~ces, and payment nformation 

in one easy to access web portal. This service is free of charge to government agencies and their suppliers, including 

services and support 

The preferred method fOI invoicing is IIlrough IPP. The IPP webs~e address is httos:llwMY,ipp,gov, Contractor 

assistance 'Nith enrollment can be obtained by contacting the Bureau of the Public Debfs IPP Team at 304·480·8000, 

OpUon 7 or IPP Production Help desk via email ipooroup@bosJrb,orgorphone(866)973-3131 . 

If the Contractor is unable to utilize IPP for submitting payment requests, invoices may be submitted electronically to 

lIle e·mail address shown in Bbck 18a, page 1 after completing the IPP Wa'Ner Form and subrrltting ~ via e·mal 10 

contractadministration@bcd.treasgov (see IPP Wa'r>ter Attachment) Adobe Acrobat Portable Document Format 

(PDF) and Microsoft Word are acceptable formats. Invoices shall contain the information required in FAR 52,212· 

4(9). 

Under this contract, the folo'Ning documents are required to be submitted as an attachment to the invoice 

None applicable 

PAYMENT AND INVOICE QUESTtONS 

For payment and nvoice questons, go to httos/1wMY ioo·90\l or contact the Accountng Services Division at (304) 

480-8000 opti:m 7 or via ema~ at AccountsPayable@bpd,treas,gov 

OVERPAYMENTS 

In accordance with 52.212·4 secbon (i) 5 Oierpayments Accounts Receivable Conversion 0( Check Payments to 

EFT: If the Contractor sends the Government a check to remedy dupicate contract financing or an overpayment by 

the governmen~ ~ v.ill be converted into an eiectronic funds transfer (EFT). This means the Government wil l copy the 

check and use the account nformation on ~ to eiectronically deM the Contractors account for the amount of the 

check. The deMfrom the Contractor's account wi l usually occur within 24 hours and wi ll be shown on the regular 

account statement. 

The Contractorwill not receive the original check back. The Govemment shall destroy the Contracto(s original check, 

but wi ll keep a copy of it If the EFT cannot be processed for technical reasons, the Contractor authorizes the 

Governmentto process the copy in place of the original check 

MARKING OF SHIPMENTS: 

The Contractor shall ensure the contract number and taskldel'Nery order number is clearly visible on all 

shippin!)'service documents, cootainers, and invoices 

1052.201·70 CONTRACTING OFFICER'S REPRESENTATIVE (COR) APPOINTMENT AND AUTHORITY (JUN 

2012) 

(a) The COR and the AHerna te COR are iden@edintheSF 1449, block 20. 

(b) Performance of mr\( under this contract is subject to the technical direction o(the COR dentified a'oove, 

or a representat'Ne designated in writing. The term 'technical direction' includes, without limitation, direction to the 

contractor that directs or redirects the labor effort, shins the mr\( between mr\( areas 0( Iocatons, and'or fins in 

details and otherwise serves to ensure that tasks oultined in the wor\( statement are accompished satisfactorily 

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(c) Technical direction must be within the scope of the contract spec~ication(s}AYorio:: statement. The COR 

does not have authority to issue technical direction that 

(1) Constitutes a change of assignment or add~ional worio:: outside the contract specification(s)/w::lrio:: 

statement; 

(2) Constftutes a change as defined in the clause enMed 'Charoges'; 

(3) In any manner causes an increase or decrease in the contract price, or the time ~qui~d for contract 

performance; 

(4) Changes any of the terms, coooitions, or speciflCation(s)/w::l1io:: statement of the contract; 

(5) Interferes with the contracto(s right to perform under the terms and corlditions of the contrac~ or 

(6) Directs, supervises or otheroYise controls the actions of the contractor's employees 

(d) Technical direction may be omlor in writing. The COR must confirm oral direction in writing within five 

workdays, with a copy to the Contracting Officer 

(e) The Contractor sha. proceed promptly with performance resuHing from the tecllnical direction issued by 

the COR. II, in the opinion of the contractor, any direction olthe COR or the designated representative laUs within the 

limitations of (c) aoove, the contractor shall immediately not~yth e Contracting Officer no later than the beginning 01 

the next Govemment work day 

(I) Failu~ 01 the Contractor and the Contractirog Officerto agree that technical direction is within the scope 01 

the contract shall be subjectto the terms of the clause entitled ·Oisputes.' 

1052,210·70 CONTRACTOR PUBLICITY (AUG 2011) 

The Contractor, or any entfty or representative acting on behalf of the Contractor, shall not refer to the equipment or 

services furnished pursuant to the provisions of this contract in any news release or commertial advertising, or in 

connection with any news release or commercial advertising, without first ottaining eJCpIicit written consent to do so 

lrom the Contracting Officer. Should any reference to such equipment or services appear in any news release or 

commercial advertising issued by or on behd of the Contractorwithout the requ ~d consent, the Government shall 

consider institut()n of all remedies available under applicable taw, including 3t U,S,C. 333, and this cootract, Further, 

any violation of this provision may be considered during the evaluaton of past performance in future competitively 

negotiated acquisitions. 

52.216·18 ORDERING (OCT 1995) 

(a) My supplies and services to be lumished under this contract shall be ordered by issuance 01 delivery 

orders or task orders by the individuals or activities designated in the ScIledule. Such orders may be issued from the 

IClIO contract date of award through a date to be identl ied at time of award 

(b) All delr.tery orders and task orders are subject to the terms and conditions of this contract. In the event 01 

conflict between a delivery order or task order and this contract the contract shall control 

(c) II mailed, a delivery order or task order is considered 'issued' wnen the Government dep:Jsits the order in 

the mail, Orders may be issued ora ny, by facsimile, or by electronic commerce methods only I authorized in the 

Schedule 

52.216·19 ORDER LIMITATIONS (OCT 1995) 

(a) Minimum arJer. When the Govemment requirtls supplies or services covered by this contract in an 

amount of less than $6000.00, the Government is not o~igated to purthase, nor is the Contractoro~;gated to furnish, 

those supplies or services under the contract 

(b) Maximum order. The Contractor is not obligated to honor-

(1) Any order for a single rtem in excess 0ISB,426,650.00; 

(2) Any order for a combination 01 ~ems in excess of 58,426,650.00; or 

(3) A series of orders Irom the same ordering office within 15 bllSiness days that together call lor quanUbes 

exceeding the imitaton in paragraph (b)(I) or (2) of this section. 

(c) If this is a requirements contract (i.e., includes the Requirements clause at subsection 52,216·2t oftfle 

Federal Acquisition Regulation (FAR)), the Government is not required to order a part 01 anyone requirement from the 

Contractor ~ that requirement exceeds the maximum-<lrder limitations in paragraph (b) of this section. 

(d) Notwithstanding paragraphs (b) and (c) of this section, the Contractor shall honor any order exceeding the 

maximum order limitations in paragraph (b), unless that order (or orders) is rtltumed to the ordering office within three 

(3) business days aner issuance, with written notice stating the Contractor's intent oot to shipthe item (or rtems) called 

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for and the reasons. Upon receiving this notice, the Gcwemment may acquire 1I1e supplies or services from another 

source 

52.216-22 INDEFINITE QUANTITY (OCT 19951 

(a) This is an indefin~e-<luan~ty contractfor1l1e supplies or services specified, and effec\M! forthe period 

staled, in the Schedule. The qua t~ es of supplies and services specified in the Schedule are estmates only and are 

nol purchased by Ihis contract 

(b) Deliv€ry or performance shal be made only as authorized by orders issued in accordance IVith the 

Ordering clause. The Contractor shall furnish to the Government, when and if ordered, 1I1e supplies or services 

specified in the Schedule up to and includiog the quantity designated in 1I1e Schedule as the "maximum." The 

Government sllall order at least the quantity of supplies or services designated in the Schedule as the "minimum' 

(c) Except for any limitations on quanbties in the Order Limitations clause or in the Schedule, there is no lim~ 

on the number of orders 1I1at may be issued. The Govemment may issue orders requiring deliv€ry 10 multipl€ 

destinations or performance at multiple locations. 

(d) Any order issued during the effectiv€ period of this contract and not completed within that period shall be 

completed by the Contraclorwithin the time specified in the order. The contract shall gcwem the Contractor's and 

Government's rights and obligations with respect to that order 10 the same extent as 11l1e order were completed 

during the contract's effective period; {X"Ovided, that the Contractor shall nol be required 10 make any deliv€ries under 

this contract after the 12-month base period and four (4) 12-month option periods. 

52.217-8 OPTION TO EXTEND SERVICE (NOV 1999) 

The Government may require continl!ed performance of any services within the li:nits and atlhe rates spec~ied in the 

contract These rates may be adjusted only as a resuH of re'lisions to prevailing labor rales provided by the Secretary 

of Labat'. The op:i:ln pro'lision may be exercised more than once, but the Iotal extension of performance hereunder 

shall nol exceed 6 months. The Contracting Officer may exercise the op:ion by written notice 10 the Conlractor IVithin 

30 calendar days before 1I1e contract expiration dale 

52.217-9 OPTION TO EXTEND THE TERM Of THE CONTRACT (MAR 2()OO) 

(a) The Government may extend the lerm of thiscontrac\ by written notice to the Contractorwithin the final 

30 calendar days of each contract period; provided 1I1at the Gcwernrnent gives the Contractor a preliminary written 

notice of its intenllo extend at least 30 calendar days before Ihe contract expires_ The preliminary notice does not 

comm~ the Gcwernment to an extension. 

(b) If the Gcwernmentexercises this option, the extencled contract shall be considered 10 inclucle this option 

clause 

(c) The total duration of this contract, including the exercise of any op:i:lns uncler this clause, shall not 

exceed fiv€ (5) years. 

CONTRACT TERM 

The period of performance is a 12·rronth base period and four (4) 12·rronth op:ion periods 

CONTRACT MINIMUM AND MAXIMUM 

(a) The minimum amount the Government is obligated to order during the term of tile contract is $1,622,800.00 

(b) The maxirrum amount of Ihe contract is 58,426,550.00. 

PAST PERfORMANCE EVALUATION 

This contract is subject to a performance evaluation 'lia The Contractor Performance Reporting System (CPARS) at 

WMY_cpars.csd.disa.mil. Following the end of each contract period and al contract completion, a completed 

Government evaluation shall be folWarded to 1I1e Contractor. The Contractor may subm~ written comments, if any, within the time period specified in 1I1e evaluation transmittal. The Contractors comments shal l be considered in the 

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issuance of the final evaluation document Any disagreement between the parties regarding the evaluation shall be 

forwarded 10 Ihe Bureau Chief Procurement Officer (SCPO) The final evaluation of the Conlractor's peliormance is 

the deciskln of the SCPO. A copy of the final pelionnance evaluabon report wi l be sent to the Contractor and 10 tI1e 

Govemment"s past peliormance database atVNNIppirs.gov 

52.212-5 CONTRACT TERMS AND CONDITIONS REQUIRED TO IMPLEMENT STATUTES OR 

EXECUTIVE ORDERS - COMMERCLAL ITEMS (APR 2012) 

(a) The Contractor shall comply m;h tI1e folkJ,ving Federal Acquisition Regulalkm (FAR) clauses, ....tlich are 

incorporated in this contract by reference, to implemenl provisions of law or Executrve orders applicable 10 

acquis~io s of commercial ~ems 

(1) 52.222-50, Combating Trafficktlg in Persons (Feb 20(9) m U.S.C. 7104f9l) 

_ AlterMte I (Aug 2(07) of 52.222-50 (22 U.S C. 71041ql). 

(2) 52.233-3 Protest After Award (AuG 1996) (31 U.S.C. 3553), 

(3) 52.233-4 Applicable Lawfor Breach of Contract Claim (OcT 2004) (Pub L. 108-77. 108-78) 

(b) The Contractor shall colTJjlly with tI1e FAR clauses in this paragraph (b) that the Contracting Officer has 

indicated as being incorporated in this contract by reference to implement provisions of law or Executive orders 

applicable to acquisitions of commercial ~ems: 

]_ (1) 52.203-6, Restrictions on Sulx:ontractor Sales to tI1e Government (Sept 2(06), with Alternate I 

(Oct 1995) (41 U.S.C 2530 and 10 US.C 24021. 

_ (2) ~ Contractor Code of 8usifl€ss Ethics and Conduct (Apr 2(10) (Pub. L. 110-252, Title VI, 

Chapter 1 (41 U.S.C. 251 note)) 

_ (3) ~ Whisfle!)OY/ef Protections under the Arnerican Recovery and Reinvestment Act of 2009 

(June 2010) (Section 1553 of PUb. L. 111-5). (Applies to contracts funded by the American Recovery and 

Reinvestment Act of 2009.) 

]_ (4) 52.204-10, Reporting Execulive Compensation and First-Tier Sul:contract Awards (FEB 2012) (Pub 

L. 109-282) (31 U.S.G. 6101 note) 

_ (5) 52.204-11 American Recovery and Reinvestment Act-Reporting Requirements (JuI2010) (Pub. L. 

111-5). 

]_ (6) 52.209-6 Protecting tI1e Government's Interest When Sul:contracting with Contractors Debarred, 

Suspended, or PrOp:lsed for Debarment (Dec 2010) (31 USC 6101 note) 

]_ (7) 52.209-9, Updates of Publicly Availa!)e Informaton Regarding Resp:lnsibility Matters (FEB 2012) (41 

US C. 2313). 

_ (8) 52.2og-10, Prohibition on Contracting with tnverted Domestic Corporations (section 740 of Division C 

of Pub. l. 111-117, section 743 of Division D of Pub. L 111-8, and section 745 of Division 0 of Pub. L 110-161). 

(Q) 52.219·3, Notice of HUBZone Set-Aside or Sole-Source Award (NOV 2011) (15 US.C. 657a) = (IO) 52.219-4, Notice of Price Evaluation Preference for HUBZone Small Business Concerns (JAN 2(11) 

(~the ofIerorelects to waive the preference, ~ shall so indicate tl its offer) (15 USC 657a) 

_ (II) (Reserved] 

_ (12)(i) 52.219.0, Nofice of Total Small Business Set-Aside (NOV 2011) (15 U.S.C. 644). 

_ Oil Memate I (NOV 201 1) 

_ Qii) A~emate II (NOV 2011). 

_ (13Xij 52.219-7, Notice of Partial Small Business Set-Aside (June 2003) (15 USC 644) 

_ Oi)Memate I (Oct 1995) of52.219-7. 

_ Qii) A~emate II (Mar 2004) of 52.219-7 

]_ (1 4) 52.219-8, Utilization of Small Business Concerns (Jan 2(11) (3)) 

_ (15)(i) 52.219-9, Small Business Subcontracting Plan (Jan 2011) 

_ (ii) Memate I (Oct 2001) of 52219·9 

_ Qii) Memate II (Oct 2001) of 52.219-9 

(iv) Atternate III (Jul2010) of 52.219·9 

- _ (16) 52.219-13, Notice of Set-Aside of Orders (NOV 2011)(15 U.S.C. 644(r)) 

_ (17) 52.219-14, limitatioflS on Sulx:ontracting (NOV 2011) (15 U.S.C. 637(a)(14)) 

_ (18) 52.219-16,liquidated Damages-Sul:contracting Plan (JAN 1999) (15 U.S.C. 637(d)(4XF)(i)) 

_ (19Xi) 52.219-23, Notice of Price Evatuation Adjustment for Sman Disadvantaged Business Concerns 

(OCT 2008) (10 U.S.C. 2323) (d the offeror elects to waive the adjustment, ~ shall so indicate in its offer). 

_ Qi) Attemate I (JUNE 2(03) of 52.219-23. 

_ (20) 52.219-25, Small Disadlrantaged Business Participation Program-Disadvantaged Status and 

Reporting (DEC 2010) (Pub. L. 103-355, section 7102, and 10 U.S.C. 2323). 

_ (21) 52.219-26, Smal D5advantaged Business Participation Program- tncentive Sul:contracting (OCT 

2000) (Pub. L. 103-355, section 7102, and 10 U.S.C. 2323). 

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_ (22) 52.219-27, Notice of Service·Disa~d Veteran-Owned Small Business Set·Aside (NOV 201 1) (15 

USC.657(f) 

]_ (23) 52,219·28, Post Award Small Business Program Representaton (APR 2012) (15 U.S.C. 632(a)(2)). 

_ (24) 52.219-29, Notice of Set-Aside for Economically DisadvantagedWomen-O.Yned Small Business 

(EOWOSB) Concerns (APR 2(12) (15 U.S.C. 637(m)). 

_ (25) 52.219-30, Notice of Set-Aside forWomen-ONned Small Business ('WOSB) Concerns Eligible Under 

the WOSB Program (APR 2012) (15 U,S,C. 637(m)). 

]_ (26) 52,222·3, Convict lalxlr (JUNE 2003) (E.O. 11755). 

_X_ (27) 52.222-19, Child Lalxlr-Cooperation.,.,;th AuthoMties and Remedies (MAR 2012) (EO 13126) 

]_ (28) 52.222·21 , ProhiMion of Segregated Facilities (FEB 1999). 

]_ (29) 52.222-26, Equal Opportunrty (MAR 20(7) (EO. 11246) 

] _ (30) 52.222·35, Equal Opportunity lor Veterans (SEP 2010X38 U,S.c. 4212) 

]_ (31) 52.222-36, Affirmative Acton for Workers .,.,;th Disabilrties (OCT 2010) (29 USC. 793) 

] _ (32) 52,222·37, Employment Reports on Veterans (SEP 2010) (38 U,S.c. 4212). 

]_ (33) 52.222·40, Notification of Employee Rights Under the National labor Relations Act (DEC 2010) 

(E,OI3496) 

_ (34) 52.222-54, Empoyment Eligibility Verification (JAN 20(9). (Executive Order 12989). (Not applicable 

to the acquisition of comrnercialy available off-the-sheH items or certain other types of commercial items as 

prescMbed in 22,1803,) 

_ (35Xi) 52.223·9, Estimate of Percentage of Recovered Material Content for EPA-Designated Items 

(MAY 2008) (42 U.S.C. 6962(c)(3)(A)(ii)). (Not applicable to the acquisition of commercially available off-the-she~ 

ijems,) 

_ ~i) AHem ate I (MAY 2(08) of 52.223-9 (42 US.C. 6962(i)(2)(C)) (Not applicable 10 the acquisition of 

commercially ava~able off-the-shelf ~ems ) 

_ (36) 52.223--15, Energy Efficiency in Energy-Consuming Products (DEC 2007) (42 U.S.C. 8259b) 

_ (37Xi) 52.223·16, IEEE 1680 Standard for the Environmental Assessment of Personal Computer Products 

(DEC 20(7) (EO. 13423) 

_ (ii) AHem ate I (DEC 2007) of 52.223--16. 

_X_ (38) 52.223·18, Encouraging Contractor Policies to Ban Text Messagillg While Driving (AUG 2(11) (E.O. 

13513). 

_ (39) 52.225-1 , Buy Amencan Act-8upplies (FEB 2009) (4 1 U.S.C, 10a·IOd) 

_ (40Xi) 52.225-3, Buy American Acl-Free Trade Agreements-Israeli Trade Act (MAR 2(12) (4t US.C 

chapter83, 19 U.S.C, 3301 note, 19 U,S,C. 2112 note, 19 U.S.C. 3805 note, 19 U.S.C. 4001 note, PUb. l. 103-182, 

Pub.l. 108-77, 108·78, 108·286, 108-302, 109-53, 109-169, 109-283, 110-138, and Pub. L 112-41) 

_ (ii) Afternate I (MAR 2012) of 52.225-3 

_ (ii i) Alternate II (MAR 2012) of 52.225-3 

(rv) AHernate II I (MAR 20t2) of 52.225-3 = (41) 52.225-5, Trade Agreements (MAR 2(12) (19 U,S.C. 2501 , et seq., 19 US.C, 3301 note). 

J_ (42) 52.225-13, RestrictioflS on Certain Foreign Purchases (JUNE 2008) (EO.'s, proclamations, and 

statutes administered by the Office of Foreign Assets Control of the Department of the Treasury). 

_ (43) 52.226-4, Notice of Disaster or Emergency Area Set-Aside (NOV 2007) (42 U.S.C. 5150) 

_ (44) 52.225-5, Restrictions on Subcontracting Outside Disaster or Emergency Area (NOV 2007) (42 

U,S,C. 5150). 

_ (45) 52.232-29, Terms for Financing of Purchases of Commerciaillems (FEB 2(02) (41 USC 255(f), 

10US.C, 2307(f)). 

_ (46) 52.232-30, Installment Payments for Commercial Items (OCT 1995) (41 US.C. 255(f), 10 US.C 

2307(Q). 

J_ (47) 52.232·33, Payment by Electronic Funds Transfer-Central Contractor Registration (OCT 2003) 

(31 U.SC. 3332) 

_ (48) 52.232-34, Payment by Electronic Funds Transfer-Olherlhan Central Contractor Registration 

(MAY 1999) (31 US.C 3332) 

_ (49) 52.232-36, Payment by Third Party (FEB 2010) (31 U.S.C. 3332) 

_ (50) 52.239-1, Privacy or Security Safeguards (AUG 1996) (5 U.SC 552a) 

_ (51)(i) 52.247-<34, Preference for Privately OMled 

_ (ii) Anernate I (Apr 2003) of 52.247-<34 

(c) The Contractorshall comply.,.,;th the FAR clauses in this para9raph (c), applicable to commercial 

services, that the Contracting Officer has indicated as being incorporated in this contract by reference to implement 

provisions of lawor ExecutM! orders appl;::able to acquisitions of commercial ~ems: 

_ (1) 52,222-41, Service Contract Act 0( 1965, (Nov 2(07) (4 1 U.S.C, 351 , el seq.~ 

_ (2) 52.222-42, Statement of Equivalent Rates for Federal Hires (May 1989) (29 U.S.C 206 and 

41 U,S,c. 351, ef seq.) 

TPQ.CFP-12-C-0016 

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376 


_ (3) 5?n2-43, Fair labor Standards Act and Service ContractAct-Price Adjustment (Multiple Year and 

Optioo Contracts) (Sep 2009) (29 USC. 206 and 41 US.C 351 et seq.) 

_ (4) 52 222-44, Fair labor Standards Act and Service Contracl Act-Plice Adjustment (Sep 2009) 

(29 US.C 2oo and 41 US.C 351 el seq.) 

_ (5) 52.222-51 Exemption from Appijcation of tMe Service Contract Act to Contracts for Maintenance, 

Calibration, or Repair 01 Certain Equip:nent-Requirements (Nov 2007) (41 U,S,C. 351 et seq.) 

_ (6)~, Exemption from Application of IMe Service Contract Act to Contracts for Certai1 ServicesRequirements (Feb 2009) (41 U.S.C 351 et seq,) 

_ (7) 52 226~ Prorrotng Excess Food Donatioo 10 NonprofilOrganizalions (Mar2009) (Pub. l. 110-247) 

_ (8) R2E:1.1. Accepting and Dispensing or SI Coin (Sept 2008) 11' USC. 5112{pl!ll) 

(eI) Comp/ro/JerGenera/ Examinal~n of Record. The Contractor shall comply with the provisions oflhis 

paragraph (d) if this contract was awarded using olher than sealed bid, is in excess of the mjll~ied acquisition 

threshold, and ooes not contain the clause at 52.215.2, Audit and Records-Negotiatioo 

(I) The ComptrollerGeneral of the United States, or an authorized representative olthe Comptroller General, 

shaD have access to and right to examine any of Ihe Contractor's directly pertinent records invoMng transactions 

related 10 this contracl 

(2) The Contractor shall make available at its offices at all reasonable times the records, materials, and other 

evidence IOf examination, audit, or reproduction, unlil3 years after final p!ymenl under this conlract orlor any shorter 

period specified in FAR Subp!rt 4.7, Contractor Records Retention, of the other clauses of this contract, If this 

contract is completely or p!rtialty terminated, the records relating to the mrk terminated shall be made available for 

3 years after any resulting final termination settlement Records relating to appeals under IMe disputes clause or to I~igation or the settlement of claims arising under or relating 10 this contract shall be made available until such 

appea l~igalioo , Of claims are finally resolved 

(3) As used in this clause, records include books, documents, accounting procedures and practices, and 

other data, regardless of type and regardless of form This does not require the Contractorto creale Of maintain any 

record thatlhe Contractor does not maintain i1 ttle ordinary course of business or pursuant to a jXOvision of law. 

(e)(I) Notv.ithstanding the requirements of the cIa uses in paragraphs (a), (b), (c), and (d) of this clause, the 

Contraclor is not required to flow dcwn any FAR dause, other than those in paragraphs (e)(I)(i) through (xi) of this 

paragraph ., a subcontract for commercial items. Unless otherwise indicated bebw, the extent of the flowdcwn shal 

be as required by the clauseW)52203-13, Contractor Code of Business Eth(:s and Conduct (Apr 2010) (Pub. L. 110-252, Title VI, 

Chapter 1 (41 USC 251 notel) 

(iij 52.219-8 Utilization of Small Business Concerns (Dec 2010) (15 U,SC. 637(d)(2) and (3l), in all 

subcontracts that offer further subcontracting opportunrties. If the subcontract (except subcontracts to smal rosiness 

concems) exceeds $650,000 ($1 .5 million fo r construction of any public facility), the subcootractor mllSt include 

~ in lo-wertier subcontracts that offer subcontracting opportunities 

(iii) [Reserved) 

(Iv) 52.222-26 Equal Opportunity (Mar 2007) (E.O. 11246). 

(v) 52222-35, Equal Opportunity for Veterans (Sep 2010) (38 U.SC 4212) 

(vi) 52.222-36 Affirmative Action for Workers with Disabnities (Oct 2010) (29 U.S.C. 793). 

(vii) 52.222-40 Not~ication of Employee Rights Under the National Laixlr Relabons Act (Dec 2010) (E.O. 

13496). FICIw down requ~ed in accordance with paragraph (f) of FAR clause 52.222-40. 

(vii) 52.222-41 Service ConlractAct of 1965 (Nov2007) (41 USC. 351 el seq.) 

(ix) 52.222·50, Combating Trafficking in Persons (Feb 2009) (22 U.SC. 7104(gl) 

_AHernate I (Aug 2007) of 52222-50 (22 USC. 71041g)). 

(x) 52.222·51 Exemption from Appl ication oflhe Service ContractAct to Contracts for Maintenance, 

Calibration, or Repair of Certain Equipment·Requirements (Nov 2007) (41 U.S.C 351 el seq.) 

(xi) , Exempl:ion from Appication olthe Service Contract Act to Conlracts for Certain ServicesRequirements (Feb 2009) (41 US.C 351 et seq.) 

(xii) , Employment Eligibi ~y Verif(:ation (JAN 2009) 

(xiii) 52.226-6 Promoting Excess Food Donation to Nonprof~Organjzalio s (Mar 2009) (Pub l. 110-247) 

Flowdown required in accordance with paragraph (e) of FAR clause 52.226-6. 

(xiv) 52 247~4 Preference for Privalely OMled U.S.-Flag Commercial Vessels (Feb 2006) (46 U.SC 

Appx. 1 241(b) and 10 U,S.C. 2631), Flow dcwn required in accordance with paragrapll (d) of FAR 

clause52247~4 

(2)While not required, the contractor may include in ~s subcontracts for commercial ~ems a minimal number 

of add~ional clauses necessary to sausfy its contractual obl9ations 

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CONTRACT DOCUMENTS, EXHIBITS, AND ATTACHMENTS 

DOCUMENTlEXHIBITI ATTACHMENT TITLE 

Attachment 1 ·11)0 Price Sciledule 

IPPWaiver Form 

Page 116 

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DEPARTMENT OF THE TREASURY 

CONSUMER FINANCIAL PROTECTION BUREAU 

INDEFINITE.QELlVERY INDEFINITE~UANTITY (IDIQ) STATEMENT OF WORK 

CONSUMER CREDIT INFORMATION PANEL 

1.(1 BACKGROUND 

The Dodd.frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) established the 

Consumer Financial Protection Bureau (CFPS) 

The Cllntral mission ofllle CFPB is to make markets for consumer financial products and services work for Americans 

-whether they are applying for a mortgage, choosing among credrt cards, or using any number of otr.erconsumer 

financial products, 

The CFPS is workir.g to give consumers lIle information they need to understand lIle terms of their agreements with 

financial companies CFPS is working to make regulations and guidance as clear and streamlined as possible so 

providers of consumer financial products and services can Mow the rules on theirown. 

Congress established the CFPB to protect consumers by carrying out Federal consumer financial laws Amor.g olller 

lIlings. CFPS: 

Conducts ru le-making, supervision, and enforcement for Federal consumer financial protectioo laws; 

Restricts unfair, deceptive, or abusive acts or pract,=:es; 

Takes consumer complaints; 

Promotes financial education; 

Researches consumer behavior, 

Monrtors financial markets for new risks to corlSumers; and 

Enfortes laws lIlat outlaw discrimination and olllel unfair treatment in consumerfinanCll 

2,« OBJECTIVE 

The CFPS seeks to acquire and maintain a nationally representative panel of credrt i:1formation on consumers for use 

in a wide range of policy research projects 

The panel shall be a random sample of consumer credit files attained from a national database of credit files. The 

Contractor shall provide an initial panel of consumers with htstorical information on a quarte~y basts, The Contractor 

shall provide an initial panel lllat goes back 10 years. Goingforward, the Contractor sJ'la11 provide updated consumer 

credit files for the consumers in the database on a quarterly basis 

3.0 SCOPE 

3,1 Panel Description' The Contractor sJ'la11 provide a national ly representative panel of consumers with 

consumer reporting information. The panel may be stralif~d atthe regional or state lewl, as delermined by lIle CFPS 

in consultation 'MIh the Contractor. If the sample is stratified, the Contractor shall provide lIle CFPB with information 

about the size of various populations within the Contractor's database such that the CFPS may construct weights to 

make lIle sample nationaly representative. The sample may be created either by sampUng at the consumer level or 

lIle household level, as determined by the CFPS in COrlSultation with the Contractor. lIthe sample is constructed at 

lIle household level, the Coillractor shall provide the CFPB with information about the size of various populations 

within the Contractor's dataoose such that the CFPS may construct weights to make the sallllie representative at the 

individual levet The Contractor shal have lIle capabil ity of including joint borrawers, co-signers, and authorized users 

as part of lIle panel. The panel sJ'la11 include 5 million consumers, and Joint borrowers, co-signers, and authorized 

users. The initial panel shall contain 10 years of h5torical data on a quarte~y baS5. The ~ial sample shall be drawn 

from current records and historical data appended for that sample as wel l as additional samples during the intervening 

years to make lIle combined sample representative at each point in time 

Page) 17 

TP[).CFP-12-C-0016 
379 


3.2 Panel Updales 

~ The Contractor shall provide quarterly updales. The Conlractor stlall have capaDl ity of providing account 

information. such as accoont balances. for lIle intervening monllls 

~ The Contractor shall be able to maintain representativeness ofllle panel OWlr ~me, willl respect to the 

Conlractor's primary credrt history database, such as through sampling new credit files and appendin g those 

samples to lIle panel. The Contractor shall deWlklp, in con u~ation with lIle CFPS a methodology lor 

periodically testing the representativeness on the panel. 

3.3 Data Chara cteristics 

~ The panel shal l contain the contents of the select consumers' credit files except lor data elements such as 

name, address, full account number, lIlat need to be masked to preserve confidentiality. The Contractor shall 

provide ZIP+4. or other geographic location information such as Census block identifier. and age or year 01 

birth, wtlen available. 

~ For each consumer in the panel, the Contractor shall provide credit scores as requested by the CFPB. 

>- The Contractor shall provide a persistent consumer identifier making it IXlssibie to fol low consumers oWlrtime 

in lIle panel The Contractor shall proYKIe a persistent trade line identifier making it pos sible to folklwtrade 

lines OYer time in the panel. 

The Contractor does not need to identify the fumis er/cred~or of particular trade lines, unless an approach to 

providing this information that is acceptable to the Contractor and the CFPB can be found. The Contractor 

shan, howeWlr, provide a means to identify wtlich trade tines come from the same fumisher1creditor, across 

consumer files 

> The contractor shal l provide non-credit demograp(1ic information about the consumers in the panel. 

3.4 Capabil ities 

~ The Contractor shall conduct surveys on particular products and subsets of consumers from the credit panel. 

>- The Contractor shall provide non-credit attributes to be i1cluded with their panel 

~ The Contractor shall design the panel so ~ can be linked to external data sets including demographic data 

3.5 Consu ~i g 

The panel shal l be fu lly supported by the Contractor's in-house data experts 

Page 118 

TP[).CFP-12-C-0016 
380 

381 

382 

383 

Q.15. Please provide a copy of a representative data request that 

the CFPB has sent to financial institutions and others involved in 

the Bureau’s consumer data collection efforts. 

A.15. ‘‘Any communications between the CFPB and a supervised financial institution or a Federal, State, or foreign Government 

agency related to the CFPB’s supervision of the institution’’ is ‘‘confidential supervisory information.’’ 12 CFR §1070.2 (i)(1). Consequently, specific supervisory requests for information are subject 

to the prohibition against disclosure of confidential supervisory information set forth in 12 CFR §1071.41. 

However, the Bureau uses a number of standard form information requests as part of its examinations. See, ‘‘Compliance Management System Information Request’’, attached. Examiners modify these requests to customize them to the particular institution. 

In the information request, examiners are instructed to specify the 

review period and the information or documentation required, in 

order to reduce the burden on the institution and avoid receiving 

data not relevant to the examination. See page 6 of the CFPB’s Supervision and Examination Manual, Examinations (Prepare and 

Send the Information Request) (available at http:// 

files.ConsumerFinance.gov/f/201210lcfpblsupervision-and-examination-manual-v2.pdf). 

The Bureau avoids receiving personally identifiable information 

whenever possible. The Bureau protects all confidential supervisory 

information in accordance with the regulation governing the Bureau’s handling of confidential information, 12 CFR Part 1070. 

Q.16. Has the CFPB conducted any cost-benefit analysis to determine the cost of the data collection requests and production on the 

institutions? Has the CFPB solicited feedback from any institutions 

about the cost of these data collection requests and production? 

A.16. The Bureau does not conduct an explicit cost-benefit analysis 

of supervisory data requests made in support of the examination 

function, as those requests are tailored to be consistent with the 

scope of information appropriate to carry out the purposes of supervisory activity. Pursuant to sections 1024(b) and 1025(b) of the 

Dodd-Frank Act, the Bureau coordinates its examinations with the 

prudential regulators and the State bank regulatory authorities; 

and, to the extent possible, the Bureau uses reports provided or required to be provided to Federal or State agencies. Both practices 

tend to reduce the cost of supervisory activities. The Bureau also 

routinely discusses its supervisory information requests with supervised entities in advance in order to make the best use of existing 

data formats and content, decreasing the burden to supervised entities of providing information requested by the Bureau. These 

interactions provide insight about how to acquire information efficiently. 

On occasion, the Bureau has also obtained data outside the supervisory process. The information has all been provided on a voluntary basis, and the Bureau believes the companies that provided 

this information attempted to do so in an efficient and cost-effective 

manner. For example, in connection with the Private Student Loan 

Report required by section 1077 of the Dodd-Frank Act, the Bureau 

met with major participants in the private student loan industry 

384 

and offered them the opportunity to provide data on several of the 

16 questions that Congress required the Bureau to answer. Nine 

lenders volunteered to provide their existing datasets to a single 

vendor that they selected. This vendor combined those data into a 

single database that did not include the identities of borrowers or 

lenders. This mechanism was an efficient way for the lenders and 

the Bureau to develop answers to Congress’ questions. Both the 

Bureau and the lenders continue to utilize that dataset to provide 

information to the public, to Congress, and to regulators about that 

industry. 

In some instances, the Bureau has requested financial institutions to provide a random sample of de-identified records rather 

than a full file. Sampling may add some cost to the financial institution but reduces the cost to the Bureau in handling larger files. 

In other instances, especially those involving ongoing data collections, the Bureau has determined that it would be more efficient 

for the financial institution to provide a full, de-identified file to the 

Bureau rather than requiring that sampling frames be created 

each time new data is provided. 

Q.17. In your testimony, you cite that GAO conducts an annual 

audit of the agency. Does the GAO specifically audit the Big Data 

collection undertaken by the CFPB? Does GAO audit the specific 

contracts of the outside, third-party vendors and their contractors 

hired by the CFPB for the collection of Big Data? Does GAO conduct any peer review of any research done using the Big Data? 

A.17. The GAO has not conducted an audit focused on the specific 

subject of data collection by the Bureau or Bureau contracts for 

such collection. However, the GAO’s and Inspector General’s audits 

and evaluations of the Bureau’s budget, information security, and 

implementation of the Dodd-Frank Act, among other subjects, address myriad aspects of the Bureau’s contracting and information 

collection, storage and usage activities. The GAO has not conducted 

any peer review of Bureau research, to the Bureau’s knowledge. 

Q.18. The CFPB issued a rule with regard to remittances to foreign 

countries last year, which the Bureau has updated on a couple of 

occasions since its issuance. The final rule on remittances contains 

a specific error resolutions procedure for remittance transfers. 

However, a recent blog posting by the Bureau suggested the CFPB 

will begin accepting consumer complaints on money transfers without distinguishing between foreign and domestic transfers. Is the 

blog posting a change in direction for the Bureau? Does the Bureau 

consider posting to its blogs as regulatory guidance or just an informational venue? Has the Bureau reached out to the industry to inquire what effect such blog postings have on the industry practices? 

A.18. Section 1073 of the Dodd-Frank Act amends the Electronic 

Fund Transfer Act to add a new provision governing remittances 

to foreign countries. One part of that amendment requires remittance transfer providers to resolve certain errors raised by consumers with respect to such remittances. Another part of the 

amendment requires remittance transfer providers to inform consumers of their rights concerning error resolution and of the Bureau’s contact information, including its toll-free consumer comVerDate Nov 24 2008 11:00 Jun 14, 2013 Jkt 048080 PO 00000 Frm 00392 Fmt 6602 Sfmt 6602 L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-A
385 

plaints number. The Bureau has issued implementing regulations 

as required by §1073 (the ‘‘Remittance Transfer Rule’’). 

Separately, §1013(b)(3) of the Dodd-Frank Act establishes within 

the Bureau ‘‘ . . . a unit whose functions shall include establishing 

a single, toll-free telephone number, a Web site, and a database or 

utilizing an existing database to facilitate the centralized collection 

of, monitoring of, and response to consumer complaints regarding 

consumer financial products or services.’’ Collecting, investigating, 

and responding to consumer complaints are integral parts of the 

Bureau’s work. 

In March 2012, the Bureau began accepting complaints about 

many types of bank and credit union products and services, including domestic money transfers and money transfers that will qualify 

as ‘‘remittance transfers’’ under the Remittance Transfer Rule 

when it takes effect on October 28, 2013, as well as the wide range 

of other types of products and services that these institutions offer, 

such as checking accounts and loans. In April 2013, the Bureau 

launched a money transfer-specific complaint form to accept complaints concerning entities other than banks and credit unions 

about domestic money transfers, as well as transfers that will qualify as ‘‘remittance transfers.’’ 

The purpose of the blog posting dated April 4, 2013, and titled 

‘‘Now accepting money transfer complaints’’ (available at http:// 

www.ConsumerFinance.gov/blog/now-accepting-money-transfercomplaints/), was to announce to consumers that the Bureau was 

now accepting these types of complaints through a dedicated complaint form. The blog provides consumers with a link to the form 

and lets them know what information they should have available 

before submitting a complaint. The blog post does not represent a 

change in direction for the Bureau; it is consistent with our use of 

the blog to engage and inform the public about Bureau activities 

and is not intended as legal guidance. 

The Bureau has engaged and will continue to engage with industry regarding its intake of money transfer complaints and welcomes 

feedback regarding the blog post. Similarly, the Bureau has 

reached out to industry and will continue to do so regarding the 

impact of the Remittance Transfer Rule. 

RESPONSES TO WRITTEN QUESTIONS OF 

SENATOR MENENDEZ FROM RICHARD CORDRAY 

Q.1. I held a hearing this month looking at some of the mortgage 

servicing abuses and the settlements that resulted. I was pleased 

to see the CFPB adopted new rules related to mortgage servicing 

standards in January 2013. I have long advocated for increasing 

consumer protections on borrowers before foreclosures, encouraging 

loan modifications, eliminating dual tracking, placing limits on 

foreclosure fees, and creating an appeals process for those denied 

loan modifications as well as a mediation program. Please detail 

some of the specific requirements as they relate to: 

• Mortgage servicers providing information about mortgage loss 

mitigation options to delinquent borrowers. 

386 

• Establishing policies and procedures for providing delinquent 

borrowers with continuity of contact with servicer personnel 

capable of performing certain functions. 

A.1. The mortgage servicing rules issued by the Bureau provide 

protections that seek to ensure that troubled borrowers receive a 

fair process to avoid foreclosure wherever possible. Most notably, 

the mortgage servicing rules include restrictions on the process of 

‘‘dual tracking’’; i.e., the consideration of a borrower for a loss mitigation option while pursuing a foreclosure process. The rules further include requirements for evaluating timely and complete loss 

mitigation applications for loss mitigation options. 

Even before the loss mitigation evaluation occurs, however, the 

Bureau has adopted requirements that will assist borrowers with 

the process of understanding and applying for loss mitigation options. First, the mortgage servicing rules include ‘‘early intervention’’ requirements that apply early in the loss mitigation process. 

The rules require servicers to reach out to borrowers about loss 

mitigation options early in a delinquency. Specifically, servicers are 

required to make good faith efforts to establish live contact with a 

delinquent borrower not later than the 36th day of a borrower’s delinquency and promptly inform such borrower about the availability of loss mitigation options if appropriate. Further, not later 

than the 45th day of delinquency, a servicer must provide a written 

notice to the borrower that includes, among other things, information about any loss mitigation options available to the borrower 

and how to apply for such options, information about contact personnel assigned to assist the borrower, and information regarding 

other resources that may be available to assist the borrower with 

loss mitigation options, such as housing counselors or organizations. 

This is designed primarily to encourage delinquent borrowers to 

work with their servicers to identify their options for avoiding foreclosure. The Bureau recognizes that not all delinquent borrowers 

who are contacted by their servicer and receive a written notice 

will respond to the servicers and pursue available loss mitigation 

options. However, the Bureau believes that the notices will ensure, 

at a minimum, that all borrowers have an opportunity to do so at 

the early stages of a delinquency. 

That is just the beginning of the process. The Bureau’s rules further require that servicers must have policies and procedures in 

place to provide delinquent borrowers with direct and ongoing access—the term of art is ‘‘continuity of contact’’—to personnel who 

are responsible for helping struggling borrowers. Such personnel 

must be assigned to assist a borrower by the time the early intervention written notice is provided, and in any event, no later than 

the 45th day of a borrower’s delinquency. The servicer’s policies 

and procedures must be reasonably designed to ensure that such 

personnel are able to provide information to the borrower about 

available loss mitigation options, the application process for such 

options, the status of any loss mitigation application submitted by 

a borrower, any applicable loss mitigation deadlines, and when a 

foreclosure process may begin. Further, the servicer’s policies and 

procedures must be reasonably designed to ensure that such personnel have access to a complete record of the borrower’s payment 

387 

history and information provided by the borrower regarding loss 

mitigation, that such personnel are able to provide this information 

to servicer personnel responsible for evaluating a borrower for loss 

mitigation options, and that such personnel can provide a borrower 

with information about the procedures for submitting a written notice of error or information request. 

Q.2. In June 2012, the CFPB announced that it would be the first 

Federal financial regulator to share with the public individual consumer complaint data. They are accepting consumer complaints in 

many areas, including checking accounts, savings accounts, CDs, 

credit cards, credit reporting, money transfers, mortgages, student 

loans, and consumer loans. How many complaints has the CFPB 

received from consumers so far about mortgages, credit cards, 

banks, debt collection, and other financial services? How many of 

those are being resolved successfully, and in what ways? 

A.2. The Bureau began accepting consumer complaints about credit 

cards on July 21, 2011. The Bureau now also accepts complaints 

related to mortgages, bank accounts and services, private student 

loans, other consumer loans, credit reporting, and money transfers. 

From July 21, 2011, through February 28, 2013, the Bureau received approximately 131,300 consumer complaints, including approximately 30,600 credit card complaints, 63,700 mortgage complaints, 19,800 bank accounts and services complaints, 4,600 private student loan complaints, 4,100 consumer loan complaints, and 

6,700 credit reporting complaints. The Bureau has received some 

money transfer complaints through the bank accounts and services 

intake form. In April 2013, the Bureau introduced a money transfer-specific intake form. Data from those complaints is preliminary. 

Data are also not available about debt collection or payday complaints because the Bureau does not accept these complaints at this 

time. The Bureau, however, continues to work toward expanding 

its complaint handling capacity to include other products and services, such as payday loans and debt collection. 

More than 109,200 complaints (83 percent of complaints) received as of February 28, 2013, had been sent by the Bureau to 

companies for review and response. The remaining complaints had 

been referred to other regulatory agencies (11 percent), found to be 

incomplete (3 percent), or were pending with the consumer or the 

Bureau (3 percent). Companies had already responded to approximately 104,100 complaints or 95 percent of the complaints sent to 

them for response. Consumers had disputed approximately 19,600 

company responses (21 percent) to complaints. 

As of February 28, 2013: 

• Credit card complaints: Approximately 27,700 (84 percent) 

credit card complaints had been sent by Consumer Response to 

companies for review and response. The remaining credit card 

complaints had been referred to other regulatory agencies (10 

percent), found to be incomplete (5 percent), or pending with 

the consumer or the Bureau (one percent). Companies had already responded to approximately 24,800 complaints or 96 percent of the complaints sent to them for response. Since December 2011, companies have had the option of reporting the 

amount of monetary relief, if any. The median amount of relief 

388 

reported was approximately $125 with $25 being the most common amount of relief for the approximately 5,300 credit card 

complaints where companies reported relief. Consumers had 

disputed approximately 4,200 company responses (18 percent) 

to credit card complaints. 

• Mortgage complaints: Approximately 56,800 (89 percent) mortgage complaints had been sent by Consumer Response to companies for review and response. The remaining mortgage complaints had been referred to other regulatory agencies (7 percent), found to be incomplete (1 percent), or pending with the 

consumer or the Bureau (2 percent). Companies had already 

responded to approximately 53,900 complaints or 95 percent of 

the complaints sent to them for response. The median amount 

of monetary relief reported was approximately $425 for the approximately 1,800 mortgage complaints where companies reported relief. Consumers had disputed approximately 10,500 

company responses (23 percent) to mortgage complaints. 

• Bank account and services complaints: Approximately 16,100 

(81 percent) bank account and service complaints had been 

sent by Consumer Response to companies for review and response. The remaining bank account and service complaints 

had been referred to other regulatory agencies (14 percent), 

found to be incomplete (4 percent), or were pending with the 

consumer or the Bureau (1 percent). Companies had already 

responded to approximately 15,500 complaints or 97 percent of 

the complaints sent to them for response. The median amount 

of monetary relief reported was approximately $110 for the approximately 4,000 bank account and service complaints where 

companies reported relief. Consumers had disputed approximately 3,000 company responses (20 percent) to bank account 

and service complaints. 

• Private student loan complaints: Approximately 3,400 (74 percent) private student loan complaints had been sent by Consumer Response to companies for review and response. The remaining private student loan complaints had been referred to 

other regulatory agencies (20 percent), found to be incomplete 

(4 percent), or pending with the consumer or the Bureau (2 

percent). Companies had already responded to approximately 

3,200 complaints or 94 percent of the complaints sent to them 

for response. The median amount of monetary relief reported 

was approximately $1,250 for the approximately 225 private 

student loan complaints. Consumers had disputed approximately 600 company responses (19 percent) to private student 

loan complaints. 

• Consumer loan complaints: Approximately 2,600 (63 percent) 

consumer loan complaints had been sent by Consumer Response to companies for review and response. The remaining 

consumer loan complaints had been referred to other regulatory agencies (30 percent), found to be incomplete (3 percent), 

or pending with the consumer or the Bureau (4 percent). Companies had already responded to approximately 2,400 complaints or 95 percent of the complaints sent to them for response. The median amount of monetary relief reported was 

389 

approximately $195 for the approximately 240 consumer loan 

complaints. Consumers had disputed approximately 500 company responses (23 percent) to consumer loan complaints. 

• Credit reporting complaints: Approximately 4,300 (64 percent) 

credit reporting complaints had been sent by Consumer Response to companies for review and response. The remaining 

credit reporting complaints had been referred to other regulatory agencies (4 percent), found to be incomplete (3 percent), 

or is pending with the consumer or the Bureau (28 percent). 

Companies had already responded to approximately 3,900 complaints or 90 percent of the complaints sent to them for response. Consumers had disputed approximately 600 company 

responses (19 percent) to credit reporting complaints. 

Q.3. At your confirmation hearing this year, I submitted questions 

for the record having to do with balancing the need for consumer 

protections and access to short term credit and building creditworthiness. As part of your response, you referenced the need to 

learn about the potential for innovation in financial products. A 

question that has not been answered is if nondepository short term 

lending is curtailed or eliminated, what products will take their 

place for underserved consumers? Can you update me on your efforts to address this issue and what is the status of the CFPB’s 

analysis of how to solve the growing problem of access to short 

term credit? 

A.3. The Bureau recognizes that there is a need for access to small 

dollar credit to handle occasional emergencies. But such loans can 

be harmful when they are poorly structured. For example, extremely short-term credit—meaning that the loan is structured so 

that the consumer has to repay the loan in a very short period of 

time—can be harmful to consumers. Furthermore, most small-dollar, short-term loans available to consumers now do not build creditworthiness. 

In light of these concerns, we strongly encourage consumers to 

explore their full range of options when dealing with a financial 

shortfall. We encourage consumers to consider less expensive credit 

options, particularly if they have an account at a bank or credit 

union or a stable credit history. Credit cards, advances, or emergency credit offered by employers, nonprofit organizations, and 

community groups are other options. Other options might include 

negotiating with the creditor or biller about the debt or bill they 

owe before resorting to a payday or deposit advance loan. 

Q.4. You stated in your answers to my questions that the CFPB 

is ‘‘determining which product structures and features may curtail 

sustained use and negative outcomes.’’ Has the CFPB made any inroads since then on this issue? Assuming the CFPB has or does 

identify negative outcomes and a product structure or feature that 

it believes may mitigate negative outcomes, how would the CFPB 

seek to require that product structure or feature of market participants? 

A.4. This past month, the Bureau released a white paper on payday loans and deposit advance products, which examined patterns 

of sustained use. We found that the median payday loan borrower 

engages in 10 such transactions per year and is indebted a median 

390 

of 199 days of the year, while more than half of all deposit advance 

borrowers end up borrowing more than $3,000 per year in advances 

and are indebted more than 40 percent of the year. However, we 

found that these products may be appropriate for some consumers 

for whom an expense needs to be deferred for a short period of 

time. The key for the product to work as structured, however, is 

a sufficient cash flow which can be used to retire the debt within 

a short period of time. 

The data presented in this study suggest some consumers use 

payday loans and deposit advances at relatively low to moderate 

levels. Thirteen percent of payday borrowers in our sample took out 

only 1–2 loans over the 12-month period, and about one-third took 

out six loans or less. A similar share of deposit advance users (30 

percent) took no more than a total of $1,500 in advances over the 

same period of time. We hypothesize that the lack of underwriting 

and the single payment structure may be contributing to these patterns of sustained use. 

We are currently undertaking additional analyses to see how outcomes vary under various State regulatory approaches, such as limits on maximum loan amounts or efforts to extend the period of the 

loan. We will evaluate whether these and other approaches may 

counter the effects of the traditional balloon payment structure 

that might lead consumers to quickly reborrow. Our current analysis seeks to determine the drivers of consumer harm, while also 

accounting for why some consumers are able to use these products 

in an appropriate way (for example, paying the full amount back 

when loan is due without having to reborrow). 

Q.5. Has the CFPB considered the implications of providing a Federal platform to regulate online short term lending in a manner in 

which some have argued that technology and the market can drive 

innovative new products for underserved consumers and help them 

build back their creditworthiness? For example, has the CFPB 

looked at the pros and cons of a model that provides for partnerships between banks and nonbanks to offer OCC or FDIC chartered 

financial products with CFPB consumer protections? 

A.5. The Bureau has not analyzed all of the proposals to provide 

Federal charters for nondepository financial service companies, and 

we generally do not comment on proposed legislation. Bureau staff 

does provide technical advice on specific provisions when requested 

by Congress. We do note that some of the bills we have reviewed 

have taken a very strong position in preempting all forms of State 

consumer protection of small dollar borrowers—moving all authority to regulate both charter issuance and consumer financial protection issues to Federal regulators. The States have invested substantial legislative and regulatory energy over many years in 

crafting protections that they view as appropriate for their consumers, so it would be a significant shift in public policy to sweep 

those protections aside. 

RESPONSES TO WRITTEN QUESTIONS OF SENATOR HAGAN 

FROM RICHARD CORDRAY 

Q.1. The Nationwide Mortgage Licensing System (NMLS) and Registry provides a single system for the licensing and registration of 

391 

the Nation’s mortgage industry. The System allows the States to 

track mortgage loan originators from State-to-State on a nationwide basis. State regulators have begun using NMLS as the licensing platform for other regulated nondepository financial services 

providers. 

Would you agree that it would be beneficial to extend the privilege and confidentiality protections for mortgage-related information contained in the NMLS and which is shared by State and Federal regulators, to information in the NMLS relating to all other 

types of nonbanks? 

A.1. The Bureau is committed to establishing and maintaining productive working relationships with State bank and nonbank regulators and understands the importance of protecting the confidentiality of information that may be shared through such coordination 

efforts. To this end, the Bureau has entered into information-sharing and cooperation MOUs, requiring the safeguarding of confidential information, with most State bank and nonbank regulators. 

Moreover, the Bureau recently entered into a State Coordination 

Framework to establish a process for coordinated Federal/State 

consumer protection supervision and enforcement of entities providing consumer products or services that are subject to concurrent 

jurisdiction of the Bureau and one or more State Regulators. 

The Bureau believes that steps to better facilitate the sharing of 

information among regulators by extending the confidentiality safeguards and privilege protections applicable to information placed in 

the Nationwide Mortgage Licensing System to additional nonbank 

activities could potentially be beneficial. We would be pleased to 

look at any specific proposal and provide technical assistance. 

Q.2. According to a Federal Trade Commission Report released in 

December, at least 5 percent of consumers had errors in their credit scores that could lead them to pay higher rates for loans. 

With the CFPB’s supervision of credit reporting companies beginning last year, do you believe that the appropriate controls are in 

place to the reduce the occurrence of errors? 

What steps are being taken to reduce the occurrence of these errors and improve the process of error correction? 

A.2. The Bureau’s authority to supervise larger consumer reporting 

agencies became effective in the fall of 2012. Among the Bureau’s 

first priorities has been to understand and evaluate the mechanisms used by consumer reporting agencies to collect consumer 

data furnished by industry, compile and match that data to individual consumer files, and then deliver that data to users in the 

form of consumer reports. The Bureau’s White Paper on ‘‘Key Dimensions and Processes in the U.S. Credit Reporting System’’ describes the Bureau’s initial insights into how the industry handles 

data. For example, in the report, the Bureau observed the limitations of the existing e-OSCAR dispute handling system, which does 

not forward the documents consumers attach in their complaints to 

furnishers. 

Through our Supervision program, which is in its early stages, 

we now have the opportunity to examine the larger consumer reporting agencies to assess their compliance with the Fair Credit 

Reporting Act and other Federal consumer financial laws. Our reVerDate Nov 24 2008 11:00 Jun 14, 2013 Jkt 048080 PO 00000 Frm 00399 Fmt 6602 Sfmt 6602 L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-A
392 

views will help us to evaluate the question you ask—are the controls in these companies appropriate to reduce errors. This issue is 

one we are focusing on in our review of consumer reporting agencies. 

Q.3. During your testimony you mentioned that the Bureau has addressed the issue of indirect auto lending in a very general way 

with a legal analysis and that it has not reached a factual conclusion about any particular instance. Can you describe the process 

through which the CFPB would move from a legal analysis to a factual conclusion? What types of statistical tools and proxies might 

be available to the Bureau to address data gaps and identify different groups of consumers? 

A.3. These questions about methodology and analysis are critical to 

the Bureau. As a data-driven organization, we want to be sure that 

our analysis of the auto finance industry is based on current and 

solid facts about the industry, its business practices, and its participants. In the past year, Bureau representatives have met with 

numerous individual lenders, auto lender associations, and dealer 

associations to learn about the industry and the statistical tools 

and proxies that industry uses to self-monitor its lending activity 

for fair lending risk. 

The Bureau’s ongoing supervision program enables it to examine 

fair lending compliance by many indirect auto lenders. We have enforcement authority over indirect auto lenders as well. The Bureau 

uses a variety of methods to identify legal violations and the choice 

of technique will often depend on the facts and circumstances. In 

the fair lending context, some violations can be determined by reviewing the text of an entity’s policies, while other violations are 

determined using other additional methods, like comparative file 

reviews or statistical analyses. 

Demographic information, such as race, sex, and ethnicity, are 

generally not collected by nonmortgage lenders but are vital to assessing fair lending compliance. Thus, Federal regulatory and enforcement agencies have long used proxy methods in nonmortgage 

data analyses. These methods are well accepted by economists and 

by regulators. Like other agencies, the Bureau also uses proxies for 

demographic characteristics. We have made clear that we base our 

proxies on publicly available data. For example, as a proxy for sex 

we use data on first names published by the Social Security Administration. For race and ethnicity, we use both surname and geographical data published by the Census Bureau. Various proxy 

techniques are publicly available in academic research, and we encourage indirect auto lenders to select a reasonable method and 

begin to examine their data, if they have not done so already. 

RESPONSES TO WRITTEN QUESTIONS OF SENATOR MORAN 

FROM RICHARD CORDRAY 

Q.1. The proposed rule to combine mortgage disclosures required 

by RESPA and TILA includes a requirement that consumers receive their closing disclosure 3 days before they actually close on 

their home. The proposed rule requires a second 3-day waiting period if there are any changes within 3 days of the scheduled closing. The proposed rule has very narrow exceptions for these last 

393 

minute changes. There are a lot of changes that can happen right 

before closing, sometimes the day of the closing on a final walk 

through of the property. Without flexibility in the regulation, retriggering a second 3-day waiting period could cause frustrating, 

costly and unwanted delays for consumers. A delay could cause 

higher costs, higher fees, lost deposits or earnest money if the real 

estate contract requires the deal to close by a certain date and lost 

interest rate lock. In situations where the consumer is going to be 

hurt financially or otherwise harmed or perhaps they do not desire 

a second 3-day delay, how can consumers be given more flexibility 

to avoid these costly delays? 

A.1. Based on what we have heard from consumers, lenders, and 

settlement agents, everyone is frustrated with the way closings are 

conducted today. One major source of this frustration is that consumers are first presented with certain critical information about 

their loans at the closing table. The proposal we are considering 

would require that consumers receive the final disclosure at least 

3 days before closing, so they have the time to review the disclosure in an unpressured environment. This is intended to ensure 

that all consumers have time to review, question, and understand 

their transaction before they have to sign on the dotted line. 

We understand, however, that sometimes things will change during the 3-day period between disclosure and closing. We also understand that not all changes justify delaying the closing date. Therefore, we proposed several exceptions specifying situations that 

would not trigger a second 3-day waiting period. One of these exceptions is for buyer and seller negotiations. For example, when a 

home is being purchased, the buyer typically performs a walkthrough inspection the day before the closing. If the buyer identifies repairs that need to be made, the buyer and seller may negotiate a change in the transaction to cover the cost of those repairs. 

Our proposal would not delay the closing for these types of 

changes. We also proposed an exception for increases in costs up 

to one hundred dollars. In addition, we proposed to allow consumers to waive the 3-day period in situations of personal financial 

emergencies. 

We understand your concern about delayed closings, which was 

also raised by numerous commenters. This is also a concern of the 

Bureau. Many of the comments on this issue suggested modifications to the proposed exceptions or the addition of new exceptions. 

We are reviewing these comments to determine the most appropriate way to provide meaningful consumer disclosure while, at the 

same time, avoid unnecessary delays in closings. 

Q.2. During your testimony to the Senate Banking Committee the 

following statement was made: ‘‘So the issue of indirect auto lending is one that, at this point, we address in a very general way 

with . . . a legal analysis that leads to a legal conclusion. It’s not 

yet a factual conclusion about any particular instance, although 

there’s a lot to be heard about this area as you go around the country and listen to people, both lenders and borrowers both.’’ Please 

reconcile this remark with, and explain the specific basis for (to include providing any supporting data), the public statements made 

by the CFPB in the fair lending guidance or the accompanying 

394 

press release that the Bureau issued on March 21, 2013. If this 

was simply a legal analysis, why was it released as a guidance and 

for what reason would lender be compelled to begin complying immediately? 

A.2. The legal analysis that the Bureau has undertaken, and that 

I referenced in my testimony, has focused on the question of whether and under what circumstances indirect auto lenders are creditors under the Equal Credit Opportunity Act (ECOA) and on the 

obligation that ECOA places on creditors to monitor the effect of 

their lending policies on protected classes. The Bulletin that the 

Bureau issued on March 21, 2013, contained the Bureau’s legal 

analysis and conclusions on those questions. The Bureau published 

that Bulletin in order to provide transparency to indirect auto lenders with respect to the Bureau’s perspective on these issues because that perspective will inform the examinations the Bureau 

conducts and will provide the legal framework that the Bureau will 

apply to the facts that the Bureau finds. 

These questions about methodology and analysis are critical to 

the Bureau. As a data-driven organization, we want to be sure that 

our analysis of the auto finance industry is based on current and 

solid facts about the industry, its business practices, and its participants. In the past year, Bureau representatives have met with 

numerous individual lenders, auto lender associations, and dealer 

associations to learn about the industry and the statistical tools 

and proxies that the industry uses to self-monitor its lending activity for fair lending risk. 

In a compliance bulletin published April 2012, the Bureau made 

clear that it would adhere to the fair lending principles outlined in 

Regulation B, the regulation originally promulgated by the Federal 

Reserve Board under ECOA. In particular, under the legal doctrine 

of disparate impact, a creditor may be responsible for a facially 

neutral policy or practice that is applied equally, if that policy or 

practice has, on a prohibited basis, a disproportionate adverse effect, unless the policy is justified by a ‘‘legitimate business need’’ 

that cannot reasonably be achieved as well by means that are less 

disparate in their impact. 

There are multiple steps in assessing whether a facially neutral 

policy or practice violates the law. The first step concerns whether 

the policy or practice has a disparate impact on a prohibited basis 

(i.e., disproportionately, adversely affects borrowers on the basis of 

race, sex, national origin, etc.). However, even if a policy has a disparate impact, the policy does not violate the law if there is a legitimate business need for the policy that cannot reasonably be 

achieved as well by an alternative that has a discriminatory impact. If, however, a creditor has a policy or practice that is not justified by a legitimate business need, or the need could reasonably 

be met by an alternative with a less disparate impact, then the Bureau can pursue corrective action through the supervisory process 

or through enforcement action. 

The evaluation of whether a facially neutral policy violates 

ECOA requires multiple steps and shifting burdens. Without applying all the requisite steps of the disparate impact analysis, the Bureau will not draw any conclusions about whether a facially neutral 

policy with a disparate impact on protected classes violates ECOA, 

395 

but the Bureau may note the existence of inadequately managed 

fair lending risk. 

Q.3. The guidance issued on March 21st of this year stated the following: ‘‘The supervisory experience of the CFPB confirms that 

some indirect auto lenders have policies that allow auto dealers to 

mark up lender-established buy rates and that compensate dealers 

for those markups in the form of reserve . . . . Because of the incentives these policies create, and the discretion they permit, there 

is a significant risk that they will result in pricing disparities on 

the basis of race, national origin, and potentially other prohibited 

bases.’’ Please explain in detail how indirect auto lender policies 

that allow auto dealers to ‘‘mark up’’ lender-established buy rates 

create ‘‘incentives’’ that result in a significant risk of disparate impact on a prohibited basis. Please provide any data, studies, or 

other materials that resulted in this conclusion. 

A.3. When a lender offers to pay higher compensation to a dealer 

if the dealer procures a higher-priced contract from a consumer, an 

incentive is creating to upcharge consumers. As a general matter, 

discretion in pricing can increase fair lending risk, as discussed in 

the Interagency Fair Lending Procedures, which have been adopted 

by all the Federal financial supervisors, including the Bureau. Discretion that is not properly controlled has often been a source of 

discriminatory disparities, both in auto lending and in other product markets like mortgage. Over the past decade, the Department 

of Justice has settled a number of cases in which discretionary 

pricing exercised by loan originators in wholesale transactions resulted in alleged disparities on the basis of race and ethnicity. In 

addition, evidence submitted in many private lawsuits from the 

last has revealed consistent disparities in markup that adversely 

affected African American and Hispanic borrowers. 

The March compliance bulletin provides guidance about compliance with the fair lending requirements of the Equal Credit Opportunity Act (ECOA) and its implementing regulation, Regulation B, 

for indirect auto lenders that permit dealers to increase consumer 

interest rates and that compensate dealers with a share of the increased interest revenues. The Bureau published the bulletin in 

part to provide clarity for indirect auto lenders that may have been 

operating under the incorrect assumption that they cannot be liable 

under the ECOA for pricing disparities caused by markup and compensation policies. 

Q.4. Mr. Cordray also stated to the Senate Banking Committee 

that there is a ‘‘possibility’’ that the Bureau would ‘‘write regulations’’ involving disparate impact in indirect auto lending. Please 

fully explain (i) what specific regulations the Bureau is considering 

writing, (ii) what specific determinations the Bureau would have to 

make before deciding to write such regulations, (iii) whether, and 

to what extent, the Bureau would coordinate with the Board of 

Governors of the Federal Reserve (FRB) and the Federal Trade 

Commission (FTC) as part of this process, and (iv) the most likely 

timetable for initiating this process. 

A.4. The Bureau is not planning on writing specific regulations on 

auto lending at this time. However, the Bureau is preserving its 

option to use rulemaking as one of the regulatory tools to ensure 

396 

that the market for auto lending provides fair, equitable, and nondiscriminatory access to credit for consumers. 

Any decision by the Bureau to write regulations on disparate impact in indirect auto lending would depend on an evaluation of our 

statutory authority and the Bureau’s view on the adequacy of existing regulations or other regulatory tools available to the Bureau to 

address risks to consumers arising from practices that may create 

disparate impacts in indirect auto lending. The Bureau would also 

consider the potential costs and benefits to, and potential impact 

on, consumers and industry stakeholders that would be covered by 

any potential regulations. 

The Bureau is committed to working closely with the prudential 

regulators and other Federal agencies, including the Board of Governors of the Federal Reserve (FRB) and the Federal Trade Commission (FTC), in conjunction with any decision to write auto lending regulations. With regard to auto lending in particular, the Bureau’s commitment to coordination with other regulators stems 

from a number of sources: (1) the Bureau’s statutory obligation to 

consult with prudential and other appropriate Federal regulators 

in the process of its rulemakings; (2) the fact that other Federal 

regulators, including the FRB and FTC, have significant regulatory 

authority over auto lending; and (3) the Bureau’s commitment to 

adopt regulations that both protect consumer interests, including 

access to credit, and preserve the ability of industry actors to pursue legitimate business objectives. 

The Bureau is continuing to review the operations of indirect 

auto lenders to ensure their compliance with fair lending and other 

Federal consumer financial laws. The future timetable for any decision to begin developing regulations would depend on the results 

of that review, our evaluation of all tools available to us to address 

risks involving disparate impact in auto lending, and our assessment of market dynamics. 

RESPONSES TO WRITTEN QUESTIONS OF SENATOR COBURN 

FROM RICHARD CORDRAY 

Q.1. The list of contracts provided by the Consumer Financial Protection Bureau (CFPB) in response to Questions for the Record 

(QFRs) from the March 12, 2013, nominations hearing included a 

large number of professional services contracts, including for professional management and consulting services. What kinds of services are these contracted firms performing and does CFPB have 

any processes in place to prevent duplication of functions between 

different professional services contracts or interagency arrangements? What metrics does CFPB use to assess the value it obtains 

from contracting with private firms and what is the frequency of 

this evaluation process? 

A.1. The Bureau does procure a variety of professional services and 

management consulting support, including strategy formulation, 

business initiative support, program/project management support, 

performance management support and performance improvements, 

contact center support, training, research, studies, and analyses. 

Early in our brief history, these services were often needed to support the Bureau’s stand-up operations. All Bureau contract awards 

397 

above $3,000 are reported, along with a description of the service 

or good, in the Federal Procurement Data System (FPDS). The 

FPDS system is publicly available and any contract listing or description can be accessed through the use of the FPDS Web site 

(www.FPDS.gov). 

The Bureau mitigates any risk of duplication of functions between different professional services contracts or interagency arrangements through various methods. The Office of Procurement 

maintains an award tracker or pipeline that is updated regularly 

and monitored through a weekly briefing and evaluation with all 

staff. The document provides a comprehensive listing of the Bureau’s planned and budgeted purchases, from origination to award. 

Managing the entire portfolio in this way allows for strategic 

sourcing decisions where needed and helps avoid redundancy between any planned or awarded agreements. The Bureau’s internal 

control sheet, which is needed prior to any expenditure above 

$3,000, provides additional risk mitigation. Before funds are released to the Office of Procurement, a control sheet is circulated 

from the Office of the Chief Financial Officer that requires cross 

functional approvals of the planned use of the funds. Investments 

above $100,000 are approved in advance by the Senior Procurement Executive, Chief Financial Officer, Chief Operation Officer, 

and Chief of Staff. Lastly, our Investment Review Board, chaired 

by the Chief Financial Officer and comprised of senior agency staff, 

reviews and approves planned investments above $500,000. 

The value that the Bureau obtains from contracting with the 

vendor community is described in the Contracting Officer Representative’s (COR) Monthly Performance Report. Each contract is 

assigned a COR at the time of award. CORs must take required 

training for certification and attend a monthly roundtable hosted 

by the Office of Procurement, which covers a variety of learning 

initiatives and best practice discussions. Further, each COR is responsible for submitting a Performance Report for monitored contracts exceeding $150,000 to the Office of Procurement on a monthly basis. Each monthly report details the vendor’s performance 

from the prior month and covers quality of service, cost control, 

timeliness of performance, and business relations. The Office of 

Procurement accumulates the individual reports and submits a 

comprehensive vendor scorecard to agency leadership, and the Office acts promptly to address any problems that appear in the 

monthly report. There is also a grading scale included in the scorecard that indicates change in performance from the previous 

month. 

Q.2. The Government Accountability Office (GAO) identified concerns during the creation of the Department of Homeland Security 

(DHS) that an overreliance on contractors performing work that 

are inherently Government functions created risks for Government 

and taxpayer interests (GAO-08-142T). What steps is CFPB taking 

to maintain visibility into the work that is being performed by private sector consultants and to ensure that consultants are not performing any work that should only be done by Federal employees? 

What kind of controls and oversight procedures does CFPB have in 

place for private contracting services that obtain sensitive information, such as private consumer credit data? 

398 

A.2. The Bureau utilizes a Service Contract Code Worksheet in 

order to maintain visibility into the work being performed by private sector consultants and to ensure consultants are not performing any work that should only be done by Federal employees. 

The Worksheet is in response to the Office of Federal Procurement 

Policy’s Policy Letter 11-01, which establishes requirements for review and management of service contracts over $25,000. The form 

is a workforce balancing tool and also requires a service need to be 

vetted through the Chief Human Capital Officer to ensure any 

service request is not inherently governmental. Procurements can 

only proceed if the form is approved by CHCO and the service is 

not considered inherent to the Government. 

Sensitive information is protected by the Bureau through specific 

controls. The Bureau includes contract language covering data 

rights usage for the development and production of any deliverable 

submission as a result of Bureau funding. The data rights language 

when utilized, allows the Bureau to govern access and distribution 

of any delivered data. Furthermore, vendors that may receive sensitive data in the course of performing contract requirements must 

sign a Non-Disclosure Agreement (NDA). The executed NDA does 

not allow a vendor to divulge any sensitive, unclassified or confidential information to any third party without the Bureau’s express approval. 

Q.3. Data provided in response to QFRs in March shows that 

CFPB is utilizing a number of contracts awarded by the Treasury, 

including sole source contracts. GAO has identified interagency 

contracting on its high risk list for many years due to problematic 

incentives it creates, including avoidance of competitive processes, 

conflicts of interest among participants in interagency contracts, 

and lack of adequate oversight. Please provide the specific justification for each case of why CFPB is utilizing contracts awarded by 

the Treasury. Among these, why have some of the interagency contracts been issued as sole source, rather than competed? How does 

CFPB coordinate with Treasury to ensure that proper oversight of 

interagency contracts is taking place? Is the CFPB paying fees to 

Treasury, or any other agency, that is providing contracting assistance? If so, what are the fee rates and what is the total amount 

of aggregate fees paid to each agency during FY2012 and FY2013? 

A.3. During the stand-up of the Bureau as part of Treasury, the 

Bureau was able to access and order services from existing Treasury vehicles when deemed appropriate. The decision to utilize certain Treasury contract agreements was considered efficient as the 

service requirements already considered competition and were 

awarded with fair and reasonable pricing. Such ordering lowered 

opportunity cost and enabled crucial support of emergent needs as 

the Bureau continued to stand up. Treasury agreements were utilized to order or provide for human capital support services, technology services, independent audit services, and administrative 

support services. Ordered pricing was evaluated and determined 

fair and reasonable prior to award. In addition to utilizing Treasury contracts, the Bureau has and continues to engage in an interagency agreement with Treasury Departmental Offices to leverage 

printing and graphics, events planning, lease, and technology supVerDate Nov 24 2008 11:00 Jun 14, 2013 Jkt 048080 PO 00000 Frm 00406 Fmt 6602 Sfmt 6602 L:\HEARINGS 2013\04-23 THE CONSUMER FINANCIAL PROTECTION BUREAU S SEMI-A
399 

port services. Most interagency agreements such as the agreement 

with Treasury were placed under the authority of the Economy Act 

per Federal Acquisition Regulation 17.502-2. When issued, interagency agreements are not subject to competition requirements as 

the agreement is between two Government agencies and determined to be in the best interest of the Government as the services 

cannot be obtained as conveniently or economically by contracting 

direct with private sources. If the agreement results in the other 

Government agency utilizing contract services, then any such 

agreements are subject to the competition rules of the FAR or procurement rules of that particular agency. 

Interagency contracts are jointly monitored by the participating 

agencies in the interagency contracts. The Bureau monitors interagency contracts similarly to contracts directly with private 

sources, ensuring services are provided within the contract terms 

and conditions. The Bureau also utilizes the contracting assistance 

of the Department of the Treasury’s Bureau of the Public Debt Administrative Resource Center (BPD–ARC). The procurement services of BPD–ARC are defined in an interagency agreement. The 

BPD–ARC staff serve as an extension of the Bureau’s internal Procurement team and are therefore managed as such. The procurement services cost $771,394 in FY2012 and $1,119,048 in FY2013. 

Q.4. For each contract or task order awarded on a sole source basis 

during FY2012 and FY2013, please provide the written justification 

from the contract file describing why the contract was awarded on 

a sole source basis, as well as a summary of the statement of work 

describing the purpose of the contract. 

A.4. See attached listing of sole source contracts with justifications 

included. 

400 


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Q.5. On March 21st, CFPB issued a guidance bulletin announcing 

that it will treat indirect auto lenders as creditors subject to the 

Equal Credit Opportunity Act (ECOA), specifically targeting ‘‘dealer markup and compensation’’ arrangements between dealers and 

lenders that may result in discriminatory pricing. CFPB’s usage of 

‘‘disparate impact’’ holds lenders liable for actions that have a discriminatory effect, even without discriminatory intent. Please provide a detailed methodology CFPB plans to utilize to analyze and 

identify cases of disparate impact in the indirect auto lending sector. 

A.5. These questions about methodology and analysis are critical to 

the Bureau. As a data-driven organization, we want to be sure that 

our analysis of the auto finance industry is based on current and 

solid facts about the industry, its business practices, and its participants. In the past year, Bureau representatives have met with 

numerous individual lenders, auto lender associations, and dealer 

associations to learn about the industry and the statistical tools 

and proxies that industry uses to self-monitor its lending activity 

for fair lending risk. 

In a compliance bulletin published April 2012, the Bureau made 

clear that it would adhere to the fair lending principles outlined in 

Regulation B, the regulation originally promulgated by the Federal 

Reserve Board under ECOA. In particular, under the legal doctrine 

of disparate impact, a creditor may be responsible for a facially 

neutral policy or practice that is applied equally, if that policy or 

practice has, on a prohibited basis, a disproportionate adverse effect, unless the policy is justified by a ‘‘legitimate business need’’ 

that cannot reasonably be achieved as well by means that are less 

disparate in their impact. 

There are multiple steps in assessing whether a facially neutral 

policy or practice violates the law. The first step concerns whether 

the policy or practice has a disparate impact on a prohibited basis 

(i.e., disproportionately, adversely affects borrowers on the basis of 

race, sex, national origin, etc.). However, even if a policy has a disparate impact, the policy does not violate the law if there is a legitimate business need for the policy that cannot reasonably be 

achieved as well by an alternative that has a discriminatory impact. If, however, a creditor has a policy or practice that is not justified by a legitimate business need, or the need could reasonably 

be met by an alternative with a less disparate impact, then the Bureau can pursue corrective action through the supervisory process 

or through enforcement action. 

The evaluation of whether a facially neutral policy violates 

ECOA requires multiple steps and shifting burdens. Without applying all the requisite steps of the disparate impact analysis, the Bureau will not draw any conclusions about whether a facially neutral 

policy with a disparate impact on protected classes violates ECOA, 

but the Bureau may note the existence of inadequately managed 

fair lending risk. 

Demographic information, such as race, sex, and ethnicity, are 

generally not collected by nonmortgage lenders but are vital to assessing fair lending compliance. Thus, Federal regulatory and enforcement agencies have long used proxy methods in nonmortgage 

data analyses. These methods are well accepted by economists and 

406 

by regulators. Like other agencies, the Bureau also uses proxies for 

demographic characteristics. We have made clear that we base our 

proxies on publicly available data. For example, as a proxy for sex 

we use data on first names published by the Social Security Administration. For race and ethnicity, we use both surname and geographical data published by the Census Bureau. Various proxy 

techniques are publicly available in academic research, and we encourage indirect auto lenders to select a reasonable method and 

begin to examine their data, if they have not done so already. 

Q.6. In Assistant Director Busette’s testimony during an April 26, 

2012, hearing in front of the Subcommittee on Oversight of Government Management, and again in a letter submitted to GAO on July 

3, 2012, references to a CFPB initiative titled the Financial Education Program Evaluation Project were made. According to the 

testimony and letter, this initiative would use rigorous quantitative 

methodologies to assess the effectiveness of existing Federal financial education programs. Does CFPB still plan to undertake and 

complete an analysis of existing Federal financial literacy programs? What metrics does CFPB use to assess the effectiveness of 

the agency’s financial literacy activities? What steps has CFPB 

taken to ensure its financial education programs do not overlap or 

duplicate the multitude of existing financial education programs 

identified by GAO? 

A.6. The Bureau is committed to ensuring that its activities are informed by data and analytics. As part of that effort, the Bureau’s 

Office of Financial Education (OFE) has launched its initial Financial Education Program Evaluation Project. Using rigorous quantitative methodologies, this project will assess the effectiveness of 

several existing financial education programs. We intend to use the 

insights from this study to provide direction to practitioners about 

how to design and support effective financial capability and money 

confidence programs. 

When the research is complete, we will understand whether 

these programs are effective in imparting personal financial management knowledge and skills to program participants, and if so, 

what elements account for this success. Our goal is to broadly 

share the results with Federal Government agencies and other nonFederal providers of financial education so that they can integrate 

the findings from this research into their offerings. At this time, we 

do not anticipate undertaking an assessment of other Federal Government agencies’ financial education. However, we will facilitate 

the sharing of programmatic best practices, evaluation methodologies, and common metrics that promote effective financial education among practitioners and other researchers. 

We use a variety of metrics to assess the effectiveness of our activities and each activity may have a different metric. For example, 

in the case of the Financial Education Program Evaluation project, 

we measure effective performance by the quality and timeliness of 

the project’s interim and final deliverables. For our tools and publications, we measure public demand for the materials by, for instance, the number of downloads or fulfillment requests. 

OFE is engaged in initiatives that advance financial education 

opportunities for American families in a manner that leverages and 

407 

complements existing Federal efforts. By meaningfully engaging 

with other agencies, including Financial Literacy and Education 

Commission (FLEC) partners, we work to delineate roles and responsibilities, to improve coordination, and avoid duplication while 

working to fulfill our statutory mandate to educate and empower 

consumers to make informed financial decisions. I serve as the 

Vice-Chairman of the Financial Literacy and Education Commission. OFE staff meets regularly with the Department of the Treasury staff members in the Office of Financial Education and Financial Access to ensure coordination. As you are probably aware, the 

GAO has recently indicated in its 2013 Annual Report: Actions 

Needed to Reduce Fragmentation, Overlap, and Duplication and 

Achieve Other Financial Benefits that all actions in the financial 

literacy areas contained within the two previous reports were addressed. 

The complex financial marketplace creates special challenges for 

consumers and requires a range of strategies and approaches. We 

are committed to thoughtfully focusing the talent of the Bureau on 

ensuring that American families understand the choices available 

to them as they manage their finances. We are equally committed 

to continuing our work with Federal agency partners to leverage all 

available resources, expertise, and opportunities for improving the 

financial well-being of consumers. 

408 

ADDITIONAL MATERIAL SUPPLIED FOR THE RECORD

SEMI-ANNUAL REPORT OF THE CONSUMER FINANCIAL PROTECTION 

BUREAU 

409 


Message from 

Richard Cordray 

Director of the CFPB 

At the Consumer Financial PrGtection Bureau, we are the nation's first federal ageru:y whose sole 

fOC\lS is protecting consumers in the financial marketplace. Weare dedicated 10 imprming the 

1i."es of e\'~ yday Americans. 

Two founding principles that lie at the heart (If the American dream are equal opportunity and 

the opportunily ((II" upward mooility. The consumer financial markets allow people to climb this 

economic ladder, and 01.11' job at the Bureau is 1(1 hold that ladder steady. 

This Semi-Annual Report reflects the Bureau's efJortsto dojust that. Througb e;w-handed and 

re3sonableo\'crsight of the market, the Bureau is working to make the market fair, transparent, 

and competitive, as the Dodd-frankAct directs us to do. Through our enforcement actions, we 

have obtained about $425 million in refunds forconsumers who were wronged by credit card 

companies. 

We have established a number of tools to equip consumers ",ith the information they need tl) 

make responsible financial decisioos. We h.weanswered nearlyl,ooo of consumers' JIl()I;t 

frequently asked questions, and if you have more questions, you can ask us at 

consumerfinance.gO\'1 AskCFPB. Our Financial Ad Shopping Sheet and Financial Aid 

Comparison Shopper ha\'e been helping students and their families better understand the 

student loan process. 

Coosumers deserve to be treated fairly and haw someone on their side when they are not. To 

that end, the Bureau has strengthened our Officeof Consnmer Responseand since our doors 

SEIoIhIoIIIIU'I. REPOIlT OF THE CFPS. MAAO! 2013 
410 


opened in July 2011, we have received over 100,000 consumer complaints from people seeking 

help on topics such as their m()rtgages, credit cards, bank products, student loans, and credit 

repGrting. 

Each day, we work to aocomplish the goal!; of rertrning consumers' trust in the marketplace and 

ensuring that fi nancial products and r.ervices help consumers climb that eronomic ladder of 

oppGrtunity. Any progress we are making is attributable to the hard work perfonned by our 

team - people of the highest caliber who are dedicated to public service and protecting American 

consumers. 

We \ook forward to continuing to fulfill C01\gress·s \ision of an agency dedicated to cultivating a 

consumer financial marketplace based on responsible practices, sound inllO\'ation, and excellent 

customer r.ervice. 

Sincerely, 

Richard Cordray 

SEIoI~ REPOIlT OF THE CFPS. MAAO! 2013 
411 


Table of Contents 

Message from Richard Cordray ................................................................................ 2 

1. Executive Summary ........ ,,,.,, ............................................................................... 7 

1.1 Consumer Challenges in Obtaining Financial Products and Services .... 8 

1.2 Delivering for American Consumers and Leveling the Playing Field .... 9 

1.3 Building a Great Institution .................................................................... 10 

2. Consumer Challenges in Obtaining Financial Products and 

Services .............................................................................................................. 12 

2.1 Consumer Concerns ................................................................................ 12 

2.2 Shopping Challenges .............................................................................. 36 

2.3 Shopping Channels ................................................................................. 37 

2-4 Product Complexity ............................................................................... ·39 

3. Delivering for American Consumers and Leveling the Playing 

Field .................................................................................................................... 40 

3.1 Resources for Consulners ...................................................................... 40 

3·2 Outreach .................................................................................................. 47 

3·3 Partnerships ...................................................... ·····································49 

4. Regulations and Guidance ................................................................................ 54 

4·1 Implementing Statutory Protections ..................................................... 54 

SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
412 


4.2 Interpreting and Streamlining Inherited Regulations; Facilitating 

Compliance with New Regulations ........................................................ 58 

5. Supervision ........................................................................................................ 60 

5.1 Supervisory Activities ............................................................................ 60 

5.2 Supervisory Guidance and Examination Procedures ............................ 62 

5.3 Information Sharing With State Regulators .......................................... 64 

5-4 Examiner Training and Commissioning ............................................... 64 

5·5 Technology ............................................................................................. 65 

6. Enforcement ....................................................................................................... 66 

6.1 Conducting Investigations ..................................................................... 66 

6.2 Public Supervisory and Enforcement Actions ....................................... 66 

7. F.ir Lending ....................................................................................................... 70 

7.1 Fair Lending Supervision ........................................................................ 71 

7.2 Fair Lending Enforcement ...................................................................... 72 

7.3 Interagency Fair Lending Coordination ................................................. 72 

8. Building. Gre.t Institution: Upd.te ................................................................. 74 

8.1 Open Government ................................................................................... 74 

9. Budget. ................................................................................................................ 76 

9.1 Howthe CFPB is Funded ........................................................................ 76 

10. Diversity and Excellence ................................................................................... 83 

10.1 Recruiting and Hiring ............................................................................ 83 

10.2 Staff Education, Training and Engagement .......................................... 85 

10.3 Diversity ................................................................................................. 86 

Appendix A: .............................................................................................................. 91 

SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
413 


More about the CFPB ....................................................................................... 91 

Appendix B: .............................................................................................................. 93 

Statutory Reporting Requirements ................................................................ 93 

Appendix c: .............................................................................................................. 95 

Significant Rules, Orders, and Initiatives ...................................................... 95 

Appendix D: ............................................................................................................ 101 

Actions Taken Regarding Rules, Orders, and Supervisory Actions with 

Respect to Covered Persons which are not Credit Unions or Depository 

Institutions .................................................................................................... 101 

Appendix E: ............................................................................................................. 103 

Reports .......................................................................................................... 103 

Appendix F: ............................................................................................................. 104 

Congressional Testimony ............................................................................... 104 

Appendix G: ............................................................................................................ 106 

Speeches ........................................................................................................ 106 

Appendix H: ............................................................................................................ 109 

Financial and Budget Reports ....................................................................... 109 

Appendix I: .............................................................................................................. 111 

CFPB Organizational Chart ............................................................................ 111 

Appendix J: ............................................................................................................. 112 

Defined Terms ................................................................................................ 112 

SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
414 


1. Executive Summary 

The Consumer Financial Protection Bureau (CFPB or Bureau) is the nation's first federal agency 

focused solely on consumer financial protection. 1 The Dodd-Frank Wall Street Refonn and 

Consumer Protection Act (Dodd-Frank Act) created the CFPS to protect consumers offinancial 

products and services and to encourage the fair, transparent and competitive operation of 

consumer financial markets. The Bureau's mission is to make consumer financial markets work 

for American consumers, honest businesses, and the economy as a whole. 

The CFPB proudly presents its third Semi-Annual Report to the President and to Congress, in 

fulfillment of its statutory responsibility and commitment to accountability and transparency. 

This report updates the Congress and the American people on the Bureau's mission, activities, 

accomplishments and publications since its last Semi-Annual Report2

, and additional 

information required by the Dodd-Frank Act.3 

I Previously, seven different federa l agencies were responsible for rulemaking, supervision, and enforcement relating 

to consumer financial protection. "The agencies which previously administered statutes transferred to the Bureau are 

the Federal Reserve Boord (and the Federal Reserve Banks), Department of HOIlSing and Urban Development (HUD), 

Federal Deposit Insurance Corporation (FDIC), Federal Trade Commission (FTC), National Credit Union 

Administration (NCUA), Office of the Comptroller of the Currency (ace), and Office of "Th rift Supervision (OTS). 

2 "The last Semi-Annual Report was published in July 2012 and may be viewed at 

http://files.consumerflllance.gov/f/20120'Ufpb .. Semi-AnnuaLReport.pdf. 

3 "The Semi-Annual Report primarily covers SLx -month increments beginning January 1st and July lSI. Certain 

sections ohhis report coverthe lime period belv.'een Janu31)' 1, 2012 and December 31, 2012. Appendix B prO\ides a 

gnide to the Bureau's response to the reporting requirements of Section IOI6{C) of the Dodd-Frank Act. 

SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
415 


The Dodd-Frank Act requires the CFPB to: 

Ensure that consumers have timely and understandable infonnation to make responsible 

decisions about financial transactions; 

Protect consumers from unfair, deceptive, or abusive acts and practices, and from 

discrimination; 

Identify and address outdated, unnecessary, or unduly burdensome regulations; 

Promote fair competition by consistent enforcement of the consumer protection laws in 

the Bureau's jurisdiction; and 

Ensure that markets for consumer financial products and services operate transparently 

and efficiently to facilitate access and innovation. 4 

The Bureau has continued its efforts to listen and respond to consumers and industry, to 

develop into a great institution worthy of the responsibility statutorily given to it by Congress, 

and to be a resource for the American consumer. 

1.1 Consumer Challenges in Obtaining 

Financial Products and Services 

In 2012, the Bureau sought input from consumers nationwide through different listening events, 

roundtables and town halls, and from our website, consumerfinance.gov, We seek to learn about 

their experiences with financial products and services, and collecting consumer input is an 

important step toward understanding consumer challenges in obtaining financial products and 

services in our troubling economic times, Consumer input is important for numerous reasons, 

including development of a research and data-driven agenda and various tools designed to help 

consumers of the financial services market obtain the products and services they need. We also 

desire to help the providers of those products and services comply with applicable regulations 

and keep the playing field fair for all participants. 

The Bureau has also continued to improve and expand the capabilities of its Office of Consumer 

Response to receive, process, and facilitate responses to consumer complaints, as well as 

4 See Dodd-Frank Act, Pub. L. No. 111-203, Sec. I021(b). 

SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
416 


establish a Consumer Complaint Database. The CFPB continually gathers data and information 

about consumers' behaviors, choices and experiences when they shop for financial products and 

how the market, market participants, and sales practices may influence the decisions that 

consumers make. 

1.2 Delivering for American Consumers 

and Leveling the Playing Field 

The CFPB continued to both develop and expand as a resource for consumers in 2012. For 

example, the CFPB's Consumer Education and Engagement Division developed and 

implemented initiatives to educate and empower consumers to make informed financial 

decisions. Its information-gathering efforu, educational tools, and reports include programs 

directed toward particular populations, such as service members, older Americans, and 

students. The Division OfSUpelVision, Enforcement, and Fair Lending focused its efforu in 2012 

on ensuring compliance with federal consumer financial laws and holding financial institutions 

accountable for their violations of those laws. The Research, Markets and Regulations Division 

focused its efforts on promoting markets in which consumers can shop effectively for financial 

products and selVices and finalizing a number of regulations implementing changes made by the 

Dodd-Frank Act to the laws governing various aspects of the mortgage market, including the 

origination and servicing of mortgages. While the various divisions of the Bureau play different 

roles in carrying out the Bureau's mission, they all work together to protect and educate 

consumers, keep the playing field fair for participants, and fulfill our statutory obligations under 

the Dodd-Frank Act. 

In 2012, the Bureau also: 

Engaged in extensive outreach to consumers and industry throughout the count!)'; 

Established advisory bodies, and initiated and developed partnerships with federal 

agencies, state financial regulatory entities, and state attorneys general; 

Implemented statutory protections for consumers who use consumer financial products 

and services, and continued the process of streamlining regulations that the CFPB 

inherited from other fede ral regulatory agencies; and 

Launched programs for supervising large banks, non-banks, and companies that provide 

consumer financial products and services, and investigated potential violations of 

consumer financial laws under the Bureau's jurisdiction. 

SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
417 


1.3 Building a Great Institution 

Many of these effort!; have taken place during the Bureau's first full yea r as an independent 

regula!!)!)' agency. As of December '5, 2012, the CFPB learn consisted of 1,073 employees 

lI'()fking tocarryout the Bureau's missioo. lt has IIUrl;ed to build a human and physical 

infl1lstructure that promCltes - and \1;11 continue to promote - trnnsparency, accountability, 

fairness, and service tothepublic. That includes: 

Demonstrating a strong commitment to openness and utilizing the Bureau's website \() 

share information (In its operations; 

Recruiting highly qualified personnel; 

Pro\iding training and enga&ement opportunities for eHe staff to imp['()\l! skills, 

increase knowledge, and maintain excellence; and 

Promoting dil'ersity in the CFPB's workforce and among its contractors, including 

through the Bureau's Officeof Minorityand Women Inclusion. 

CFPB "",pl<>yml at In All Hands )Ieetq in Allguot 1Ol2 

The CFPB is proud of the accomp~shments it achie>.ro. in 2012, but this marks only the 

beginni ng of the Bureau's work on behalf of consumers and providers of financi1ll prodllCts and 

services. In 2013, theCFPB's efforts t() makecolISumer financi1ll marketswOIk better \lill 

10 SEIoIhIoIIIIU'I. REPOIlT OF THE CFPS. MAAO! 2013 
418 


continue to expand. We invite you to visit the CFPB's website at consumerfinance.gov for 

updates on our work over the coming months. 

11 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
419 


2. Consumer Challenges in 

Obtaining Financial Products 

and Services 

The challenges consumers face in obtaining financial products and sClVices are a driving force 

behind the eFPS's efforts to make consumer financial markets work better. Listening and 

responding to consumers are integral components of our mission, and the Bureau provides 

numerous ways for consumers to make their voices heard. 

2.1 Consumer Concerns 

Financial markets are rooted in the daily lives and the financial and credit needs of individual 

Americans. Consumer financial products and sClVices, when understood and appropriately 

used, can bring broad benefits to consumers. Savings accounts are a first step to help people 

pursue their dreams, and checking accounts facilitate everyday transactions. Mortgages help 

people buy homes and pay for them over time. Credit cards give people convenient access to 

money when needed. Student loans allow people who lack means but have talent and ambition 

to pursue their deepest aspirations. 

Over the past year, consumers have shared with the CFPB their experiences - positive and 

negative - with financial products and services. Consumers have the opportunity to provide the 

CFPB with such feedback through a variety of forums, including, among others, the ''Tell Your 

Story~ feature on the CFPB's website, roundtables, town halls, and field hearings. This feedback 

is critical to our efforts to understand the challenges consumers face in obtaining the financial 

products and services they need. 

12 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
420 


The stories consumers have shared with the Bureau through "Tell Your Story" cover a wide 

range of financial products and services, and provide snapshots of consumers' day-t(}-day 

experiences in the financial marketplace, Consumers' stories are reviewed by CFPB staff and 

further the Bureau's understanding of current issues in the financial marketplace. They also 

supplement what we learn from listening to consumer complaints. 5 For example, consumers' 

stories about student loans echo the issues raised in the CFPB Student Loan Ombudsman's 

Annual Report about student loan complaints, The stories reflect consumers' fmstrations with 

loan origination and repayment, and often describe how these challenges have affected their 

day-to-day lives, as well as their long-term plans. 

Consumers have expressed how their lives have been negatively impacted by their student loan 

obligations. For example, some consumers have reported: 

Experiencing difficulty balancing paying for basic necessities (housing, food, 

transportation, healthcare) while having to repay student loan debt; 

Amassing credit card debt to cover shortfalls due to having to repay shldent loan debt; 

Delaying family planning (marriage, children) because of their debt burden; and 

Being fearful that their debt burden will prevent them from owning a home, saving for 

their children's education, and/or saving for retirement. 

Stories illustrate that the lives of borrowers' family members have been adversely affected as 

well: 

Parents and/or grandparents who cosigned for borrowers unable to repay their loans are 

now faced with having to repay these loans; 

Parents and/or grandparents who borrowed money to help their children and/or 

grandchildren pay for school are unable to repay the loans due to lost income; and 

Family members are harassed by debt collectors collecting on student loans, even if they 

did not cosign. 

In addition to "Tell Your Story," consumers have opportunities to voice concerns and share their 

experiences in person, Consumers and advocates have participated in large Bureau-sponsored 

5 Consumer complaints are submissions that express dissa tisfaction lIith, or communicate suspicion of wrongful 

conduct by, an identiftable entity related to a consumer's personal a~perience with a financial product or ser.ice. 

t3 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
421 


public events in Detroit, MI, st. Louis, MO, Seattle, WA, and Mountain View, CA6

, including 

town halls, field hearings and public meetings, focused on particular consumer finance issues. 

These events have drawn hundreds of participants, many of whom have shared their personal 

experiences with credit reporting, debt collection, and other consumer financial issues. 

The CFPB's Office of Community Affairs (OCA) has also hosted roundtable conversations with 

leaders of consumer, civil rights, community, housing, faith, student, women, and other 

organizations. The roundtables have provided opportunities for stakeholders to meet with 

Director Cordray and other key Bureau staff to share their ground-level perspectives on key 

consumer finance issues that affect their communities. 

Collecting, investigating, and responding to consumer complaints are integral parts of the 

eFPE's work, as Congress set forth in the Dodd-Frank Act.7 The Office of Consumer Response 

hears directly from consumers about the challenges they face in the marketplace, brings their 

concerns to the attention of companies, and assists in addressing their complaints . 

.. _-" .. ..-_.-.....-. r<l\s,.,,·nn 

[s-ch II 

HOME INSIDE THE CfPS GET ASSISTIo1ICE .unCl~ATE lAW! REGUlATION SUBMIT. COM~UJNT 

, _", sv'~~ ACOW",,,,", 

Submit a complaint 

Iiil Bank account or saMC. 

~ C,edltca.d 

r:i C .... 1t •• ponlng 

consumerfinance.gov/complainl 

6 BeIl'.l!eIl July I, 2012 and December31, 2012. 

7 See Dodd-Frank Act, Pub. L No. 111-203, Sa:. 1021(CX2). 

14 SEMI·ANNUAL REPORT OF THECFPB. MARCH 2013 

IlI:l I51 

CHECK YOUR COMrLAINT STATUS 

r , ... prt><!OI'''''''quojo." ......... 

...... oI.(6SS)~II·l372 
422 


The CFPB began Consumer Response operations on July 21,2011, by accepting consumer 

complaints about credit cards. Consumer Response now accepts complaints related to bank 

accounts and services, private student loans, mortgages, other consumer loans, and most 

recently, on October 22, 2012, it began handling credit reporting complaints. The CFPB 

continues to work toward expanding its complaint handling capacity to include other products 

and services, such as money transfers, payday loans, and debt collection. Consumers may also 

contact the CFPB with questions about other products and services. The Bureau answers these 

questions and refers consumers to other regulators or additional resources as appropriate. 

Consumer Complaint Database 

Thi.llXlltainsdata!r(m the t(RI$Umereredit eard complaints reeeivtd bytheO:nsumer Financial!'n)tecti(Jl Rurean. We dOl\(t verify 

the aceuraeyda11 /aetsal1eged in Ihese eomplainl!, but we dotakl! Slep;SlDtoofinn acommercial relatioosbip between thet(RI$Umer 

and the identified eompany. 

Cunplaintsue lisIed after tbecompanYrespa:ldsorafterthey have had the ccmplaintror 15ca1endardays, whiche\'erccmes first. 

Cunplainlscan be remCMd iftbeyd(Jl' meet all dthe paley 5btements publicati(Jl criteria. Data isrefreshed daily. 

Download, search, & visualize 

----- ---- •••• •••• I ••• 

----

_~L<!a}~ 

Example Yisualizations 

~ co nsumerfinance.gov / complaintdatabase 

15 SEMI·ANNUAl REPORTOFTHE CFPB, MARCH 2013 
423 


Information about consumer credit card complaints is available to the public, through the 

CFPB's public Consumer Complaint Database, launched on June 19, 2012,8 Initially populated 

with credit card complaints received by the CFPB, the database was expanded in October 2012 

to include consumer credit card complaints dating back to December 1, 2011. A complaint is 

listed in the database when the company responds to the complaint confirming a commercial 

relationship with the consumer, or after the company has had the complaint for 15 days, 

whichever comes first. Complaints can be removed if they do not meet all of the publication 

criteria. 

The database is live, updates daily, and contains certain individual complaint~ ev l data 

collected by the CFPB, including the type of complaint, the date of submission, the consumer's 

zip code, and the company that the complaint concerns. The database also includes information 

about the actions taken by a company in response to a complaint - whether the company's 

response was timely, how the company responded, and whether the consumer disputed the 

company's response. The database does not include confidential information about consumers' 

identities. Web~based and user-friendly features of the database include the ability to filter data 

based on specific search criteria, aggregate data in various ways, such as by complaint type, 

company, zip code, date, or any combination of available variables, and download data. 

Information from the database has been shared and evaluated on social media and using other 

new applications. 

In the summer of 2012, the CFPB asked for public comment on adding complaints about other 

consumer financial products and services under its authority to the Consumer Complaint 

Database and received a wide range of comments from interested stakeholders.

9 The CFPB 

continues to evaluate, among other things, the release of consumer narratives, the potential for 

normalization of data to make comparisons easier, and the expansion of functionality to 

improve user experience. 

8 In December 2011, the CFPB asked the puh/ic to comment on a proposed policy of making some credit ca rd 

complaint data publicly available. Afterconsidering those comments, the CFPB fina lized its policy for disclosing some 

of the data through its Consumer Complaint Database (Policy Statement). See Disclosure of Certain Credit Card 

Complaint Data, 77 Fed. Reg. 37,558 (June 22, 2012). 

9 In June 2012, the CFPB asked the public to comment on a proposed policy of duplicating the data disclosure 

practices described in the Policy Statement for consumer complaints about other consumer financial products and 

services .... ithin the Bureau'sjurisdiction. 77 FR 37616 (June 22, 2012). 

16 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
424 


2.1.1 How the CFPB Handles Complaints 

In keeping .... ith the CFPB's statutory re<lpons i~ tya d its commitment tGaccountabmty, the 

fl)UO\\ln& pa&es pfO'oide an overview of the handling and analysis of complaints receil-ed by 

Consumer ResponsefromJanuary I, 2012 through December31, 2012. 

Consumer Responsescreensall complaints submitted hYC()Ilsumer.;; based on sen~ral criteria, 

including whether the complaint falls lIithin the CFPB's primary enforcement authority, 

whether the complaint is complete, and whether the complaim is duplicative of a pri()l" 

submission bylhe same consumer. Screened complaints are forwarded ,ia a secure web portal 

to the appropriate company.l0 The company re\iews the inf()ffllation, communi cates with the 

consumer as needed,and determines what action to take in response. Then, the company 

repClrtS back to the consumer and the CFPB ,;a the secure ·company portal", and the Bureau 

invites the oonsumer to review the response and provide feedback. Consumer Response w.iews 

the feedback consumers provide about oompany responses, using this infonnation along with 

other information such as the timeliness (If the C1)Illpany's response, 11 f(lr example, to help 

prioritize oomplaints for invl!stigation. Consumers who hall! submitted complaints to the 

Bureau through Consumer Response can log (Into the secure "ronsumer portal" a'':Iilable on the 

eFPB's website, or call a toll-free number. 10 re<:enl! status updates, provide additional 

information. and rel'iew responses prolided to the conswner by the oompany. 

Throughout this process, subject-matter e:'Iperts help monitor certain complainlll. For e:'Iample, 

the Office of Servicemember Affairs coordinates on rompiainlll filed by sen.icemembers or their 

spouses and dependents. 

10 H • parliOlllar """plli.l d ... noI in, ... I1 ... prndud or madet lb.l " "i!hin l~. Bureau', jurisdidion. or & .. 1" 

"UTtntly btinghl.dled by It:. Bu .... u. Con"""" ~ refm it to ft.. appropriate rtglllolor. 

11 ll-.e CFPB tequesl, & .. 1 OOI:lpat.~ respot.d 10 oor:>p1oir.1S will-.in 15 r.alet,dardays. [f. com)'lllir:l car.noI be cbed 

within 15 Wet,dar days. • tOr.'lp8oy mayit.dicate & .. 1 ii, work 00 lheW':lJllainl i, "!n progress- tr.d p""';(\e. final 

"'"J'OU" wi&.in 60 OIludordays. 

11 SEM~ R'EPORTOFTHE CFP6.t.tAACH 2013 
425 


Consumer Response continually strive.<; to improve data quality and protect sensitive 

information, while increasingly making data about the complaints the CFPB receives available 

through reports toCongre.<;s and the public, and by sharing certain data with the public through 

the Consumer Complaint Database. 

16 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
426 


2.1.2 Complaints Received by the CFPB 

BetweenJanuary 1,20]2 and December 31, 2012, the CFPB received approximateiY91,oOO 

consumer compiaints. 12 

FIGURE 1: CONSUMER COMPLAINTS BY PRODUCT 

1% 4% I C,ed' "'port;'9 

Consumer loan 

Student loan 

- 17% 

Bank 

account 

and service 

The Dodd-Frank Act created the Office of Servicemember Affairs at CFr B to address the specific 

challenges faced by servicemembers, veterans, and their families (collectively 

"servicemembers~). It monitors complaints from servicemembers in conjunction with Consumer 

Response. Behveen January 1,2012 and December 31, 2012, approximately 3,500 complaints 

were submitted by servicemembers. 

12This analysis excludes multiple complaints submitted by a giW!D consumer on the same issue and whistleblower 

tips. All data are current as of January 1, 2013. Since laullchillg CollSumer Respollse operatiolls 011 July 21, 2011, the 

CFPB has received approo:imately 104,000 consumer complaints. 

19 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
427 


FIGURE2: SERVICEMEMBER CQMPLAJNTS BY PRODUCT 

- 5% 

Student loan 

- 15% 

Bank account 

and service 

Approximately 46% of all consumer complaints were submitted through the eFPS's website and 

9% via telephone calls. Referrals accounted for 34% of all complaints received, with the 

remainder submitted by mail, email, and fax. 

The tables and figures presented below show complaints by type, actions taken, company 

responses, and consumers' feedback about company responses. 13 

\3 Percentages may not sum to 100% due to rounding. 

20 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
428 


CONSUMERS' CREDIT CARD COMPLAINTS 

Table 1 shows the most common types of credit card complaints that the CFPB has received as 

reported by consumers. 67% of the approximately 18,600 credit card complaints fell into these 

10 categories. 

TABLE 1: MOST COMMON CREDIT CARD COMPLAINTS REPORTED BY CONSUMERS 

Complaint 

Billing disputes 14% 

Annual Percentage Rate (APR) or interest rate 

Credit reporting 8% 

Ident~y theftlFraudlEmbezzlemenl 7% 

Closing/Cancelling account 6% 

Collection practices 5% 

Other 5% 

Late fee 4% 

Credit card protection/Debt protection 4% 

Collection dett dispute 4% 

Credit Card CoJl1)laints in Top 10 Types 67% 

As the table illustrates, billing disputes are the most COIDIDon type of credit card complaint. 

Some consumers are confused and fmstrated by the process and by their limited ability to 

challenge inaccuracies on their monthly credit card billing statements. For example, some 

consumers realize only after their claim has been denied that they needed to notify their credit 

card companies within 60 days of any billing errors. In other cases, consumers are not aware 

that companies typically do not stop a merchant charge once the cardholder has authorized it, or 

do not override a merchant's "no-return policy." Other common types of credit card complaints 

21 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
429 


relate to annual percentage rates (APRs) or interest rates, credit reporting, and identity theft, 

fraud, or embezzlement. 

The CFPB generally has relied on the consumer's characterization of his or her complaint to 

identify its nature for analytical purposes. However, the CFPB's experience to date suggests that 

consumers may have differing interpretations of what these categories mean. For example, one 

consumer might choose to categorize a problem as a billing dispute, while another might 

identify the same issue as a concern with a provider's setting or changing of an interest rate. To 

improve our reporting on the data we receive, the Bureau is evaluating the use of these 

categories by col15umers to date and developing a simplified identification scheme to promote 

more consistent categorization of complaints. 

22 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
430 


CONSUMERS' MORTGAGE COMPLAINTS 

Figure 3 shows the types of mortgage complaints reported by consumers for the approximately 

45,200 mortgage complaints the CFPB has received. 

FIGURE 3: TYPES OF MORTGAGE COMPlAINTS REPORTED BY CONSUMERS 

Complamt 

Problems when you are unable to pay (Loan mocJjfica~on, coIiECtial, fae::losure) 57% 

Making .ooyments (Loan servicing, payments, escrow axoonts) 25% 

Applying for the loan (Applicatial, originator, mortgage broker) 8% 

Signif'9 the agreement (Settlement process and costs) 4% 

other 4% 

Receiving a credit offer (Credit decisioollJrderwriting) 2% 

Total Mortgage COfl'1)laints 100% 

23 SEMI·ANNUAl REPORT OF THE CFPB, MARCH 2013 
431 


The most common type of mortgage complaint concerns problems consumers face when they 

are unable to make payments, such as loan modifications, collections, or foreclosures. 

Consumers who have submitted these complaints generally appear to be driven by a desire to 

seek agreement with their companies on foreclosure alternatives. These complaints indicate that 

consumer confusion persists around the process and requirements for obtaining loan 

modification.s and refinancing, especially regarding document submission timeframes, payment 

trial periods, allocation of payments, treatment of income in eligibility ca\culation.s, and credit 

bureau reporting during the evaluation period. The shelf life of documents provided as part of 

the loan modification process is of particular concern to consumers. Although con.sumers must 

provide documents within short time periods and income documentation generally remains 

valid for up to 60 days, lengthy evaluation periods can result in consumers having to resubmit 

documentation - sometimes more than once, contributing to consumer fatigue and frustration 

with these processes. 

Other common types of mortgage complaints address issues related to making payments, such 

as loan seIVicing, payments, or escrow accounts. For example, consumers express confusion as 

to whether making timely trial period payments will guarantee placement into a permanent 

modification. Issues related to applying for the loan, such as the application, the originator, or 

the mortgage broker, are also among the most common types of mortgage complaints. 

24 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
432 


CONSUMERS' BANK ACCOUNT AND SERVICE COMPLAINTS 

Figure 4 shows the types of bank account and service complaints, such as complaints about 

checking and savings accounts, re{Xlrted by consumers for the approximately 15,700 complaints 

received by the CFPB. 

FIGURE 4: TYPES OF BANK ACCOUNT AND SERVICE COMPLAINTS REPORTED BY CONSUMERS 

6% 

Using a debit or 

ATM card I 

_ 10% 

Sending or 

receiving 

payments 

- 16% 

Problems 

caused by 

low funds 

Complaint % 

Account opening, closing, or management (Confusing marke~ng, denial, disclosure, 

fees, closure, interest, statements, joint occounts) 

OeJXlS~S aoo withdrawals (Availability r:i dep:)sits, withdrClWal proo/ems and 

penalties, unalAtmzaJ transactions, chf£k Cashing, payroll deposit prcb/ems, lost 

ex missing fuOOs, traflSaGtion OOIds) 

Problems caused by my funds being low (Overdraft fees, late fees, tounced checks, 

crOOit reporting) 

Making or receiving payments, sending money to others (PrOOlems with payments 

by cfler;k, card, ph<:ne (y online, unauthct"ized or fraudulent tratlsechons, 

mooeYNl/lfe transfers) 

Using a debit or ATM ca rd (Disputed transection, unauthxized card use, ArM (( 

debit card fees, ArM problems) 

25 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 

41% 

27% 

16% 

10% 

6% 
433 


Total Bank Account and Service Complaints 100% 

As the table iIIustrat£'.'i, the most common type of bank account and service complaint relat£'.'i to 

opening, closing, or managing the account. These complaints addr£'.'is issues such as confusing 

marketing, denial, fees, statements, and joint accounts. Other common complaints relate to 

deposit and withdrawal issues, such as transaction holds and unauthorized transactioll'l, and 

problems caused by the consumer's funds being low, including bounced checks, overdraft and 

late fees, and credit reporting. Many consumers remain frustrated .... 1th overdraft fees and the 

wide discretion companies have to assess these and other fees, so long as the fees are outlined in 

account agreements. Similarly, some consumers express frustration when some companies 

process larger withdrawal transactions before smaller ones, which can generate more overdraft 

fees. 

26 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
434 


CONSUMERS' STUDENT LOAN COMPLAINTS 

Figure 5 shows the types of student loan complaints reported by consumers for the 

approximately 3,900 student loan complaints received by the CFPB. 

FIGURE 5: TYPES OF STUDENT LOAN COMPLAINTS REPORTED BY CONSUMERS 

5% 

Getting a loan 

I 

Complaint 

Repaying your loan (Fees, bi/lir)J, ooferment, fabeararx:e, fraud, credit reportifYJ) 

Problems when you are unable to pay (Default, debt co/Ja;tion, bankruptcy) 

Getting a loan (Confusir¥) terms, rates, denial. CoofU5iIYJ advertisir)J or 

marketifYJ, sales tactics or pressure, financial aid services, recruiting) 

Total Student Loan Complaints 

64% 

31% 

5% 

100% 

The most common type of student loan complaint relates to repaying the loan, such as fees, 

billing, defennent, forbearance, fraud, and credit reporting. Consumers struggle with the limited 

payment deferment options permitted in their loan agreements, especially when they have not 

found employment by the time they must begin repaying their loans, and because deferments 

often are limited to six months. Another common type of complaint addresses problems 

27 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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consumers confront when they are unable to pay, such as issues related to default, debt 

collection, and bankmptcy. 

28 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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CONSUMERS' CONSUMER LOAN COMPLAINTS 

Figure 6 shows the types of consumer loan complaints, sllch as complaints about installment 

loans, vehicle loans and leases, and personal lines of credit, reported by consumers for the 

approximately 3,200 consumer loan complaints received by the CFPB. 

FIGURE6: TYPES OF CONSUMER LOAN COMPLAINTS REPORTED BY CONSUMERS 

9% 

Shopping for the loan 

I 

Complaint 

- 18% 

Taking out 

the foan 

Managing the loan, lease, or line of credit (Billing, late fees, damage or loss, insurance 

(GAP, credit, etc), credit repating, priva:y) 

Problems when you are unable to pay (Debt collection, repossession, set-df fran bank 

axount, deficierr:y, bankruptcy, default) 

Taking out the loan or lease f Account terms and changes (Term changes (mid-deal 

cha(1Jes. cha(yJes after cloSirfJ, rates. fees, etc.), required ackJ-on procJucts, tracJe.in 

paycif, fraud) 

Shopping for a loan, lease, or line of credit (Sales tactics or pressure, cffdit denial, 

ccnfusing advertisirq ex marketirq) 

Total Consumef Loan Complaints 

29 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 

49% 

24% 

18% 

100% 
437 


The table illustrates that the most common type of consumer loan complaint pertains to 

managing the loan, lease, or line of credit. Another common type of complaint addresses 

problems consumers have when they are unable to pay, including issues related to debt 

collection, bankruptcy, and default. 

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CONSUMERS' CREDIT REPORTING COMPLAINTS 

Figure 7 shows the types of credit reporting complaints reported by consumers for the 

approximately 3,300 credit reporting complaints the CFPB has received.]4 

FIGURE7: TYPES OF CREDIT REPORTING COMPLAINTS REPORTED BY CONSUMERS 

Complaint 

2'1\ 

00" 

I 

3'1\ I Credit monitoring or identity protection 

I 3'1\ r---Improper use of credit report 

--7'1\ 

Unable to obtain 

Incorrect information on credit report (Information is 001 mine, Account terms, Account status, 

Perswai informatictl, Public rocord, Reinsetted previously deJeted informatiCtl) 

Credit re~rtirg company's investigation (Investigation t()()/{ too /ooJ, Did oot get pr~ notice 

d investigaticrl status or results, Did net receive ada:!uate help CHef the phcre, Problem with 

statement of dispute) 

Unable to get my credit report or credit score (PrcbJem geltirtg free annual repro, Problem 

geffirYJ report or credit seae) 

14 ConSllmer Response began handling credit reporting rompiainlson October 22, 2012. 

31 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 

73% 

7% 
439 


Improper use of my credit rel>'Jrting (Repat improperly sharEd by credit repatirq canpany, 

ReceivEd marketing cifers after oplifYJ out, Report provided to employer witfk:Jut written 3% 

authcrization) 

Credit monitoring or identity protection services (Problem cance/lifYJ or closing account, 8illifYJ 

dispute, ReceivilY,/ unwantEd marketing or adverlisifYJ, Account or product terms and 3% 

changes, Prcblem with fraud a/erls) 

Other 2% 

Total Credit Reporting Complaints 100010 

This table illustrates that the most common type of credit reporting complaint is about incorrect 

information appearing on the consumer's credit report, such as information that is not the 

consumer's, incorrect account status, and incorrect personal information. Another common type 

of complaint is about issues with credit reporting companies' investigations of information 

disputed by consumers. 

HOW COMPANIES RESPOND TO CONSUMER COMPLAINTS 

Approximately 75.400 (or 83%) of all complaints received behveen January 1, 201 2 and 

December 31, 2012 were sent by Consumer Response to companies for review and response. IS 

Table 2 shows how companies responded to these complaints during this time period. 

Company responses include descriptions of steps taken or that will betaken, communications 

received from the consumer, any follow-up actions or planned follow-up actions, and 

categorization of the resJXlnse. Based on industry comments received about disclosure of credit 

card complaint data, beginning June 1, 2012, response category options included "closed with 

monetary relief, ~ ~closed with non-monetary relief," "closed with explanation," "closed," "in 

progress," and other administrative options. Monetary relief is defined as objective, measurable, 

and verifiable monetary relief to the consumer as a direct result of the steps taken or that will be 

taken in response to the complaint. "Closed with non-monetary relief indicates that the steps 

taken by the company in response to the complaint did not result in monetary relief to the 

IS The remaining complaints haw been referred to other regulatory agencies (11%), found to be incomplete (3%), or 

are pending with the consumer or the CFl'B (1% and 3%, respectiwly). 

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consumer that is objective, measurable, and verifiable, but may have addressed some or all of 

the consumer's complaint involving non-monetary requests. Non-monetary relief is defined as 

other objective and verifiable relief to the consumer as a direct result of the steps taken or that 

will be taken in response to the complaint. "Closed with explanation" indicates that the steps 

taken by the company in response to the complaint included an explanation that was tailored to 

the individual consumer's complaint. For example, this category would be used if the 

explanation substantively meets the consumer's desired resolution or explains why no further 

action will be taken. Tlosed ~ indicates that the company closed the complaint without relief -

monetary or non-monetary - or explanation Consumers are given the option to revie\v and 

dispute all company closure responses. 

TABLE 2: HOW COMPANIES HAVE RESPONDED TO CONSUMER COMPLAINTSI6 

Bank account student Consumer Credit 

All Credit card Mortgage and service loa n loan reporting 

75,400 15,700 39,500 13,000 2,900 2,100 2,000 

Company reported 

closed with 65% 56% 72% 57% 71% 66% 59% 

explanation 

Company relXlrted 

closed with 15% 29% 5% 28% 7% 12% 1% 

monetary relief 

Company reported 

closed with non· 9% 8% 10% 5% 11% 9% 16% 

monetary relief 

Company 7% 4% 8% 5% 8% 8% 23% reviewing 

16 While companies' responses under previous categoriza tions were maintained, for operational and reporting 

purposes, responses categorized as fun resolution provided," "partial resolution provided," and "closed with relief' 

are considered a subset of "dosed with monetary relief," and responses calegorized as "no resolution provided" and 

"dosed wit bout relief' are calegorized as "dosed with explanation." 'Closed wilb non-monetary relief' and "dosed" 

reflect only those responses provided by companies after June I, 2012. 

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Company provided 

administrative 3% 2% 3% 3% 2% 2% 1% 

response 

Company reported 

closed (without 2% 1% 2% 3% 1% 4% 0% relief or 

explanation) 

100% 100% 100% 100% 

Companies have responded to approximately 95% of complaints 17 sent to them and report 

having closed 90% of the complaints sent to them. Table 2 shows how companies have 

responded. 

Beginning December 1, 2011, companies had the option to report an amount of monetary relief, 

where applicable. In 2012, companies have provided relief amounts in response to more than 

9,300 complaints. The median amount of relief reported by companies was $145; however, 

company reports of relief amounts and medians vary byproduct. For the approximately 4,100 

credit card complaints where companies provided a relief amount, the median amount of relief 

reported was approximately $123. For the approximately 1,400 mortgage complaints where 

companies provided a relief amount, the median amount of relief reported was approximately 

$413. For the more than 3,300 bank account and service complaints where companies provided 

a relief amount, the median amount of relief reported was approximately $105. For the 

approximately 200 student loan complaints where companies provided a relief amount, the 

median amount of relief reported was approximately $1,307. And fo r the approximately 200 

consumer loan complaints where companies provided a relief amount, the median amount of 

relief reported was approximately $174. 

CONSUMERS' REVIEWS OF COMPANIES' RESPONSES 

Once the company responds, the CFPB provides the company's response to the consumer for 

review. Where the company responds "closed with monetary relief, n "closed with non-monetary 

17 ApproximalelY71,Jooof7S,400. 

34 SEMI·ANNUAl REPORT OF THE CFPB, MARCH 2013 
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relief," "closed with explanation," or "closed," consumers are given the option to provide 

feedback on the company's ra<iponse. Table 3 shows how consumers responded to the 

approximately 68,000 complaints where they were given the option to provide feedback. 

Consumers are asked to notify the CFPB within 30 days if they want to provide feedback by 

disputing a company's ra<iponse. Approximately 61% of such consumers did not dispute the 

ra<iponses provided, while approximately 22% of consumers did dispute the response provided. 

The ra<it were pending with consumers at the end of this period. 

TABLE 3: CONSUMER FEEDBACK ABOUT COMPANY RESPONSES 

Credit Bank account student Consumer Credit 

" I card Mortgage andseNice loan loan reporting 

Consumer did not 

dispute com~ny s 61% 67% 59% 64% 67% 57% 21% 

response 

Consumer disputed 22% 20% 24% 21% 19% 24% 20% com~ny s response 

Pending consumer 

review of com~ny s 17% 14% 17% 16% 14% 19% 59% 

response 

Total 100% 100% 100% 100% 100% 100% Complaints 

35 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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CONSUMER RESPONSE INVESTIGATION AND ANALYSIS 

After requesting that companie.<; respond to complaints sent to them fo r response and giving 

consumers the opportunity to review and provide feedback on company responses, Consumer 

Response prioritizes complaints for investigation based on a review of the complaint, the 

company's response, and the consumer's feedback. Consumer Response seeks to determine why 

a company failed to provide a timely response (if applicable) and whether the consumer's 

feedback of the company's response (if applicable) justifies additional review of the company's 

minimum required actions under the consumer financial protection laws within the CFPB's 

authority. In the course of an investigation, Consumer Response may ask companies and 

consumers for additional information, and once an investigation is completed, Consumer 

Response sends the consumer a summa I)'. In some cases, Consumer Response has referred 

complaints to colleagues in the CFPB's Division of Supervision, Enforcement, and Fair Lending 

and Equal Opportunityfor further action. 

Listening to consumers and reviewing and analyzing their complaints is an integral part of the 

CFPB's work in understanding issues in the financial marketplace, and in helping the market 

work better for consumers. The information shared by consumers and companies throughout 

the complaint process informs the Bureau about business practices that may pose risks to 

consumers and helps the Bureau in its work to supervise companies, enforce federal consumer 

financial laws, and write better rules and regulations. 

2.2 Shopping Challenges 

The challenges that consumers face in the marketplace highlight the importance of a tenet which 

is central to the CFPB's mission - promoting markets in which consumers can shop effectively 

for financial products and seIVices. When the costs, risks, and other key features of financial 

products are transparent and understandable, consumers are better able to compare products 

and choose the best one for them. This discussion presents preliminary obseIVations about 

opportunities and challenges that consumers face when shopping for short term credit needs. 

2.2.1 Small Dollar Lending 

Many American households face an unexpected expense or simply find that their expenses 

regularly outstrip their income, Low-to moderate-income households may use credit options 

such as payday loans, pawn loans, or consumer finance installment loans to deal with a financial 

36 SEMI·ANNUAl REPORT OF THE CFPS, MARCH 2013 
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shortfall. Other strategies may include cutting back on expenses, delaying a bill payment, 

tapping savings, or getting help from friends, family, or an employer. Individual consumers may 

consider a range of products and strategies for this type of need. For example, several surveys of 

payday loan borrowers found that a significant share of respondents considered other options, 

either as an alternative to obtaining a payday loan or after some length of payday loan use, 

including borrowing from their bank or credit union, taking a loan from a consumer finance 

company, using a credit card, or getting assistance from a friend or relative. 18 

While credit cards are perhaps the most common way to address a short-term credit need, this 

section focuses on other options such as payday loans, overdraft signature loans from a bank or 

credit union, installment loans from a consumer finance company, or a pawn shop. Because 

surveys suggest that some consumers shopping for small loans may choose among these 

options, we consider the trade-offs and challenges inherent in making this decision. 

2.3 Shopping Channels 

Consumers shopping among small dollar loan options may find that various products are 

offered with different prices, terms, and conditions. The cost of a payday loan is typically 

communicated as a fee calculated as a percentage of the loan amount, with the entire amount 

due on the borrower's next payday. In addition, the lender must disclose an APR. Somewhat 

similarly, an overdraft also has an upfront fee and usually is repaid when a consumer next 

deposits funds into their bank account, although an overdraft fee is usually fixed regardless of 

the amount by which a transaction overdraws an account. Other options, such as installment 

and signature loans, carry varying interest rates and are typically repaid over longer periods of 

time. Finally, a pawn loan is usually repaid within a month, or the borrower may choose to 

simply forfeit the item being held as collateral at the end of the loan term. 

18 SUlyeys showing households' consideration of these various strategies when faced with a fmandal short-fall include 

Payday Advance Customer Research Cumulatil>e State Researc:h Report, IO Da ta Corporation (September 2(02), 

North CaroJioo Coflsumers After Payday Lending: Altitudes and Experiences with Credit Options, Uni\'ersityof 

North Carolina Center for Community Capital (November 2007), Gregory Elliehausen, Afl .4nalysis of Consumers' 

Use 0/ Payday Loons (January 2009), Paydny Lending inAmerica: l'iho Borrows, Where They Borrow, and Ivny, 

Pew Charitable Trusts (July 2012), and A Complex Portrait: An framination o/Small-Dollar CreditConsumers, 

Center for Financial Ser.'ices Innovation (August 2012). 

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While the cost of obtaining a loan may be a major consideration when deciding to take on debt 

and selecting which credit product to use, it is not the only factor in a consumer's decisionmaking process. For example, in some sUiveys, borrowers of small dollar amounts have 

ovenvhelmingly cited the speed, convenience and near-certainty that they will be approved for a 

loan as the primary considerations for using these products. 19 Likewise, while friends and family 

may charge little or nothing to a consumer needing some assistance, there may be concerns 

about mixing financial needs with these important relationships that outweigh cost 

considerations.

20 

Many of those decisions are dependent on the loan products for which the consumer can qualify, 

with consumers on the subprime end of the credit scale potentially having fewer credit options. 

In the case of payday loans, availability is generally dependent on the state in which the 

borrower resides, since a significant number of states do not permit loans at the interest rates 

these products typicallycarry.21 However, in these (and other) states, residents may be 

obtaining internet payday loans. 

19 Speed, convenience, and likelihood of approval were top reasons borrrn',ersdecided to use small dollar credit 

products in four ua tional surveys. &e Payday .4.dvance Customer Research Cumulatiue State Re5earch Report, 10 

Data Corporation (September 2(02), Payday .4.dvante Customer Satis/actiouSuruey, Cypress Research Group (May 

2(04), Gregory Flliehausen, All Analysis o/Cow;umers' Use a/Payday LoaIlS (January 2(09), and.4. Complex 

Portrait: An Examination a/Small-Dollar Credit Consumers, Center for Financial Services Innovation (August 2012). 

20 In a survey of how low and moderate-income North Carolina families managed firumcial shortfalls, 42% noted that 

they obtained money from friends and family. See North Caro/illa Consumers.4.fter Payday Lending: .4.ttitude5 and 

Experiellce5 with Credit OptiOIlS, University of North Carolina Center for CommunityCapital (Now;mber 2(07). 

Similarly, over a quarter of payday borrowers consider taking a loon from a friend or fami ly member, according to two 

national surveys. See suJ':ey results in Payday Ad~'Gnce Customer Research Cumulative State Research Report, 10 

Da ta Corporation (September 2(02) and Gregor), Elliehausen, An Analysis a/Consumers' Use 0/ Payday Loans 

(January 2(09). 

21 Stephens Inc. reports that 13 states and the District of Columbia haw no payday lending storefrouts and an 

additional state would no longer authorize the product by mid-:wlO. See Payday Loaf! Industry Update, Stephens 

luc. (Juue 6, 20U). There are, hO'ol'e\'eI', a smalluumberof consumers in these states that do rep:>rt using payday 

loons in a recent Pew survey. SI!£ Payday Lending in America: who &Jrrows, where They BoITOW, mid 1\1ly, The 

Pew Charitable Trusts (July 2012). 

38 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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2.4 Product Complexity 

Given the diversity of small dollar loans that exists in the marketplace, consumers may have 

difficulty comparing these products on an apples-to-appl£5~ basis. It may be challenging to 

determine whether taking out a two-week payday loan, pawning a household good for a month, 

or gradually paying down a six-month installment loan makes better financial sense. One 

standard approach to comparing loan costs is the APR; however, APRs may not be provided in 

every case, or include all fees. For example, APRs are not disclosed when a consumer incurs an 

overdraft fee, and other products might have application or other fees that are not included in 

this calculation. 22 At least one survey suggests that many consumers may not understand how to 

use APR to measure the relative costs of different small dollar credit options.23 

Importantly, especially for payday loans, some consumers may overestimate (or fail to give 

consideration to) their ability to fully repay a loan, resulting in the need to refinance or 

otherwise extend their loan, which can result in considerable additional cost. If consumers do 

not understand all their options and potential obligations, they may not fully anticipate their 

repayment costs, and may lose the opportunity to choose a different product that might be more 

appropriate to meet their needs. 

22 For example, "deposit advance" prodnctsoffered by banks tocheckingaccoont customers lIith direct deposit are 

structured as ·open end" lines and the cash advance fee on sllch a line maynol trigger anAPR disclosure. 

23 A na tional survey of 1,173 payday borl'O'ol'ers found tha t only 34% were able to cite an APR for a payday loan. Of 

those who reported an APR, about half reported a rate that w3S unrealistically low. See Gregory Elliehausen,An 

Analysis o/Consumers' Use of Payday T..cans (January 2.009). 

39 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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3. Delivering for American 

Consumers and Leveling 

the Playing Field 

The CFPB is authorized to exercise its authorities under federal consumer financial protection 

laws to administer, implement, and promote compliance with those laws. To this end, the 

Bureau has worked to expand the resources it makes available to consumers and build the 

infrastructure necessary for making consumer financial markets work better. 

3.1 Resources for Consumers 

The CFPB has launched a variety of offices to provide assistance and infonnation to consumers. 

The Bureau strives to provide individualized help to consumers based on their specific issues 

with financial products and services, and it works to improve financial literacy and capability -

amongst the public as a whole and consumers who have experienced particular challenges in the 

financial markets. 

3.1.1 Consumer Response 

Consumer Response receives complaints and inquiries directly from consumers. The CFPB 

accepts complaints through its website and by telephone, mail, email, fax, and referral. 

Consumers submit complaints on the CFPB website using complaint fonns tailored to specific 

products, and can also log on tothe secure consumer portal to check the status of a complaint 

and revie'o'll a company's response. While on the website, consumers can chat with a live agent to 

receive help completing a complaint form. Consumers can also call the Bureau's toll-free 

number to ask questions, file a complaint, check the status of a complaint, and more. The 

CFPB's U.S.-based contact centers handle calls with little-to-no wait times and can provide 

40 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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services to consumers in more than 180 languages and serve hearing- and speech-impaired 

consumers via a toll-free telephone number. Cutting-edge technology, including the secure 

company and consumer portals, makes the process efficient and user-friendly for consumers 

and companies. The CFPB also provides secure channels for companies to communicate directly 

with dedicated staff about technical issues. 

As Consumer Response processes complaints and responds to inquiries, it continues to seek ne\.." 

ways to improve existing processes to make them as efficient, effective, and easy-to-use as 

possible. Based on feedback from consumers and companies, as well as its own observations, 

Consumer Response identifies new opportunities to improve its processes and implement 

changes with each product launch. By applying the lessons learned through previous complaint 

function rollouts, Consumer Response has continued to improve its intake process, enhance 

communication with companies, and ensure the system's ease-of-use and effectiveness for 

consumers, while providing services trusted by consumers and companies alike. 

3.1.2 Consumer Education and Engagement 

The CFPB's Consumer Education and Engagement Division is responsible for developing and 

implementing initiatives to educate and empower consumers to make better-informed financial 

decisions. Improving financial literacy and capability encompasses many short and longer-term 

efforts, including education and engagement with information and tools designed to provide 

clear and meaningful assistance to consumers when they need it. 

Reaching out to consumers is essential to the work of this division. From July 1, 2012 through 

December 31, 2012, the division's offices engaged \vith different groups across the country 

through more than 240 listening sessions, town halls and roundtables, visits to military 

installations, and other stakeholder events. These and other opportunities to hear directly from 

consumers about their financial needs, aspirations, and experiences help inform all of the 

Bureau's work. Through this outreach work, the CFPB has connected to more than 4,100 

stakeholder organizations that were involved in these events. 

As a 21st-century agency, the Bureau has focused on bringing financial decision-making tools 

and information to consumers through an accessible online format. In 2012, a steadily 

increasing number of consumers took advantage of these offerings. The Bureau's website 

received more than five million unique views in the past year. The CFPB estimates that more 

than 3,750,000 of those were to areas of the site providing consumer tools, information, and 

assistance. 

41 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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3.1.3 Financial Education 

The Bureau's Office of Financial Education (OFE) has engaged a variety of communities and 

stakeholders in its work. OFE has continued to prioritize outreach to key stakeholders, including 

financial educators and community leaders, and directly with consumers, through webinars, 

listening sessions, and large consumer events. Much ofOFE's outreach has prioritized 

innovation to solve common financial challenges for consumers by holding a number of events 

around the country to assess need and to establish its priorities in this area. 

In its efforts to engage with a larger American audience, OFE has produced some of its core 

consumer education materials in Spanish, and provided radio intetvie\'/s both in Spanish and 

English to appeal to a broad audience. OFE also received more than 100 comments from a range 

of organizations, individuals, financial institutions and other entities in response to a Request 

for Information (RFI) on Effective Financial Education. 

OFE has also added to its research and innovation portfolios, procuring the services of outside 

experts to develop metrics for success in financial education and to test solutions for consumers 

as they make regular, everyday financial decisions. 

3.1.4 Consumer Engagement 

The Office of Consumer Engagement (CE) continues to encourage the public to participate in the 

Bureau's work by developing programs, initiatives, and digital experiences that help consumers 

make informed financial decisions. 

CE continues to improve and build out the Bureau's online presence with innovative, userfocused, and data-driven approaches to social media and web development. Through ra<;earch 

and user ta<;ting, CE has been able to tap into the needs, habits and interests of consumers, thus 

allowing the team to create opportunities to engage the public at the moments we can be most 

useful to them. 

In particular, CE has focused on building an online consumer experience through the beta 

version of its Paying for College project. This online module guides users through the primary 

decision points of the college decision-making process and offers tools that help users to: 

Find financial aid and choose a loan; 

Compare financial aid and college costs; 

Manage college money; and 

42 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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• Repay student debt 

CE continues to collaborate with divisions across the Bureau on ways to best engage the public 

through digital media. 

3.1.5 Servicemember Affairs 

The CFPB's Office ofSetvicemember Affairs (OSA) conducted 82 outreach events in 2012, 

delivering consumer financial information to more than 31,000 military and veteran consumers 

to help them make better informed financial decisioll.'i. 

More specifically, this figure includes reaching out to servicemembers where they live and work, 

by visiting 10 military ill.'itallatioll.'i/National Guard units, and participating in six town halls and 

15 roundtable discussioll.'i with senior military leaders from July 1, 2012 through DlX:ember 31, 

2012. At these outreach events, the Servicemember Affairs team listened to seryicemembers 

discuss the financial challenges they face, observed financial education training, and provided 

educational materials. In addition to the military units/installations visited, OSA participated in 

40 outreach events sponsored by external organizations seeking additional educational 

information about OSA and the CFPB. OSA also launched Facebook and Twitter accounts 

specifically to selVe the military and veteran communities. By incorporating the use of digital 

and social media channels into the delivery methodolOO"oY for coll.'iumer financial education, QSA 

reached approximately 2.8 million more coll.'iumers. 

OSA awarded a contract to develop an effective "just enough and just in me~ financial 

education experience designed to equip Delayed Entry Program (DEP) participants (those who 

have committed to join the military but not yet been sent to boot camp) with the information 

and education needed to make sound financial decisions in predetermined target areas. The 

DEP education program aims to offer experiential education that engages the interest and caters 

to the learning style of the recruit demographic. Due to the varied timelines and geographical 

locations of the future recruits in DEP and to ensure the curriculum's availability across the 

selVices, course content and materials will be made available through an e-leaming platform 

that DEP personnel can access regardless of time or location. This experience should also set the 

stage for future financial education efforts. 

Collaboration and building upon viable outreach nehvorks was a key focus throughout 2012. 

OSA connected with the Departments of Defense, Veterans Affairs, Justice, and Labor to raise 

awareness of the CFPB's mission and OSA's specific efforts on behalf of the military and veteran 

43 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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communities. At the state level, efforts have centered on introducing state and local resources to 

the military community. Military consumer-focused events included the participation of 14 state 

National Guard Adjutants General and the Attorneys General of 11 states. 

3.1.6 Older Americans 

The Consumer Education and Engagement Division's Office for Older Americans (OA) has 

continued its outreach efforts nationwide with its core constituency, key public officials, 

financial institutions, industry, advocates, and other stakeholders. OA's mission is "to facilitate 

the financial literacy of individuals who have attained the age of 62 or more ... on protection from 

unfair, deceptive, and abusive practices, and on current and future financial choices, including 

through the dissemination of materials to seniors on such topics." OA participated in 46 events 

from July 1,2012 through December 31, 2012, reaching more than 2,050 participants. 

OA's outreach work is raising awareness of the critical problem of financial exploitation and 

unfair, deceptive, or abusive practices targeted at older people. OA is also building on its 

outreach work to help foster local networks to prevent financial harm directed at older people. 

In support of its mission, Hubert H. "Skip" Humphrey III, Assistant Director for OA, testified 

before the U.S. Senate Special Committee on Aging on November 15, 2012 regarding OA's many 

initiatives to combat the crisis of financial exploitation facing older Americans. 24 

Specific examples of these outreach efforts include helping coordinate Older American 

Protection Networks in four states, representing the CFPB on the federal Elder Justice 

Coordinating Council, which consists of 11 federal agencies that playa role in addressing elder 

abuse, and collecting and reviewing comments submitted in response to the CFPB's RFI 

Regarding Senior Financial Exploitation. The Bureau received over 1,200 comments in response 

to the RFI, providing invaluable public participation to inform OA's work. 

The RFI has also provided important input for OA's work on an upcoming report to Congress 

and the Securities and Exchange Commission (SEC) on senior financial advisor certifications 

and designations, pursuant to Section 1013(g)(3)(C) of the Dodd-Frank Act. That report will 

24 Assistant Director Humphrey's testimony maybe found inAppendL~ F. 

44 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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address consumer issue.<; relating to certifications or designations of financial advisors for 

seniors. 

Other initiatives underway include developing consumer guides to help fiduciaries handle 

finances on behalf of older consumers, a guide to help identify and intervene when financial 

exploitation occurs in congregate living facilities, and developing, along with the FDIC, a 

community education and awarene.<;s program called Money Smart for Older Americans, which 

focuses on preventing, recognizing, and reporting elder financial exploitation targeting older 

consumers, family caregivers and other key audiences. 

3.1.7 Students 

Pursuant to Section 1035 of the Dodd-Frank Act, the CFPB's Student Loan Ombudsman 

submitted a report to the Director of the CFPB, the Secretary of the Treasury, the Secretary of 

Education, and Congress in October 2012. The report offered analysis of complaints from 

private student loan borrowers, and was informed by nearly 3,000 complaints, as well as input 

from borrowers and stakeholders. 

The report found that some private student loan borrowers are experiencing similar issues to 

borrowers struggling with mortgages. For example, borrowers complained about the difficulty in 

negotiating a lower payment, as well as issues they faced when loans and servicing rights change 

hands. 

In a separate report, the Student Loan Ombudsman, in coordination with OSA, identified a 

unique set of issues facing servicemembers with student loans. The report identified problems 

faced by servicemembers when attempting to invoke their rights afforded by the Senice 

Members Civil Relief Act. 

The Bureau has developed more tools to help consumers make better financial decisions about 

paying for college and managing student debt. In July 2012, the CFPB launched the Student 

Loan Debt Collection Assistant to help borrowers avoid costly penalties and fees when their 

loans are in collection. As part of the Paying for College suite of tools, the Bureau launched 

Repay Student Debt, a combined, expanded version of our tools. 

Based on public feedback received in response to a prototype launched in April 2012, the CFPB 

released the next iteration of Compare Financial Aid and College Cost, a tool to help students 

and families make smarter choices when weighing financial aid offers. The Bureau also issued a 

45 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
453 


special guide to assist students when choosing a checking account and accessing financial aid 

offers. 

3.1.8 Financial Empowerment 

Since its launch in May 2012, the Office of Financial Empowerment (Empowerment) has 

conducted extensive outreach to consumers and stakeholders from around the country. 

Empowerment participated in five listening sessions in San Francisco, CA, New York, r-,ry, St. 

Louis, MO, Cleveland, MS and Dallas, TX. The team conducted field research focused on 

organizations and companies that provide innovative programs and services designed to build 

the financial capability of underserved and vulnerable consumers. It also participated in 

community events and conferences focused on low-income issues. 

On November 28-29, 2012, at the CFPB's headquarters in Washington, DC, Empowerment 

brought together 125 external stakeholders to discuss opportunities to make consumer financial 

markets work better for low-income and economically vulnerable consumers. This meeting 

included Bureau leaders, local, state, and federal financial regulators, senior government and 

agency officials, and leaders and practitioners from indlL'itry, academia, and nonprofit 

organizations who have been developing and evaluating innovative initiatives to address the 

financial services needs of low-income and economically vulnerable consumers. 

Empowerment launched two major projects in September 2012. The first is a three-phase 

information-gathering effort to better understand whether bundled financial products and 

services are effective in building the financial capability of consumers. This effort will help gauge 

whether programs designed to build the credit and/or savings of consumers are more effective if 

they include a bundled secondary product or service. This phase is designed to lead to further 

stages that will include an evaluation of two programs that currently use the bundled products 

and/or services strategy, and eventually a pilot phase that will test t\vo "idear programs based 

on the lessons learned from the previous two stages. The second project is the development of 

Financial Empowerment Training for front-line staff, like social workers or benefits 

administrators, for organizations that provide services directly to low-income and economically 

vulnerable consumers. 

Empowerment is also working with other federal agencies to streamline and integrate federal 

resource services designed to make consumers more financially capable and stable. Current 

work includes coordination with the Department of Labor's Office of Disability Employment 

46 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
454 


Policy (DOEP) in a joint effort to identify opportunities to promote financial capability strategies 

to selected OOEP grantees. 

3.2 Outreach 

In addition to its efforts to engage and educate particular populations, the CFPB has hosted 

events throughout the country to infonn and receive input about its work on issues related to 

consumer financial products and services. More than 1,000 consumers have made their voices 

heard by participating in town halls and field hearings convened by the eFPB - such as one on 

credit reporting in Detroit, MI and one on debt collection ill Seattle, WA. The CPFB has acti\"ely 

solicited public input on key policy initiatives at the launch of Project Catalyst in Silicon Valley, 

CA, and at the inaugural meeting of the Consumer Advisory Board (CAB) in SI. Louis, MO. 

Director Cordray speaks at an e;-em on credit reporting in Detroit, Michigan 

The eFPB um"eiled Project Catalyst as part of its effort to foster consumer-friendly innovation in 

the marketplace. The Bureau believes markets work best when they are open to new ideas, and 

that the insights and innovations that come from looking at problems and solutions from new 

angles hold great potential in our efforts to achie\"e our mission of making the consumer finance 

47 SEIv1~ANNUAL REPORT OF THE CFP6. MARCH 2013 
455 


market work for all consumers. Project Catalyst is designed to open lines of communication and 

foster collaboratioIl.'i that promote consumer-friendly innovation. In addition to conducting 

ongoing outreach and forums for discussion, the CFPB has launched a new section of its website 

where innovators can obtain relevant information, propose ways the Bureau can make 

innovation easier, or suggest pilot projects to develop and test new market ideas. 

In conjunction with field events, Director Cordray and Deputy Director Date held roundtables 

with community banks, credit unions, and other members of the financial services industry as 

part of our continuing commitment to engage with financial services providers. The Bureau has 

actively solicited the perspectives of consumer and civil rights groups and has held roundtables 

with community-based organizations across the country. Since July 2012, the CFPB's DCA has 

engaged thousands of community group representatives through more than 100 meetings, 

briefing calls, and public appearances. Topics discussed include mortgage, credit cards, payday 

loans, student loans, bank accounts, prepaid cards, credit reporting and scoring, debt collection, 

remittances, and more. 

As with industry outreach, the Bureau has ensured that consumer groups' perspectives inform 

its internal deliberations on policy initiatives. Bureau representatives have met with hundreds of 

industry representatives, and Director Cordray and senior CFPB leadership have delivered 

several speeches at widely-attended industry and nonprofit conferences.25 

25 A list of speeches given in 2012 byCFPB personnel may be fou nd in Appendix G of this report. 

48 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
456 


Senior CFPB leadership Idd...sttcornrner.tslt an ~nt <>Il ~ alIled:ion in SeatO .. Wlsr.i,;gtOll. 

3.3 Partnerships 

The Bureau has furthered many existiltg partnerships and formalized se\'eral new ones. 

Todate, the Bureau has signed numerous memoranda of understanding (MOUl \lith 

intergol-ernmental partners, including federal agencies, state fi nancial regulatory entities, state 

attorneys general. and municipal law €nforrement agencies. :!IS The Bureau has also actively 

solicited the perspectil-es (If ooll.'mmer and civil rights groups. 

(Q SEIoIhIoIIIIU'I. REPOIU OF THE CFPS. MAAO! 2013 
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Bureau personnel also testified before Congress on 17 occasions between January 1, 2012 and 

December 31 , 2012 to discuss policy, operations and budget matters.27 

3.3.1 Office of the Consumer Advisory Board and Councils 

In addition, the Bureau has established the Office of the Consumer Advisory Board and 

Councils, which is charged with managing the Bureau's advisory groups and serving as the 

liaison behveen advisory group members and the Bureau. It oversees the Bureau's engagements 

with external stakeholders and includes the: 

Consumer Advisol)' Board (CAB); 

Community Bank Advisory Council (CBAC); 

Credit Union Advisory Council (CUAC); and 

Academic Research Council (ARC) 

The Office of the Consumer Advisory Board and Councils is part of the External Affairs Division. 

To manage these bodies, the Office of Consumer Advisory Boards and Councils: 

Regularly facilitates discussions between the Bureau and advisory board/council 

members; 

Recommends policy and associated strategies as suggested by advisory boards and 

councils; 

Manages the selection process for the Bureau's advisory boards and councils; 

Conducts agenda setting for advisory board and council meetings; and 

Manages the policies and procedures for the constitution and management of advisory 

boards and councils. 

These groups will meet at least twice per year and offer vital insight and perspective of financial 

service providers as the Bureau strives to issue thoughtful, research-based rules. 

27 CFPB testimony before Congress may be found in AppendL~ F of this report. 

5(1 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
458 


ROLE OF THE CONSU MER ADVISORY BOARD 

Section 1014(a) of the Dodd-Frank Act states: 

The Director shall establish a Consumer Advisory Boord to advise and consult with the 

Bureau in the exercise of irs functions under the Federal consumel'jinanciallaws, and 

to provide infonnation on emerging practices in the conSi/mer financial products or 

services industry, including regional trends, concerns, and other relevant 

information.28 

The Consumer Advisory Board and the other advisory councils help the Bureau solicit external 

stakeholder feedback on a range of topics, including consumer engagement, policy development 

and research, and from a range of actors, academics, industry, community members and 

advocates. Advisory boards and councils may consult on a variety of cross-cutting topics, report 

on meetings, and provide minutes and/or summaries of their meetings. Members of boards and 

councils will serve for limited, specified terms. 

MEMBERSHIP AND PUBLIC NOMINATING 

PROCESS OF THE CONSUMER ADVISORY BOARD 

Section 1014(b) of the Dodd-Frank Act states: 

In appointing the members of the Consumer Advisory Boord, the Director shall seek to 

assemble experts in consumer protection,financial services, community development, 

fair lending and civil rights, and consumer financial products or services and 

represel1tatives of depository institutiol1s that primarily serve underserved 

communities, and representatives of communities that have been significantly 

impacted by higher-priced mortgage loans, and seek representation of the interests of 

covered persons and consumers, without regard to party affiliation. 29 

Following these statutory guidelines, the Bureau invited e:xternal experts, industry 

representatives, consumers, community leaders, and advocates to apply to be a member of the 

28 Dodd-Frank Act, Pub. L No. 111-203, § 1014(a). 

29 Dodd-Frank Act, Pub. L No. 111-203, § IOI4(b). 

Sl SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
459 


Consumer Advisory Board. Additionally, the Bureau publishoo a notice for nOOlinatiOlls on its 

website, distributed a notice v.i dely through mass email distnbutions, and published a notice 

outlining the functions of the Board and soliciting nominations for members to serve on the 

Board in the Federal Register. In responsetothis call for nominations, the Bureau receil.roO\-er 

1,100 unique candidate nOOlinations for membership on the Board. On September 12, 2012, the 

Bureau announced the appointment of 2.5 consumer I'-lperts to the Consumer Ad\isory Board3G. 

The inlllgund members 01 11-.. Cocsum.r AI";""" brd. meeting inSlLwi .. htisswri 

INAUGURAL MEETINGS OF THE CONSUMER 

ADVISORY BOARO AND THE OTH ER COUNCILS 

The Bureau held the inaugural meeting of the Consumer Alh"isory Board in St.louis, MOon 

September :17-28, 2012, in\;ting members of the public to watch 3 portioo of the meeting and to 

prolide testimooydirectlyto CAB members 011 the financial issues that affect their 

JO Th.IIlf.I>uo..,,,,,,&t I&d list of m.C1be" Cloy be round It 

bttp:/tw-·COIlSIIClerfilll<l<qrrr/pm<mlto-/tomIlmer-fimonau.protu:ti""·ba.--... """"nca-coIlSlI"'.rod,t.ory-boord·members!. 

~1 SEIoIhIol-IIIU'I. REPOIU OF THE CFPS. MAAO! 2013 
460 


communities. Director Cordray provided remarks at the event that are available on our 

website. 31 

The inaugural meetings of the Community Bank Advisory Council and the Credit Union 

Advisory Councils were held, respectively, on October 11, 201 2 and October 12, 2012. 

For more information about the CAB and the other CFPB advisory bodies, please visit our 

website. 

31 Director Cordray's remarks may be read at http://I1,,",'W.consumerfinance.gov /~peec es/ repared remarks-byrichard -rordray-at-the-inaugura l-consumer-advisory-board-meelingf. 

S3 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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4. Regulations and Guidance 

Since the issuance of the July 2012 Semi-Annual Report, the Bureau issued a number of 

proposed and final rules on mortgage-related issues, in anticipation of meeting a January 21, 

2013 deadline under the Dodd-Frank Act, as well as a number of non-mortgage related 

proposed and final rules on various other matters within its authority. Along with the issuance 

of these new rules, the CFPB is also working to facilitate industry compliance. In addition, the 

Bureau continues to implement suggestions received in response to a Bureau RFI seeking public 

comments on potential projects to streamline Bureau regulations. 

4.1 Implementing Statutory Protections 

The CFPB has recently finalized a number of rules implementing changes made by the DoddFrank Act to the laws governing various aspects of the mortgage market, including originations 

and servicing of mortgages. In 2012, the Bureau issued a series of proposed mles for public 

comment after months of preparation and outreach, including several small business review 

panels. The Bureau analyzed the comments received on those proposals and prepared the final 

mles, as well as various final rules for proposals inherited by the Bureau from the Federal 

Reserve Board. These rules will provide significant improvements to the mortgage process that 

will benefit both consumers and the mortgage industry alike through strengthened consumer 

protections and increased efficiencies. The Bureau issued the following final rules in January 

2013: 32 

A rule implementing Dodd-Frank Act amendments to the Truth in Lending Act (TILA) 

requiring that creditors make a reasonable, good-faith determination of a consumer's 

32 Links to fina l and proposed rules discussed in this section are available at: consumerfinance.gO\'!regulations/' 

54 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
462 


ability to repay any consumer credit transaction socured by a dwelling (excluding an 

open-end credit plan, timeshare plan, reverse mortgage, or temporary loan), establishing 

certain protections from liability under this requirement for "qualified mortgages,~ and 

limiting prepayment penalties. The rule also requires creditors to retain evidence of 

compliance with the rule for three years after a covered loan is consummated. 

Rules implementing new Dodd-Frank Act requirements in the Real Estate Settlement 

Procedures Act (RESPA) and in TILA related to mortgage servicing. The rule amending 

Regulation X, which implements RESP A, addresses servicers' obligations to correct 

errors asserted by mortgage loan borrowers, to provide certain information requa<ited by 

such borrowers, and to provide protections to such borrowers in connection with forceplaced insurance. Additionally, this rule addresses servicers' obligations to establish 

reasonable policies and procedures to achieve certain delineated objectives, to provide 

infonnation about mortgage loss mitigation options to delinquent borrowers, to 

establish policies and procedures for providing delinquent borrowers with continuity of 

contact with servicer personnel capable of performing certain functions, and to evaluate 

borrowers' applications for available loss mitigation options. Further, the rule modifies 

and streamlines certain existing servicing-related provisions of Regulation X. The rule 

amending Regulation Z, which implements 11 LA, includes requirements concerning 

notices of initial rate adjustments for adjustable rate mortgages (ARMs), periodic 

statements for residential mortgage loans, prompt crediting of mortgage payments, and 

responses to requests for payoff amounts. This rule also amends current rules governing 

scope, timing, content, and fonnat of disclosures to consumers regarding the interest 

rate adjustments of their variable-rate transactions. 

A rule implementing certain amendments to TILA made by the Dodd-Frank Act that 

lengthens the time for which a mandatory escrow account established for a higher-priced 

mortgage loan must be maintained and exempts certain transactions from the escrow 

requirement, including creating an exception for certain small servicers in rural or 

undersenred areas. 

A rule implementing Dodd-Frank Act changes to l1LA regarding loan originator 

compensation, qualifications of and registration or licmsing of loan originators, 

compliance procedures for depository institutions, mandatory arbitration, and the 

financing of single premium credit insurance. The rule also revises or provides additional 

commentary on restrictions on loan originator compensation, including application of 

these restrictions to prohibitions on dual compensation and compensation based on a 

term of a transaction or a proxy for a term of a transaction, and to rocordkeeping 

S5 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
463 


requirements. The rule also establishes tests for when loan originators can be 

compensated through certain profits-based compensation arrangements. 

An interagency rule implementing Dodd-Frank Act amendments to TIIA that requires 

appraisals for ~higher risk mortgages,~ including, for certain mortgages, requiring 

creditors to obtain an appraisal or appraisals meeting certain specified standards, and 

providing applicants ¥.1th a notification regarding the use of the appraisals and a copy of 

the written appraisals used. 

A rule implementing a Dodd-Frank amendment to the Equal Credit Opportunity Act 

(ECOA) that requircs creditors to provide applicants with free copies of all appraisals 

and other written valuations developed in connection with an application for a loan 

secured by a first lien on a dwelling, and requircs creditors to notify applicants in writing 

that copics of appraisals will be pro\1ded to them promptly. 

A rule implementing Dodd-Frank Act amendments to TILA that expands the types of 

mortgage loans that are subject to the protections of the Home Ownership and Equity 

Protection Act of 1994 (HOEPA), revises and expands the tests for coverage under 

HOEPA, and imposes additional restrictions on HOEPA mortgage loans, including a preloan counseling requirement. The rule also implements other Dodd-Frank Act 

amendments to TIIA and RESPA that impose certain other requirements related to 

homeownership counseling, including a requirement that consumers receive information 

about homeownership counseling providers. 

In addition, since the July 2012 Semi-Annual Report, the Bureau has issued other proposed and 

final rulcs, including the following: 

in November 2012, the Bureau proposed to amend the rules implementing the credit 

card ability to pay pr0\1sions ofTiIA to addrcss concerns that the current rules unduly 

limit the ability of spouses and partners not working outside the home toobtain credit 

cards based on the income of the other spouse or partner. 

In August 2012, the Bureau issued a final rule that providcs a "safe harbor~ provision 

exempting from the requirements of the Bureau's Regulation E, which implements the 

Electronic Fund Transfer Act, as amended by the Dodd-Frank Act, those who, in the 

normal course of business, provided 100 or fe'wer remittance transfers in the current 

calendar year. This amendment \\111 make the remittance transfer process easier for 

institutions that handle 100 or fewer remittances per year. The August 2012 rule also 

adjusts rules regarding transfers that consumers schedule several days in advance. In 

December 2012, the Bureau proposed three substantive amendments to the remittance 

56 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
464 


nile, which would temporarily delay the February 7, 2013 effective date of the rule and 

provide additional clarity regarding disclosures and error resolution procedures. On 

January 22, 2013, the Bureau issued a final nile temporarily delaying the February 7, 

2013 effective date. 

In January 2013, concurrently with issuing its ability to repay/qualified mortgage nile, 

the Bureau issued a proposed nile proposing certain amendments to the rule, including 

exemptions for certain nonprofit creditors and certain homeownership stabilization 

programs and an additional definition of a qualified mortgage for certain loans made and 

held in portfolio by small creditors. The Bureau also sought feedback on whether 

additional clarification is needed regarding the inclusion ofloan originator 

compensation in the points and fees calculation. 

The Bureau continues work to finalize the proposal it issued in July 2012 that would, among 

other things, combine certain disclosures that consumers receive in connection with applying 

for and closing on a mortgage loan under TILA and RESPA, as required by the Dodd-Frank Act. 

The Bureau also continues work to finalize the proposal it issued in April 2012 with respect to 

fees charged by credit card issuers prior to the opening of an account, and continues working on 

an interagency basis to complete rulemakings related to appraisals and implementation of the 

Expedited FundsAvaiiability Act. 

As the Bureau completes work on these pending rulemakings, it is also in the process of 

analyzing and prioritizing additional projects. It expects, for example, to accelerate work on 

other rule makings that are mandated under the Dodd-Frank Act, such as amendments to the 

Home Mortgage Disclosure Act (HMDA) to require creditors to collect and report certain 

additional lending data. In addition, the Bureau is in the process of assessing infonnation 

gathered in the past year concerning a variety of consumer financial products and services 

besides mortgage loans to determine whether rulemakings are warranted to address other 

markets. In particular, the CFPB has issued a number of RFls, an advance notice of proposed 

rulemaking, and congressionally mandated and other reports in the past year concerning a wide 

variety of markets and consumer financial issues. The Bureau expects, for example, to issue a 

proposed rule with respect to prepaid cards in 2013. 

57 SEMI·ANNUAl REPORT OF THE CFPB, MARCH 2013 
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4.2 Interpreting and Streamlining Inherited 

Regulations; Facilitating Compliance 

with New Regulations 

The CFPB continues to work with consumer and industry stakeholders to interpret and 

streamline regulations that implement existing federal consumer financial protection laws. 

These regulations were issued previously by other federal financial regulators and transferred to 

the Bureau in July 2011. The Bureau is also working to find ways offacilitating industry 

compliance with newly issued Bureau rules. 

In 2012, the Bureau issued interpretive guidance33 on a variety of topics, including interpreting 

regulations concerning mortgage loan originator compensation, licensing requirements for loan 

originators under the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE 

Act), and reaffirming the applicability of the disparate impact doctrine under ECOA. 

The CFPB is also considering opportunities to streamline, modernize, and hannonize 

regulations that it inherited from other federal agencies. The Bureau issued an RFI in December 

2011 on this topic seeking broad stakeholder input, and as a result of the comments received, 

has identified several priority areas for regulatory action. For example, the proposal that the 

Bureau issued in November to amend the ability-to-pay regulations under the Credit Card 

Accountability Responsibility and Disclosure Act of 2009 (the Credit Card Act) was advocated 

by a number of industry participants responding to the streamlining RFI. Similarly, the Bureau 

is carefully exploring methods to reduce the burden of HMDA reporting while simultaneously 

increasing the value of the information collected. 

In addition, the CFPB is assessing ways to facilitate industry compliance with newly-issued 

regulations. The Bureau has determined that one important way to help reduce compliance 

burdens is to assist regulated entities, especially community banks, credit unions, and small 

entities, in understanding and complying with the mles. For example, in connection with the 

remittance mle, the Bureau has engaged in outreach and provided educational materials to 

industry. In October 2012, the Bureau issued its International Fund Transfers Small Entity 

33 00llS11merfinanre.gov/guidallce/. 

58 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
466 


Compliance Guide.Mone industry representative remarked upon reading the Guide, "I 

commend the CFPB for providing a guide that is so informative .... The guide presented the 

requirements of the remittance rule in a clear and concise manner in a format that could be 

understood by all levels of employees. ~ The Bureau also held a webinar in October 2012 

explaining the remittance rule that was similarly well received. J4 The webinar was viewed live by 

over 3,000 participants and more than 1,000 individuals have viewed the archived webinar 

online. As one industry professional stated in an e-mail to the Bureau, "This webinar was much 

better than one I paid $300 for from a reputable banking resource . .. Great job, FPB! ~ In 

addition, Bureau staff have participated in a large number of conferences to discuss the 

remittance rule, and have handled informal inquiries from a myriad of remittance service 

providers. The Bureau intends to engage in similar activities in the coming months to facilitate 

understanding of, and compliance with, the mortgage regulations that the Bureau has issued. 

The Bureau is also working to develop opportunities to test alternatives to currently-mandated 

disclosures which may enhance the efficacy of such disclosures and/or reduce costs. In 

December 2012, the Bureau issued a proposed Policy to Encourage Trial Disclosure Programs 

and invited public comment on that proposed policy. The Bureau expects to finalize the policy 

shortly so as to create room for such trial disclosures. 

Finally, the CFPB promulgated supplemental ethics regulations for Bureau employees, 

establishing restrictions on outside employment and business activities, prohibitions on the 

ownership of certain financial interests, restrictions on seeking, obtaining, or renegotiating 

credit and indebtedness, prohibitions on recommendations concerning debt and equity 

interests, disqualification requirements based on credit or indebtedness, prohibitions on 

purchasing certain assets, and restrictions on participating in particular matters involving 

outside entities. 35 

34 Remarks, the webinar, and a slide presentation on the remittance ntles may he found at 

www.ronsumerfinan~ govfblog/remillance-ru e-session . 

3S oonsllmerfinance.gov/reglliations/. 

S9 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
467 


5. Supervision 

The eFPE's supervision program seeks to ensure that businesses that provide financial products 

and services to consumers comply with federal consumer financial laws. Initially, the CFPB's 

5upenrision office was organized into hvo groups, one addressing the supervision oflarge banks 

and the other focusing on nonbank supervision. In December 2012, Supervision announced the 

reorganization of its headquarters staff into an examinations team and a policy team. lhis 

realignment replaces the previous organizational stmcture and is consistent with the Bureau's 

mission to protect consumers across financial markets without regard to the charter of the 

provider. The examinations team focuses on the processes vital to accomplishing the CFPB's 

examination function, including recruitment, training, and commissioning of examiners, the 

implementation of examination policies and procedures, and the planning and execution of 

examinations appropriately in light of the Bureau's resources and priorities. The policy team 

ensures that policy decisions for Supervision are consistent with both the law and our mission, 

and that they are consistent across markets, charters and regions. The Supervision Policy office 

is organized by product or service market rather than bytype of service provider or financial 

institution. 

5.1 Supervisory Activities 

On October 31,2012, the Office of Supervision issued three publicdocuments: 

SUPERVISORY HIGHLIGHTS: FALL 2012 

The CFPB supervises certain financial institutions and service providers to determine their 

compliance with applicable federal consumer financial laws and regulations and to help ensure 

that markets for financial products and services work in a fair and transparent way for 

consumers and the businesses that serve them. As part of its commitment to transparency, the 

CFPB has issued Supervisory Highlights: Fall 2012, a periodic publication that apprises the 

public and the financial services industry about its supervision and examination program, 

60 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
468 


including significant concerns discovered during the course of its completed work. The CFPB 

believes this communication will help providers of financial products and services better 

understand steps they can take to fully comply with federal consumer financial laws and protect 

against the risk ofharm to consumers. This first edition of Supervisory Highlights emphasizes 

the need for financial institutions to implement sound compliance management systems, and 

discusses issues noted in three key product areas: credit cards, credit reporting, and 

mortgages. J6 

SUPERVISION AND EXAMINATION MANUAL, VERSION 2 

The CFPB's Supervision and Examination Manual guides CFPB examiners in overseeing 

companies that provide consumer financial products and services. In Version 2, the Manual has 

been updated to restate outdated regulatory citations with new CFPB citations, reflecting the 

rulemaking authority for federal consumer financial laws which was transferred from other 

federal agencies to the CFPB by the Dodd-Frank Act. CFPB regulations are codified in Title 12, 

Chapter X, of the Code of Federal Regulations. 

The Manual also incorporates updated interagency examination procedures based on revisions 

to (1) IlIA, and its implementing Regulation Z, pursuant to the Credit Card Accountability, 

Responsibility and Disclosure Act of 2009 and (2) the Fair Credit Reporting Act (FCRA), that 

requires the disclosure of credit score and related information when a credit score is used in 

taking an adverse action or in risk-based pricing. In addition, it provides newe.xamination 

procedures covering short-term, small-dollar lending, the Secure and Fair Enforcement for 

Mortgage Licensing Act, and consumer reporting. It includes updated guidance and procedures 

for compliance with ofRESPA in mortgage originations, and incorporates the June 21, 2012 

Interagency Guidance on Mortgage Servicing Practices Concerning Military Homeowners with 

Permanent Change of State Orders.

37 

J6 Supen>isory Highlights, Fall20l2 can be found al: http://files.consumerfinanC1!.gov/f/201210_dpb_supervisoryhighlights-fall-2oI2.pdf. 

37 The updated CFPB Supervision and E.xamination Manual can be found at: 

http://files.oollsumerfinance.gov/f/20 1210 _cfpb supervision-and-examinat iOll-mallual-Y2.pdf. 

61 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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EXAMINATION APPEALS POLIC Y 

The CFPB has issued a new policy that allows supervised entities that receive final, less than 

satisfactory ratings on their reports of examination to request review of their rating by CFPB 

officials not involved in the examination or determination of the rating. Supervised entities may 

also appeal adverse findings conveyed in a supervisory letter. This new appeals policy promotes 

the CFPB's goals of establishing constructive relationships with supervised entities and 

maintaining a fair and factually based supervision program. It will help assure consistency in 

ratings, and will encourage greater industry compliance with applicable laws and regulations 

and better markets for consumers. 38 

5.2 Supervisory Guidance and Examination 

Procedures 

CFPB BULLETIN: MARKETING OF CREDIT CARD ADD-ON PRODUCTS 

On July 18,2012, the CFPH issued Bulletin 2012-06, entitled "Marketing of Credit Card Add-on 

Prod cts~. Credit card issuers market "add-on~ products to card users, including debt 

protection, identity theft protection, credit score tracking, and other products that are 

supplementary to the credit provided by the card itself. The CFPE's supervisory experience 

indicates that some credit card issuers have employed deceptive promotional practices for addon products. They have failed to disclose important product terms and conditions, enrolled 

consumers in programs without their affirmative consent, billed for services that were not 

activated or performed, and misled consumers by the marketing and sales practices employed. 

This Bulletin outlines the CFPB's expectation that institutions under its supervision and their 

service providers offer such products in compliance with provisions of law, including DoddFrank Act prohibitions against deceptive practices, TILA, ECOA, and other applicable federal 

laws and regulations. 

38 TheAppeals Bulletin can be found at: http ://files.ron5llmerfinance.gov/f/20121Q_d'pb __ bulletin_5lIpelVisoryappeals-process.pdf. 

62 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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The Office of Supervision has issued new examination procedures in three broad areas, which 

are now incorporated into the Supervision and Examination Manual: 

LARGER PARTICIPANT RULES 

Pursuant to provisions of the Dodd-Frank Act, the CFPB generally has authority to supervise 

nonbank covered persons of all sizes in the residential mortgage, private education lending, and 

payday lending markets. In addition, the CFPB has the authority to supenrise "larger 

participant[s]" of markets for other consumer financial products or services, as the Bureau 

defi nes by rule. 

On July 20, 2012, the Bureau issued a final rule to define larger participants in the consumer 

credit reporting market. This final nile facilitates the supervision of nonbank covered persons 

active in that market. In September 2012, the Bureau released examination procedures related 

to this rule, and since then has begun exercising its supervisory authority in this market. 

Further, in October 2012, the Bureau issued a final rule to define larger participants of the 

consumer debt collection market, bringing those entities under its supenrisory and examination 

authority. The Bureau also released examination procedures fo r this market and held a field 

hearing in Seattle, WA on October 24, 2012 to receive public feedback. 39 The nile and related 

examination procedures became effective on January 2, 2013. 40 

RULES ESTABLISHING SUPERVISORY AUTHORITY OVER CERTAIN PERSONS 

POSING RISKS TO CONSU MERS 

The Bureau has also proposed a nile to establish supervisory authority over any nonbank entity 

that it has reasonable cause to determine is posing a risk to consumers with regard to the 

offering or provision of consumer financial products or senrices. 41 The proposed nile would 

39 The video for this event may be \;ewed at www.oonsumerfinance.gov/blog/categoJ)'/debt-oollection/ andDirector 

Cordray's remarks forthee\'ent may be viewed at ..... "oIw.consumerfinance.gov/sprecltes/prepared-remarks-brrichard-eordrar-at-the-public'field'hearillg-on-debt-coUection-practices/ . 

..., httll://Y,"¥OW .gpo.gov/fds),s/pkgjFR-:w 12-12-07/pdf/2012-29438.pdf. 

41 hHps:/ /wW¥.'Jederairegister.gO'l,/articies/2012/0S/25/2012-12718/procedurai-ruies-to-estabiish-supervisoryaUlhorily-owr-certain-nonhank-rovered-persons-based-on. 

63 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
471 


establish a process for the CFPB to give notice to the nonbank entities of such determinations 

and would provide them with a reasonable opportunity to respond. The proposed rule would not 

impose new substantive consumer protection requirements on any nonbank entity. The Bureau 

anticipates that this rule will be finalized in 2013. 

EDUCATION LOANS 

On December 17, 2012, the CFPB published procedures it will use in examining private student 

lenders. These procedures will help CFPB examiners ensure that private student lenders comply 

with applicable federal consumer financial laws, including TIIA, the Electric Fund Transfer Act, 

the Fair Debt Collection Practices Act, the FC RA, ECOA, and the Gramm-Leach-Bliley Act. 

5.3 Information Sharing With State 

Regulators 

The Office of Supervision has continued to expand its information sharing outreach to state 

regulators, and now has in place information sharing MOUs with 61 state regulatory agencies in 

49 states, the District of Columbia, and Puerto Rico. On December 6, 2012, the CFPB issued a 

Statement of Intent for Sharing Information with State Banking and Financial Services 

Regulators. Under an access agreement with the State Regulatory Registry, a subsidiary of the 

Conference of State Bank Supervisors, the Bureau will have access to state regulatory and 

licensing information in the Nationwide Mortgage Licensing System. 

5.4 Examiner Training and Commissioning 

The CFPB's field examination work is carried out by a highly qualified and diverse examination 

staff that has broad experience in planning and conducting examinations of financial 

institutions and businesses supervised by the CFPB. In August 2012, 89 experienced examiners 

became commissioned CFPB examiners, based on their prior experience and commissioning at 

other federal agencies.lbe CFPB is continuing to develop its own examiner commissioning test, 

which will be based on the CFPB's examiner training strategy and components. The examiner 

training component includes, among other items, the Bureau's Fair Lending Examination 

Techniques course. Examiners who complete the training and pass the test that the CFPB adopts 

will become commissioned CFPB examiners. 

64 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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5.5 Technology 

The Bureau has continued to build out its technology infrastructure in order to supervise 

covered persons in a data-driven manner. 

EXAMINERS ENCYCLOPEDIA (E2l 

Supervision has launched the Examiners Encyclopedia (e2), an internal online resource that 

organizes supervisory documentation for reference. The Examiners Encyclopedia includes 

guidance and publications to support and facilitate the work oftheCFPB's Supervision program, 

including links to the CFPB Supervision and Examination Manual. Additional publications 

referenced in the tool include: 

CFPB Handbooks and Examination Programs; 

Regulatory Bulletins (Federal and State); 

Federal Register Publications; 

Legal Opinions; and 

interagency Guidance 

COMPLIANCE ANALYSIS SOLUTION 

Supervision has also developed the Compliance Analysis Solution (the Solution), an automated 

system which supports collection, validation and analysis of loan portfolio data through a 

centralized system. The overall objective of the Solution is to analyze 100% of a loan portfolio, 

giving examiners the analytical insights necessary to conduct risk-based and targeted 

compliance assessments. It also allows secure and standardized data submission to the CFPB, 

which enables consistency in the examination process across institutions. A fa ir lending-focused 

component to the Solution is also under development. 

The first release of the Solution, on October 19, 2012, performed compliance analysis on 

mortgage loans, specifically for compliance with the requirements of HOEPA, TllA, and RESPA 

65 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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6. Enforcement 

The CFPB aims to enforce the consumer protection laws within the Bureau's jurisdiction 

consistently and to support consumer-protection effort<; nationwide by investigating potential 

violations both independently and in conjunction with other federal and state law enforcement 

agencies. 

6.1 Conducting Investigations 

Since the CFPB's launch, the Office of Enforcement has been conducting research and 

investigating potential violations of federal consumer financial laws. Some investigations were 

transferred to the Bureau by the prudential regulators and HUD, and the Bureau initiated other 

investigations based on potentially problematic practices that Bureau staff identified or 

consumers and others have reported. Enforcement has focused its investigative resources on 

violations of law that cause the greatest hann to consumers. The investigations currently 

underway span the full breadth of the Bureau's enforcement jurisdiction. Further detail about 

ongoing investigations will not generally be made public by the Bureau until a public 

enforcement action is filed. 

6.2 Public Supervisory and Enforcement 

Actions 

Section 1016(c)(S) of the Dodd-Frank Act requires the Bureau to include in the annual report "a 

list, with a brief statement of the issues, of the public supervisory and enforcement actions to 

which the Bureau was a party during the preceding year. " The Bureau was a party in nine such 

enforcement actions from January 1, 2012 through December 31,2012, detailed as follows: 

66 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
474 


In the Matter of: Capital One Bank (U.S.A.),N.A., File No. 2012-CFPB-0001 (July 18, 

2012). 

The CFPB brought this public enforcement action and obtained an order requiring Capital One 

Bank (U.S.A.), NA.to refund approximately $140 million to an estimated hvo million customers 

and pay an additional $25 million penalty. The action resulted from a CFPB examination that 

identified deceptive marketing tactics used by Capital One's vendors to pressure or mislead 

consumers into paying for "add-on products" such as payment protection and credit monitoring 

when they activated their credit cards. The Office of the Comptroller of the Currency (OCC) 

brought a coordinated enforcement action against Capital One, which also included restitution 

and civil monetary penalties. 

In the Matter of: Discover Bank, File No. 2012-CFPB-0005 (September 24,2012) 

The CFPB and the Federal Deposit Insurance Corporation (FDIC) jointly determined that 

Discover Bank used deceptive telemarketing practices to sell certain credit card add-on products 

to cOl15umers. Discover agreed to stop deceptive marketing practices, pay approximately $200 

million in restitution to more than 3.5 million customers who purchased credit card add-on 

products over the telephone between December 1, 2007 and August 31, 2011, and pay a $14 

million civil money penalty. 

In the Matters of: American Express Centurion Bank, et al., File Nos. 2012-CFPB0002, 2012-CFPB-0003, and 2012-CFPB-0004 (October 1, 201 2). 

The CFPB ordered three American Express subsidiaries to refund an estimated $85 million to 

approximately 250,000 customers, and, together with the FDIC, the OCC and the Federal 

Reserve Board, imposed an additional $27.5 million in civil money penalties. The Utah 

Department of Financial lnstitutiol15 (DFI) also took its own enforcement action. The 

investigation of American Express began after a routine exam by the FDIC and Utah DFI which 

was shared with the CFPB after the CFPB inherited jurisdiction over federal cOl15umer financial 

laws in July of 2011. The CFPB and its sister regulators determined that the programs of various 

American Express-related companies violated consumer protection laws, including the Card Act, 

ECOA, the FCRA, and the prohibition against deceptive practices, at nearly every stage of the 

cOl15umer experience, by using deceptive marketing and debt collection practices, unlawfully 

discriminating against new account applicants on the basis of age, failing to report col15umer 

disputes to cOl15umer reporting agencies, and charging unlawful fees. The fair lending violatiol15 

at issue in this matter are discussed in greater detail in the Fair Lending Enforcement section 

below. 

67 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
475 


Consumer Financial ProtecnonBureau v. Gordon, etal. (C. D. Cal. No. 12-CV-06147) 

(complaint filed July 18, 2012). 

This action involves a nationwide mortgage relief scheme in which the CFPB allegE'-" that the 

defendants took advantage of financially distrE'-"sed homeowners by promising to help them 

obtain loan modifications and charging them an advance fee ranging from $2,500 to $4,500. In 

reality, the CFPB believes, the defendants provided consumers with little, if any, meaningful 

assistance to modify their mortgages. On July 18, 2012, at the Bureau's request, the U.S. District 

Court issued a Temporary Restraining Order, effectively halting the alleged scheme. The 

complaint charges that the Defendants violated the Dodd-Frank Act and the Mortgage 

Assistance ReliefSelVice:; Rule, recodified as Regulation O. On November 16, 2012, the Court 

entered a Preliminary Injunction against the Defendants, finding that the Bureau was likely to 

succeed on the merits of its case. On February 1, 2013, the Court entered a Stipulated Final 

Judgment and Order for Permanent Injunction and Settlement of Claims as to Defendants 

Abraham Michael Pessar, Division One Investment and Loan, Inc., and Processing Division, 

LLC. 

In re: 3D Resorts-Bluegrass, LLC, (W.D. Ky., Bankruptcy No. 11-41599) (proof ofclaim 

filed July 20, 2012). 

The CFPB filed a proof of claim in this bankruptcy action based on potential violations of the 

Interstate Land SalE'-" Full Disclosure Act and the Dodd-Frank Act of 2010. The potential 

violations include a seriE'-" of alleged misrepresentations by a lot seller debtor and others 

regarding the registration, marketing, and sale of certain lots on a property known as the Green 

Fann Resort. 

Consumer Financial Protecnon Bureau v. Jalan, et al. (C.D. Cal. No. 8:12-CV02088)(complaint filed December 3, 2012). 

This action involves a nationwide mortgage relief scheme that the CFPB alleges took advantage 

of financially distressed homeowners. The complaint alleges that the defendants promised to 

help those homeowners obtain loan modifications and charged them an advance fee ranging 

from $1,000 to $3,000 or more. TheCFPB contends that the defendants provided consumers 

with little, if any, meaningful assistance to modify their mortgagE'-". On December 4, 2012, at the 

Bureau's request, the U.S. District Court issued a temporary restraining order, effectively halting 

the alleged scheme, and the defendants subsequently stipulated to a preliminary injunction that 

was issued on December 14, 2012. The complaint charges that the defendants violated the DoddFrank Act and the Mortgage A<lsistance Relief SelVices Rule, recodified as Regulation O. 

68 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
476 


Consumer Financial Protection Bureau, et al. v. Payday Loan Debt Solution, Inc., 

etal. (S.D. Fla. 201 2). 

The CFPB obtained a stipulated final judgment in federal district court against a nationwide 

debt-relief company, Payday Loan Debt Solution, Inc. (PLDS) and its principal, Sanjeet Parvani. 

The CFPB brought this action in partnership with the State Attorneys General of New Mexico, 

North Carolina, North Dakota and Wisconsin, and with the State of Hawaii Office of Consumer 

Protection, based on a CFPB investigation. The investigation revealed that PLDS routinely 

charged consumers advance fees before attempting to settle their debts. This practice violates 

the Telemarketing Sales Rule, the Dodd-FrankAct of 2010, and various state laws. The court 

required PLDS to pay a full refund of up to $100,000 for the advance fees, imposed a $5,000 

civil penalty, and enjoined PLDS and its principal from engaging in future unlawful conduct. 

69 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
477 


7. Fair Lending 

The eFPB's Office of Fair Lending and Equal Opportunity (Fair Lending) is charged by Congress 

with "providing oversight and enforcement of Federal laws intended to ensure fair, equitable, 

and nondiscriminatory access to credit for both individuals and commllni ies~ that are enforced 

by the CFPB, including ECOA and HMDA. 42 

ECOA 43 prohibits discrimination in mortgage lending and a wide array of other lending, 

including auto finance, credit cards, business loans, and unsecured loans. HMDA 44 requires that 

specified mortgage lenders annually collect and accurately report mortgage lending data in 

order to determine whether institutions are serving the housing needs of their communities, to 

aid in targeting public investment, and to identify possible discriminatory lending patterns and 

enforce fair lending laws. 

In addition, Fair Lending is charged with "coordinating fair lending efforts of the Bureau with 

other federal agencies and state regulators, as appropriate, to promote consistent, efficient, and 

effective enforcement of federal fair lending laws,,4s and '\vorking with private industry, fa ir 

lending, civil rights, consumer and community advocates on the promotion of fair lending 

compliance and education.,,46 The Dodd-Frank Act also mandates "annual reports to Congress 

42 Dodd-Frank Act, § 1013(C)(2)(A). 

43 See 15 U.S.c. § 1691 et seq. 

44 See 12 U.S.C. § 2801 et seq. 

4S Dodd-Frank Act, § 1013(c)(2)(B). 

46 Oodd-FrankAct, § IOI3{C){2){C). 

70 SEMI·ANNUAl REPORT OF THE CFPB, MARCH 2013 
478 


on the efforts of the Bureau to fulfill its fa ir lending mandate"47 and transfers to the CFPB 

annual reporting responsibilities set forth in ECQA 48 and HftWA.49 

Pursuant to the Dodd-Frank Act's requirement that the Bureau report to Congress annually on 

its efforts to fulfill its fair lending missionso, the Bureau submitted its Fair Lending Report in 

December 2012 in satisfaction of both this requirement and the Bureau's reporting 

requirements under ECOAand HMDA. The inaugural Fair Lending Report described the 

Bureau's first-year accomplishments in fair lending, which included - among other things -

establishment of the Office of Fair Lending, commencement of the CFPB's fair lending 

supenrision program and completion of various levels of fair lending reviews at dozens ofbank 

and nonbank institutions offering a variety of lending products, development of the CFPB's fair 

lending enforcement program, and initiation of fair lending investigations. 

In this update, we focus on highlights from our fair lending supervision program, a recent fair 

lending enforcement action, and interagency coordination activity. 

7.1 Fair Lending Supervision 

With respect to ECOA, the CFPB has discovered that some institutions have inadequate fair 

lending compliance programs. In order to avoid potential fair lending compliance issues, every 

financial institution should establish fair lending policies, procedures and internal controls 

which are tailored to the particular institution's size and operations, in order to ensure that it is 

operating in compliance with ECOA and its implementing Regulation B, in all of the financial 

institution's relevant lines ofbllsiness. Additionally, CFPB examiners have identified several 

institutions with significant error rates in data reported pursuant to HMDA. HMDA data plays a 

key role in the work of the CFPB's examination teams and Fair Lending, as well as other 

47 Dodd-Frank Act, § IOI3(c)(2)(O). 

48 See 15 U.S.C. § 1691f. 

49 See 12 U.S.C. § 2807. 

SO Dodd-Frank Act, § IOI3(C)(2){O). 

71 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
479 


regulatory agencies. Lenders that do not accurately report data under HMDA violate the law, 

and hinder regulators' and the public's ability to compare mortgage data across the industry in a 

meaningful way. 

7.2 Fair Lending Enforcement 

As discussed in the section on Enforcement above, on October 1, 2012, the CFPB - together with 

federal and state partners - announced a public enforcement action against American Express. 

The CFPB announced that it had issued orders requiring three American Express subsidiaries 

to, among other things, refund an estimated $85 million to approximately 250,000 customers 

and pay a civil money penalty of $14.1 million to the CFPB for violations of consumer protection 

laws. Fair Lending, working closely with Supervision and Enforcement colleagues within the 

Bureau, addressed practices at one subsidiary involving the use of a credit scoring system that 

took age into account when evaluating applicants. The CFPB found that the subsidiary, 

American Express Centurion Bank, discriminated against applicants on the basis of age because 

its credit scoring system did not comply with ECOA and its implementing regulation. 

The Consent Order required American Express Centurion Bank to take all action necessary to 

eliminate violations of ECOA and ensure full compliance with the law. Specifically, American 

Express Centurion Bank will not unlawfully discriminate based on age in credit decisions and 

will also be required to certify that all qualified consumers who suffered unlawful age 

discrimination have an opportunity to reapply for a card. 

7.3 Interagency Fair Lending Coordination 

Fair lending supervision and enforcement requires close partnerships and coordination both 

among the various divisions and offices within the Bureau, as well as among the Bureau's many 

federal and state regulatory and enforcement partners. Recently, recognizing that effective 

cooperation is important to protect consumcrs, prevcnt duplication of efforts, and provide 

consistent enforcement of federal fa ir lending laws, the CFPB formalized its fair lending 

enforcement relationship with the Civil Rights Division of the United States Department of 

Justice via an MOU. 

n SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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The CFPB has also engaged in a variety of efforts to coordinate with other federal supervisory 

and enforcement agencies, and has begun outreach to state agencies. Those efforts include 

joining the U.S. Department of Justice, HUD, the Federal Reserve, and the National Association 

of Attorneys General as a co-chair of the Federal Financial Fraud Enforcement Task Force's 

Non-Discrimination Working Group. The Task Force brings together representatives from law 

enforcement agencies, regulatol)' authorities, inspectors general, and state attorneys general to 

combat financial fraud. The CFPB also participates in the Federal Interagency Task Force on 

Fair Lending, which brings together various federal regulatory agencies51 to discuss and 

coordinate fair lending activities. 

The CFPB is committed to working with federal and state partners to ensure that all instances of 

unlawful discrimination in lending and unequal access to credit are appropriately addressed. 

51 The following agencies also participate in the Federal InteragencyTask Force on Fair Lending: HVD, the U.S. 

Department of Justire, the OCC, the Federal Reselye, the FDIC, the Federal Housing Finance Agency, the NCVA, and 

the FIe. 

73 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
481 


8. Building a Great Institution: 

Update 

The CFPB strives to promote transparency, accountability, and fairness. Built on these values, 

the CFPB is better able to make consumer financial markets work for consumers, honest 

businesses, and the economy. 

8.1 Open Government 

A key mission of the CFPB is to make consumer financial products and services more 

transparent in the consumer marketplace. The CFPB strives to lead by example by being 

transparent vvith respect to its own activities. 

The Bureau's website is its primary vehicle for sharing information. For example, the Bureau 

posts the following information on consumerfinance.gov: 

Leadership Calendars 

The CFPB is committed to letting consumers know the daily schedules of its senior 

leadership. The Bureau posts the monthly calendars of its Director and Deputy Director 

on its website. To further the usefulness of these calendars, the Bureau provides the 

calendars in multiple formats

52 on a monthly basis. 

Budgl1: Updates 

The CFPB has published regular quarterly budget updates on its website, including 

financial reports for each quarter of the fiscal year, three fiscal years' worth of funding 

52 E.g. inleractirc/web-based, ics file. RSS feed and Adode pdf. 

74 SEMI-ANNUAl REPORT OF THE CFPB. MARCH 2013 
482 


requests and acknowledgements, and information about the Bureau's Civil Penalty Fund 

that was created under the Dodd-Frank Act. 

General Reports 

The CFPB publishes a variety of reports to document challenges observed in the 

consumer financial marketplace, to present empirical findings to policymakers, and to 

illustrate progress in specific areas. Recently published reports concern reverse 

mortgages, private education loans, an analysis of differences between consumer and 

creditor-purchased credit scores, a report on the credit reporting marketplace, the 

annual report of the CFPB Student Loan Ombudsman, and a report on student loan 

sclVicing and the cost to our men and women in uniform. S3 Additionally, the CFPB 

posted a list of depository institutions and depository affiliates of depository institutions 

under its supervisory authority. Finally, in certain instances, the Bureau publicizes 

petitions made to modify or set aside civil investigative demand actions. 

Guidance Updates 

From time to time, the CFPB will publish specific materials providing guidance to 

industry and members of the public. In 2012, the Bureau provided additional guidance 

on its website in the form of a Statement of Intent for sharing information with state 

banking and financial sclVice£ regulators, a bulletin regarding FCRA's streamlined 

process requirement for consumers to obtain free annual credit reports, a bulletin 

regarding implementation of the remittance rule, a bulletin regarding appeals of 

supelVisory matters, a bulletin regarding the marketing of credit card add-on products, a 

final policy statement on the publication of credit card complaint data, interagency 

guidance on mortgage servicing practice£ concerning military homeowners with 

Permanent Change of Station Orders and a supervisory coordination MOU with the 

Federal Re£erve Board, FDIC, NCUAand OCC. ~ Additionally, the Bureau has posted 

information about its Amicus program, the briefs filed in court, and the Information 

Quality Guidelines that illustrate how the Bureau strive£ to ensure and maximize the 

quality, objectivity, utility and integrity of the information it disseminates to the public. 

53 SeeAppendix E for a list of all the reports published in 2012 by the CFPB. 

54 All guidance documenlsand MOUs may be found al cOllsumerfinance.gov/guidance/. 

75 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
483 


9. Budget 

The Bureau is committed to fulfilling its statutory responsibilities and delivering value to 

American consumers by being accountable and llsing our resources wisely and carefully. 

The CFPB's Operations Division is responsible for coordinating activities related to the 

development of the CFPB's annual budget. The Office of the Chief Financial Officer within the 

Division has primary responsibility for developing the budget, and works in close partnership 

with the Office of Human Capital, the Office of Procurement, the Technology and Innovation 

team, and other program offices to develop budget and staffing estimates in consideration of 

statutory requirements, performance goals, and priorities of the Bureau. The CFPB Director 

ultimately approves the CFPB budget. 

9.1 How the CFPB is Funded 

The CFPB is funded principally by transfers from the Board of Governors of the Federal Reserve 

System, up to the limits set forth in the Dodd-Frank Act. The Director of the CFPB requests 

transfers from the Federal Reserve System in amounts that are reasonably necessary to cany out 

the Bureau's mission. Annual funding from the Federal Reserve System is capped at a fixed 

percentage of the total 2009 operating expense.<; of the Federal Reserve System, equal to: 

10% ofthe.<;e Federal Reserve System expenses (or approximately $498 million) in fiscal 

year (FY) 2011; 

11% of these expense.<; (or approximately $547.8 million) in FY 2012; and 

76 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
484 


12% of these expenses (or approximately $597.6 million) in FY 2013 and each year 

thereafter, subject to annual adjustments. 55 

As, of December 31, 2012, the CFPB had requested transfers from the Federal Reserve totaling 

$136.2 million to fund CFPB operations and activities for the first quarter of FY 2013. 56These 

funds are held in an account for the Bureau at the Federal Reserve Bank of Nevi York. 

Bureau funds that are not funding current needs of the CFPB are invested in Treasury securities. 

Earnings from those investments are also deposited into the Bureau's account. 57 

If the authorized transfers from the Federal Reserve are not sufficient in FY 2010-2014, the 

CFPB has the authority to ask Congress for up to $200 million in additional funds, subject to the 

appropriations process. 58 The CFPB did not request an appropriation in FY 2011 or FY 2012 and 

does not plan to request one in FY 2013 or FY 2014. 

Pursuant to the Dodd-Frank Act, the CFPB is also authorized to collect and retain for specified 

purposes civil penalties collected from any person in any judicial or administrative action under 

federal consumer financial laws. S9 The CFPB generally is authorized to use these funds for 

payments to victims of activities for which civil penalties have been imposed, but may also use 

the funds for purposes of consumer education and financial literacy programs under certain 

circumstances. The CFPB maintains a separate account for these funds at the Federal Reserve 

Bank ofNe\v York. 

In the fourth quarter of FY 2012, the CFPB conducted major enforcement actions against Capital 

One Bank and Discover, which resulted in the institutions entering into two separate consent 

orders. The institutions agreed to pay a total of $32 million in civil monetary penalties to the 

CFPB, and also agreed to provide other relief directly to consumers. 

SS See DOOd-FrnnkAct, Pub. L No. 1lI-203, Sec. 1017(a)(2). 

56 The Bureau posts all funding request letters on its website at consumerfiuanre.gov/budget. 

57 See Dodd-Frank Act, Pub. L. No. 111-203, Sec. 1017{h). 

58 See id. Sec. I017(e). 

59 See id. Sec. I017(d). 

77 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
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In the first quarter of FY 2013, the CFPB also settled enforcement actions against American 

Express and PLDS, which resulted in the institutions entering into four separate consent orders. 

American Express agreed to pay a total of $14.1 million in civil penalties toCFPB and to provide 

relief directly to consumers identified in the action. PLDS agreed to pay a total of $5,000 in civil 

penalties to CFPB and provide $100,000 in redress for hanned consumers. 

9.1.1 Fiscal Year 2013 Spending 

As of December 31, 2012, the end of the first quarter ofFY 2013, the CFPB had spent $85.9 

million (including commitments, obligations, and outlays) for FY 2013. The CFPB spent 

approximately $45 million on employee compensation and benefits for the 1,073 CFPB 

employees who were on-board as of December 15, 2012. 

In addition to pa)Toll expenses, the largest obligations for the first quarter of FY 2013 were 

related to contractual services. Large obligations of $1 million and over made during the first 

quarter ofFY 2013 to both government and non-government vendors included: 

$7.5 million to the Department of Treasury for cross-servicing of various human 

resource and financial management services, such as core financial accounting, 

transaction processing and reporting, travel and payroll; 

$3.5 million for maintaining ongoing operations of the CFPB's consumer contact center 

and enhancements to the case management database; 

$3.5 million for facility operations and maintenance costs for the CFPB's headquarters 

building; 

$1.5 million for electricity at CFPB headquarters; 

$l.4 million for security services at CFPB headquarters; and 

$1.2 million for management and consulting services for the CFPB's Office of Consumer 

Response. 

78 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
486 


TABLE 4: BREAKS OUT YEAR·TO-OATE SPENDING BY EXPENSE CATEGORY 

Expense Category FY 2013 Spending to Date' 

Personnel Compensation 535,323,000 

8enem Compensation 9,605,000 

Travel 2,569,000 

TranslXlrtation of Things 15,000 

Rents, Communications, Utilities & Misc 3,635,000 

Printing and Reproduction 72,000 

Other Contractual Services 28,865,000 

Suppies & Materials 836,000 

Equipment 5,002,000 

Total (as of 12131112) $85,922,000 

'Include;; open rommitments for procurements for which a w.ndor has not yet been determined 

and funds have not yet been obligated. 

TABLE 5: TABlE 9 BREAKS OUT 2013 YEAR·TO·OATESPENDING BY DIVISION/PROGRAM AREA 

DIvIsion/Program Area FY 2013 Spending to Date 

Office of the Director S1 ,231 ,000 

Operations 

Consumer Education & Ergagement 2,585,000 

Research, Markets & Regulations 7,910,000 

SuperviSion, Enforcement, Fair Lending 22,857,000 

Legal Division 2,521 ,000 

79 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
487 


External Affairs 1,066,000 

Ombudsman 95,000 

Centralized Services 60 17,866,000 

Total (as of 12131112) $86,922,000 

9,1.2 Fiscal Year 2012 Spending 

In FY 2012, which ended on September 30, 2012, the CFPB incurred $299.76 million in 

obligations.

61 Approximately $134 million was spent on employee compensation and benefits 

for the 970 CFPB employees on-board by September 30, 2012. 

In addition to payroll expenses, the largest obligations for FY 2012 were related to other 

contractual services, such as administrative services provided by other Federal agencies, 

including the Department of Treasury. 

As required by the Dodd-Frank Act, the CFPB prepared financial statements for FY 2012. The 

Government Accountability Office (GAO) rendered an unqualified, or "dean

n audit opinion on 

the CFPB's financial statements. GAO noted no material weaknesses or significant deficiencies 

in CFPB's internal controls and cited no instances of noncompliance with laws and regulations. 

The CFPB financial statements and GAO's opinion are available in the Financial Report of the 

CFPB for FY 2012. 

00 Centralized services include the cost of certain administratiw and operational sel'\lces provided centrally to other 

Divisions (e.g., building space, utilities, and IT-related equipment and sel'\ices), 

61 Budget and spending infonnalion is available at ronsumerfinance.gol'/budget. 

80 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
488 


TABLE 6: BREAKSQUT FINAL FY 2012 SPENDING BY EXPENSE CATEGORY 

Expense Category FY 2012 Spending 

Personnel Compensation S99,464,000 

8enem Compensation 34,727,000 

Travel 10,117,000 

TranslXlrtation of Thir.;Js 166,000 

Rents, Communications, Utilities & Misc 1,514,000 

Printing and Reproduction 1,693,000 

Ott"er Contractual Services 134,933,000 

Suppies & Materials 2,556,000 

Equipment 14,590,000 

Tolal (as of Il30l12) $299,760,000 

TABLE 7: BREAKS OUT FINAL FY 2012 SPENDING BY DIVISIONIPROGRAM AREA 

DIvIsion/Program Area 

Office of the Director 

Operations 

Consumer Education & Ergagement 

Research, Markets & Regulations 

Supervision, Enforcement, Fair Lending 

legal Division 

External Affairs 

61 SEMI·ANNUAl REPORT OF THE CFPB, MARCH 2013 

FY 2012 Spending 

S3,948,000 

73,895,000 

15,036,000 

24,838,000 

83,027,000 

7,821,000 

3,773,000 
489 


Centralized Services 87,422,000 

Total (as of 9130112) $299,780,000 

Some of the Bureau's significant obligations that occurred during F1' 2012 included: 

$19.8 million to Treasury for various administrative support services, including 

information technology and human resource systems support; 

$14.2 million fo r occupancy agreements with other federal agencies; 

$10.3 million for project and administrative management, as well as general consulting 

selVices, to support the Office of the Chief Information Officer through the end of fY 

2013; 

$8.4 million to a contractor for the development and operation of the Consumer 

Response System; 

$7.6 million to the Bureau ofthe Public Debt for cross-servicing of various human 

resource and financial management services, such as core financial accounting, 

transaction processing and travel; 

$6.8 million to an information technology contractor for project management support 

selVices; 

$4.0 million to a contractor for hosting, cloud infrastructure, and system administration 

services; and 

$3-9 million to a contractor for human resource support services. 

62 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
490 


10. Diversity and Excellence 

10.1 Recruiting and Hiring 

Over the past year, the CFPB has pursued a strategic imperative to recruit and hire highly 

qualified individuals. These efforts have focused on filling vacancies at its headquarters in 

Washington, DC, and in its examiner workforce distributed across the country. The Bureau's 

examiners are organized by regions and anchored by key strategic satellite offices in three of the 

nation's financial hubs - Chicago, IL; New York, NY; and San Francisco, CA. As of December 15, 

2012, there were 1,073 staff on-board and working to carryont the CFPB's mission. These 

include approximately 230 highly qualified regulators, researchers, lawyers, and market 

practitioners who transferred to the CFPB from consumer protection divisions of the prudential 

regulators and other federal agencies. 

N; the Bureau continues to grow, the CFPB has implemented a strategic recruiting plan that 

enhances formal recruiting efforts62 to ensure a sustainable pipeline of diverse candidates for 

occupations across the Bureau. This strategy includes: 

Conducting significant and broad outreach at over 60 universities and affinity group 

events to introduce potential employees to the mission, vision, and values of the CFPB; 

Establishing a flagship jobs website to provide candidates with information about 

employment opportunities across CFPB divisions; 

Utilizing over 200 existing staff as recruiters to share their experiences with potential 

employees; 

62 These inclnde utilizing USAJobs and the posting of job annOlln~mellts on the CFPB website at 

ronsumerfinance.gov/jobs/. 

63 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
491 


Using social media to connect with potential employees and spread information about 

employment opportunities at the CFPB; 

Enlisting senior leadership to host outreach events to attract people to the CFPB as a 

~best place to serve"; 

Creating professional development programs to build a robust pipeline of talent to meet 

current and emerging workforce needs, such as the Presidential Management Fellows, 

Director's Financial Analysts and Honors Attorney programs, as well as a 51-person 

summer intern program; 

Partnering with diversity and professional groups such as the Hispanic National Bar 

Association and the Partnership for Public SelVice to conduct online and in person 

infonnation sessions about applying for careers with the CFPB and other federal 

agencies; 

Employing a novel strategy of reaching candidates through focused social media and 

relevant print and online publications; 

Working closely with our colleagues to help prospective employees get a sense for the 

CFPB culture and employee experience; and 

Working closely with our colleagues in design, technology, and consumer engagement to 

develop an employer identity that invites people to learn more about the work of the 

CFPB. 

84 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
492 


FIGURE8: QUARTERLY GROwrH OF CFPB POSITIONS FILLED THROUGH DECEMBER 15, 2012 

'" w 

w 

9 

.. 

:!; 

w 

FY,1 FY11 FY11 FY'1 FY12 FY12 FY12 FY12 FY13 

m ru 00 ~ m ru 00 ~ m 

FISCAL YEARS 2011-2013 

10.2 Staff Education, Training and 

Engagement 

Since its creation, the CFPB has focused on strong engagement with existing and potential 

Bureau staff, successfully utilizing education, training, and engagement programs. A5 the CFPB 

matures, it continues to build and offer: 

Robust programs that aim to keep its employees current on the latest skills they need to 

conduct their work and he sucCf5sful; 

Vehicles for full participation in a vibrant culhlre that adheres to the CFPB's values of 

Serve, Lead, and Innovate, and that fosters the successful achievement of its mission; 

Management training and process support for performance management to provide 

employees with clear performance plans and objectives, and meaningful feedback on 

their performance; and 

Programs and methods to ensure that the CFPB attracts the best, brightest, and most 

diverse group possible to carry out its mission. 

65 SEMI·ANNUAl REPORT OF THE CFPB, MARCH 2013 
493 


The CFPB is developing a learning environment tailored to meet the specific needs of the 

Bureau's divisions and the individuals within them. 

In addition, the Bureau's Office of Human Capital (OHC) is working to identify, cultivate, and 

sustain a diverse workforce and inclusive work environment. OHC is committed to a culture that 

encourages collaboration and fairness, and leverages diversity throughout the organization so 

that all individuals are equipped to Serve, Lead, and Innovate. 

10.3 Diversity 

Diversity has been a cornerstone of the CFPB's foundation, its strategic workforce planning 

programs, and its contracting since its establishment. In January 2012, the Bureau formally 

established The Office of Minority and Women Inclusion (OMWl) to ensure that inclusion 

continues to inform its work, and in April 2012 hired the first Director for this office. 

The OMWI focuses on developing and refining standards for: 

Equal employment opportunity, workforce diversity, and inclusion at all levels of the 

Bureau; 

Increased participation of minority-owned and women-Qwned businesses in theCFPB's 

programs and contracts; and 

Assessing the diversity policies and practices of entities that the CFPB regulates. 

10.3.1 Diversity in the CFPB's Workforce 

As of December 15, 2012, the CFPB's workforce is 48% women and 52% men. Minorities 

comprise 34% of the CFPB workforce. 

86 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
494 


FIGURE9: BUREAU-WIDE GENDER AND MINORITY STATISTICS TO FIRREACOMPARISQNS 

48% 

Female 

I 

Female FIRREA Comparison 

FIRREA Comparison 

Figure 963 compares CFPB's workforce to the FIRREA community with respect to diversity by 

gender, race, and ethnicity, 

10.3.2 OMWI'S Role at the CFPB 

OMWI helps all parts ofthe Bureau bring diverse perspectives to their work and promotes 

inclusive hiring and contracting practices. 

EMPLOYMENT 

OMWI is responsible for promoting diverse and inclusive employment practices at the Bureau. 

OMWI is collaborating with OHC to develop long-term plans that focus on active participation 

at recruitment and outreach events in order to attract a diverse pool of qualified candidates 

emphasizing diversity from a wide range of American society. 

OMWI is assisting with the development of internal systems and processes that will continually 

support the capability to attract applicants and ensure that the CFPB has the benefit of a diverse 

and qualified pool of candidates for all job openings. To support this effort, OMWI is developing 

63 FIRREA numbeIS as of September 2012. Figure 9 corrq>ares the CFPB 'llith other FIRREA agencies IJ.ith respect to 

the percentage of IJ.'OInen and racial and ethnic minorities in the workforce. 

67 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
495 


strategic partnerships with colleges, universities, professional organizations and affinity groups 

from across the country. O~nVI is working with hiring managers at the CFPB to create 

internship opportunities and entry-level positions that target diverse groups of students around 

the country. 

OM\VI is also collaborating with OHC and the Office of Equal Employment Opportunity (OEEO) 

to develop baseline metries and reporting systems to monitor and analYle the diversity of 

applicants and hires. OMWl is involved in developing the applicant assessment process, 

including exploring the use of methods that will enhance the qualifications review process. 

OM\VI is working with OHC to ensure that employees and supervisors receive diversity training 

to expand awareness, knowledge and cultural competencies that aid in the understanding and 

management of a diverse workforce and its value to the CFPB mission. 

OM\VI is collaborating with OHC and division heads to promote policies, practices, and 

procedures to ensure that all employees are developed to their maximum potential. This is 

accomplished through a comprehensive workforce planning strategy centered around training 

and developmental opportunities, mentoring programs, rotations, lateral moves, and details 

that enhance the skills and key competencies necessary for advancement and success. OM\VI 

works closely with OHC, OEEO, and department heads in analYling annual employee survey 

results, exit inteniew trends and workforce analyties to detennine retention issues and areas of 

opportunity to maintain and grow an inclusive workforce at the CFPB. OMWI also supports 

affinity group development for the CFPB's workforce to further foster collaboration and 

inclusion within the Bureau. 

DIVERSITY AND INCLUSION AT REGULATED ENTITIES 

Under the Dodd Frank Act, OMWl is required to create standards for assessing the diversity and 

inclusion policies and practices of the entities regulated by the CFPB. OM\VI is coordinating 

with fellow OMWI Directors at the FDIC, the Federal Reserve, the NCUA, the oce, and the SEC 

to create these standards. The OMWls have met with stakeholders from the banking and finance 

community, as well as with advocacy and community organizations to discuss methods to 

develop the standards. 

EXTERNAL AFFAIRS AND COMMUNICATION 

In collaboration with External Affairs, OMWI conducts outreach to consumer groups, advocacy 

organizations and other stakeholders to develop strong and productive partnerships. These 

68 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
496 


meetings serve as forums to discuss concerns and issues such as those related to minority and 

women-owned business contracting opportunities with the Bureau, as well as opportunities 

v.'ithin the regulated entities. OMWI and the Procurement Office will continue to develop 

productive relationships with the representatives of the communities that we SClVe. 

PROCUREMENT 

The Procurement Office is currently measuring obligations for certain small business contracts 

awarded to minority-owned small disadvantaged businesses and women-owned small 

businesses. During FY 2012, the Bureau awarded 27% of contract dollars to small businesses.64 

AI; shown in Table 8, of the total contract dollars awarded in FY 2012, 9%65 went to small 

disadvantaged businesses, with a substantial majority of that 9%(£, being awarded to certified 

8(a) minority-owned firms. Additionally, 6.5%67 of total contract dollars went to woman-owned 

small businesses. 

TABLE 8: CONTRACT DOLLARS AWARDED TO SMALL BUSINESS BY TYPE 

Obligated dollars' 

Small disadv"antaged business $7 M 

Woman-owned small business $5 M 

Service disabled veteran owned small business $4 M 

HubZone small business $1 M 

"Dollars may apply to multiple socio-economiccategories. 

64 Approximately $21 million. 

65 Approximately $7 million. 

(£, 85% of contract dollars awarded to small disadvantaged businesses, or approximately $6 million, ", .. ere awarded 10 

certified 8(a) minority-owned firms. 

67 Approximately $5 million. 

69 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
497 


Coordinating with OMM, the Procurement Office is developing an external website presence 

with a forecast of procurement opportunities. Many small and minority-owned businesses may 

find trying to do business with the Federal Government difficult and unclear. In an effort to 

increase transparency, both offices are working together to provide a forum for Frequently 

Asked Questions, and are partnering with our fellow FIRREA partners in developing a joint 

training event on "how to do business with the Federal Government," targeting small, minority 

and woman-owned businesses. 

90 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
498 


APPENDIX A 

More about the CFPB 

GENERAL INFORMATION: 

Email Address: info@con5umerfinance.gov 

Phone Number: (202) 435-7000 

Mailing Address: 

Consumer Financial Protection Bureau 

ATIN: Employee Name, Division, and/or Office Number 

1700 G Street, NW 

Washington, DC 20552 

CONSUMER RESPONSE: 

Hours of Operation: 8 am -8 pm m 

Toll Free Number: (855) 411-CFPB (2372) 

Espanol: (855) 411-CFPB (2372) 

TIY(fDD: (855) 729-CFPB (2372) 

Fax Number: (855) 237-2392 

• MAILING ADDRESS: 

91 

Consumer Financial Protection Bureau 

PC Box 4503 

Iowa City, Iowa 52244 

WHISTLEBLOWERS: 

Email: whistleblower@consumerfinance.gov 

Toll Free Number: 855-695-7974 

SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
499 


.1 

PRESS & MEDIA REQUESTS: 

Email: prcss@consumerfinance.gov 

OFFICE OF LEGISLATIVE AFFAIRS: 

Legislative Affa irs: 202-435-7960 

CFPB OMBUDSMAN'S OFFICE: 

Email: CFl'BOmbudsman@clpb.gov 

Webpage: (:onsumerfinance.gov /ombudsman 

Toll Free Number: (855) 830-7880 

Fax Number: (202) 435-7888 

92 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
500 


APPENDIX B 

Statutory Reporting 

Requirements 

This Appendix provides a guide to the Bureau's response to the reporting requirements of 

Section 1016(c) of the Dodd-Frank Act. The sections of the report identified below respond to 

Section 1016(c)'s requirements. 

Reporting Requirement Section 

A discussion of the significant problems Consumer Challer.;;le5 in faced by consumers in shopping for or 

attaining consumer financial products or Ot;(aining Financial Products and 

services Services - Shopping Cha llenges 

Building a Great Insmution: 

2 A justification of the Bureau's budget Update - Budget; 

request for the previous year Apperdix H - FinarK:ial ard 

BlXlget Reports 

A list of sjgn~icant rules and orders 

adopted by the Bureau, as well as other 

significant n~iatives conducted by the Apperdix C - Sign~icant Rules, 3 Bureau, during the preceding year, and the Orders, and Initiatives plan of the Bureau for rules, orders, or 

other initiatives to be undertaken during the 

up:::oming period 

An analysis of complaints about consumer 

financial products or services that the Consumer Challenges in 

4 Bureau has received ard collected in ~s Obtaining Financial Products ard 

central database on complaints during the Services - Consumer Correrns 

preceding year 

93 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 

36-39 

76-82 

109-10 

95-100 

12-36 
501 


A list, w~h a brief statement of the issues, 

5 of the public supervisory and enforcement Public Supervisory and 

actions to wtlich the Bureau was a party Enforcement Actions 

during the ~ecedi ng year 

Appmjix D - Actions Taken 

The actions taken regarding rules, orders, Regarding RlJes, Orders, aOO 

6 aOO supervisory actions w~h respect 10 $upeNisory Actions wilh Respect 

covered persons which are I'd: credit to Covered Persons VlJhich Are 

unions or delXlSitory inst~Liioos Not Cred~ Unions or Depository 

lnsmutions 

An assessment of significant actions by 

N/Ass 7 State attorneys general or State regulators 

relating to Federal consumer finarx:ial law 

An analysis of the Bureau's efforts to fulfill Delivering for American 

8 its fair IeOOing mission CoOSl..lTlers and Leveling the 

Playing Field - Fair Lerding 

An analysis of the Bureau's efforts to Building a Great Institution: 

9 increase workforce and contracting Update - Diversity and divers~y consistent with the procedures Excellence established by OMWI 

68 The Bureau bas uollearned of any such actions lhal have been filed bel .... 'CCn January 1, 2012 and December 31, 

2012. 

94 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 

66-69 

101-02 

NlA 

70-73 

83-90 
502 


APPENDIX C: 

Significant Rules, Orders, 

and Initiatives" 

Section I016(c)(3) requirt5 "a list of significant rules and orders adopted by the Bureau, as well 

as other significant initiatives conducted by the Bureau, during the preceding year and the plan 

of the Bureau for rules, orders or other initiatives to be undertaken during the upcoming 

period. ~ 

In the past year, the Bureau proposed or adopted the following significant rules and orders and 

conducted the following significant initiatives70: 

Rules (proposed and final) to implement Dodd-Frank Act protections concerning 

consumer remittance transfers to foreign countries; 

Final rule temporarily delaying the effective date of the CFPB's final rule on remittance 

transfers; 

Rules to implement Dodd-Frank Act provisions on the following: 

D Ability to Repay/Qualified Mortgages (final rule); 

Cl Escrows (final rule); 

Cl Appraisal requirements for higher-risk mortgages (interagency) under TILA 

(proposed and final rules); 

Cl Appraisal requirements under ECOA (proposed and final rules); 

69 Links to fina l rules, proposed rules and guidance doruments are available from the CFPB's website, available at: 

ronsumerfinance.gov/regulations/. 

70 To provide a more complete description of the Bureau's .... "()rk during this period, this Appendix also discusses rules 

issued in January 2013. In addition, to better infonn the public, this Appendix contains a discussion of a broad range 

of rulemakings, orders, and initia tives, which may not be defined as 'significan ~ for other purposes. 

95 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
503 


I:l High-cost mortgage loans under HOEPA (proposed and final rules); 

I:l Loan originator compensation (proposed and final rules); and 

I:l Mortgage loan servicing (proposed and final rules). 

Proposed rule combining certain disclosures that consumers receive under TlLA and 

RES PA in applying for and closing on a mortgage loan; 

Final rule delaying the implementation date for certain new mortgage disclosure 

requirements in order for those requirements to be implemented with the Bureau's final 

rule integrating mortgage disclosures under TILA and RESPA; 

Concurrently with issuing the final Abilityto Repay/Qualifi ed Mortgage rule, a proposed 

rule proposing amendments to the final rule, including exemptions for certain nonprofit 

creditors and certain homeownership stabilization programs, and an additional 

definition of a qualified mortgage fo r certain loans made and held in portfolio by small 

creditors. The Bureau also sought feedback on whether additional clarification is needed 

regarding the inclusion of Joan originator compensation in the points and fees 

calculation; 

Proposed rule amending the rules implementing the credit card ability to pay provisions 

ofTILA to address concerns that the current rule unduly limits the ability of spouses and 

partners not working outside the home to obtain credit cards based on the income of the 

other spouse or partner; 

Proposed rule amending the rules implementing TILA's limits on the total amount of 

fees that a credit card issuer may require a consumer to pay during the first year after 

account opening; 

Final rule defining "larger participants" in the debt collection market; 

Final rule defining "larger participantsn in the consumer reporting market; 

Final rules defining procedures for investigations, rules of practice for adjudication 

proceedings; 

Final rule regarding confidential treatment of privileged information; 

Interim final rule ensuring nondiscrimination on the basis of disability in programs and 

activities undertaken by the Bureau; 

Interim final rule regarding supplemental ethics regulations for CFPB employees; 

Advance Notice of Proposed Rulemaking seeking comment, data and infonnation about 

GPR prepaid cards; 

Appointed 25 consumer experts for the CFPB's Consumer Advisot)' Board; 

Began accepting complaints on bank products and serviC{'S, private student loans, 

consumer loans, and credit reporting; 

96 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
504 


Continued to expand information sharing with state regulators; information sharing 

agreements are now in place with 61 state regulatory agencies in 49 states, the District of 

Columbia, and Puerto Rico; 

Entered into an MOU formalizing the CFPB's fair lending enforcement relationship \\~th 

the Civil Rights Di\~sion of the Deparbnent of Justice; 

Entered into an MOU \vith the Fl'C to protect consumers and avoid duplication of 

federal law enforcement and regulatory efforts; 

Entered into an MOU with the prudential regulators to ensure the coordination of 

important aspects of the supenision of insured depository institutions with more than 

$10 billion in assets and their affiliates; 

In collaboration with the Department of Education, released a report to Congress ,vith 

respect to private student loans; 

Issued Bulletin on third-party ser.~ce providers to supervised entities; 

Issued Bulletin regarding marketing of credit card add-on products; 

Issued Bulletin regarding Remittance Rule implementation; 

Issued the Bureau's Supervision and Examination Manual, Version 2.0; 

Issued Examination Appeals Policy; 

Issued examination pl'Oredures for education loans; 

Issued Statement of Intent for sharing information with state banking and financial 

services regulators; 

Launched kk CFPB, an interactive online tool that helps consumers find clear, unbiased 

answers to their financial questions; 

Launched the Consumer Complaint Database; 

Proposed policy to Encourage Trial Disclosure Programs; 

Launched an interactive online tool to allow students and families to compare financial 

aid offers to better understand future debt burdens and navigate paying for college. 

Based on feedback from consumers, institutions of higher education, and other 

stakeholders, new features and improvements have been implemented; 

Released a compliance bulletin regarding the enforcement of ECOA, and recognizing the 

disparate impact doctrine; 

Released a report and consumer guide about reverse mortgages; 

Released a report on the difference in ~educationar credit scores sold to consumers and 

scores sold to and used by creditors; 

Released a white paper describing the credit reporting infrastructure at the three largest 

crroit reporting agencies; 

Released and tested a draft periodic mortgage statement; 

97 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
505 


Request for Comment on Payday Lending Hearing Transcript; 

Request for Information Regarding Complaints From Private Education Loan 

Borrowers; 

Request for Infonnation Regarding Consumer Use of Reverse Mortgages; 

Request for Information Regarding Credit Card Market; 

Request for (nfonnation Regarding lmpacts of Overdraft Programs on Consumers; 

Request for Information Regarding Scope, Methods, and Data Sources for Conducting 

Study of Pre-Dispute Arbitration Agreements; 

RaJuest for Information Regarding Senior Financial Exploitation; 

With the U.S. Department of Defense, the FTC, and the National Association of 

Attorneys General, developed a database to combat consumer financial fraud directed at 

military members, veterans, and their familie'>; 

With the FDIC, the Federal Reserve, the OCX:, and the NCUA, released joint guidance to 

address mortgage selVicer practices that may pose risks to homeowners who are serving 

in the military; 

In 2013, the Bureau also plans to propose or adopt the following significant rules and orders, 

and conduct the following significant initiatives: 

Final rule addressing proposed amendments to the Bureau's Ability to Repay/Qualified 

Mortgage rule and Regulation Z (TILA) to exempt certain nonprofit creditors and certain 

homeownership stabilization programs and to add an additional definition of a qualified 

mortgage for certain loans made and held in portfolio by small creditors. The rule will 

also address whether there is a need for additional clarification regarding the inclusion 

ofloan originator compensation in the points and fees calculation; 

Final rule (proposed in December 2012) amending the CFPB's remittance rule to provide 

additional clarity regarding disclosures and error resolution procedures; 

Rule finalizing a Bureau proposal amending the regulations implementing TlLA's limits 

on the total amount of fees that a credit card issuer may require a consumer to pay 

during the first year after account opening; 

Rule finalizing a Bureau proposal to amend the regulations implementing the credit card 

ability to pay provisions ofTILA to address concerns that the current rule unduly limits 

the ability of spouses and partners not working outside the home to obtain credit cards 

based on the income of the other spouse or partner; 

9a SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
506 


Rules finalizing the restatement of regulations implementing consumer financial 

protection laws transferred from other regulatory agencies to the Bureau by the DoddFrank Act; 

Rules concerning the Consumer Financial Civil Penalty Fund, which will establish 

procedures that the Bureau will follow when allocating funds in the Civil Penalty Fund to 

victims of activities for which civil penalties were imposed under federal consumer 

financiallawsj 

Rules concerning debt collection, which will contain procedures for the Bureau's 

collection of debts owed to the United States; 

Continue to finalize integrated disclosures and accompanying rules for mortgage loans 

that satisfy the requirements of both TILA and RESPAj 

Continue work on possible regulatory streamlining and burden reduction efforts; 

Continue work toward a mlemaking to implement the Dodd-Frank Act amendments to 

HMDA; 

Continue work toward a rulemaking on GPR prepaid cards; 

Continued expansion of the Bureau's capacity to handle consumer complaints with 

respect to all products and services within its authority; 

Enforcement of Nondiscrimination on the Basis of Disability in Programs and Activities 

Conducted by the Bureau of Consumer Financial Protection; 

Enforcement of Nondiscrimination on the Basis of Disability in Programs Receiving 

Financial Assistance from the Bureau; 

Issue reports on private student loans and recommendations on best practices 

concerning financial advisors who work with older Americans, as directed in the DoddFrank Act; 

Issue reports on various aspects of the Bureau's work and operations, including reports 

on Consumer Response, Financial Education, Fair Lending, and Human Capital, among 

others,71 as directed in the Dodd-Frank Act; 

Pilot program to evaluate certain financial education programs in the field; 

Procedures for Filing Claims against the Bureau under the Federal Tort Claims Act for 

loss of or damage to property or for personal injury or death; 

71 SeeAppendix E for reports. 

99 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
507 


Propose additional rules to further define the scope of the Bureau's nonbank supervision 

program; and 

Working jointly with the Federal ReselVe Board, rules finalizing a Board proposal 

regarding the Expedited Funds Availability Act as implemented by Regulation CC. 

100 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
508 


APPENDIX D: 

Actions Taken Regarding 

Rules, Orders, and Supervisory 

Actions with Respect to 

Covered Persons which are 

not Credit Unions or 

Depository Institutions 

Section 10 16(c)( 6) requires a report on ''the actions taken regarding rules, orders and 

supervisory actions with respect to covered persons which are not credit unions or deposito!)' 

institutions." Be!:weenJanuary 1, 2012 and December 31, 2012, the Bureau has taken the 

following actions with respect to such covered persons: 

Final rule defining "larger participants~ in the debt collection market

72; 

Final rule defining "larger participants" in the consumer reporting market 73; and 

Proposed rule regarding procedures for supervising nonbanks that pose risks to 

consumers.74 

72 https:/Iy,wv.'Jederalregisle.r.gov/articies/2012/12/07/2012-29438/defining-larger-partiripants-of-Ihe-ronsumerdebt-rollection -market -correction. 

73 bllps:/ /v.'v{w.federalregisler.gav/artides/'1012/07 /20/2012-17603ldefining-larger-participants-of-the-consumerreporting-mancel . 

101 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
509 


In addition to these items, other Bureau rules issued in 2012 apply to both depository 

institutions and non-depository institutions. 

74 https:!!v.·v,w.federalregisler.gav!artides!Z012!OS!2S!2012-12718!proredural-rules-lo-establish-supenisol1'-

aUlhorily-o\'{!r-certain-nonbank-ro\'ered-l'ersons-based-on. 

102 SEMI-ANNUAl REPORT OF THE CFPB. MARCH 2013 
510 


APPENDIX E 

Reports 

The CFPH published the following reports from January 1, 2012 through December 31, 2012, 

which may be found at consumerfinance.gov/reportsj: 

January 3 0 , 2012: Semi-Annual Report of the CFPB; 

March 20, 2012: Fair Debt Collection Practices Act; 

March 31, 2012: Consumer Response Annual Report; 

April 13, 2012: Plain Writing Compliance Report; 

June 19, 2012: Consumer Response: A Snapshot of Complaints R6:!cived; 

June 28, 2012.: Reverse Mortgage Report; 

July 30,2012.: Semi-Annual Report of the CFPB; 

July 31, 2012: Annual Report to the Committee on Appropriations of the House of 

Representatives; 

August 10, 2012: Final Report of the Small Business Review Panel on CFPB's 

Proposals Under Consideration for Mortgage Servicing Rulemaking; 

August 29, 2.012: Private Student Loans; 

September 2012: AnaiYl'is of Differences beh .. reen Consumer and Creditor- Purchased 

Credit Scores; 

October 10, 2012: Consumer Response: A Snapshot of Complaints Received; 

October 16, 2012: Annual Report of the CFPB Student Loan Ombudsman; 

October 18, 2012: Thc Next Front? The Student Loan Servicing and the Cost to our 

Men and Women in Uniform; 

Odober 31, 2012: II ~rvisoty Highlights: Fall 2012; 

November 13. 2012: Independent Performance Audit of CFPB Operations and Budget; 

November 15, 2012: Financial Report of the CFPB ~ Fiscal Year 2012; 

December 6, 2012: Fair Lending Report oftheCFPB; 

December 7,2012: 2012 CFPB Annual Employee SUlVey; 

December 13, 2012: Key Dimensions and Pr0ct5ses in the U.S. Credit Reporting System: 

A review of how the nation's largest credit bureaus manage consumer data; and 

December 20, 2012: Growing our Human Capital. 

103 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
511 


APPENDIX F: 

Congressional Testimony 

Senior CFPB staff has testified before Congress a total of 29 times in 2011 and 2012, including 

on the following 17 occasions between January 1, 2012 and December 31,2012, which may be 

found at consumerfinance.gov/speeches: 

January 24, 2012: Richard Cordray before the House Oversight and Government 

Reform Subcommittee on TARP, Financial Services and Bailouts of Public and Private 

Programs; 

January 3 1, 2012: Richard Cordray before the Senatc Banking Committee; 

February 15, 2012: Richard Cordray before the House Financial Services 

Subcommittee on Oversight and Investigations; 

March 29. 2012: Richard Cordray before the House Financial Services Committee; 

April 26, 2012: Camille Susette before the Senatc Homeland Security and 

Governmental Affairs Subcommittee on Oversight of Government Management, the 

Federal Workforce, and the District of Columbia; 

June 6, 2012: Richard Cordray before the Senate Banking Committee; 

June 6, 2012: Gail Hillebrand before the House Financial Services Subcommittee on 

Financial Institutions and Consumer Credit; 

June 20, 2012: Raj Date before the House Financial Services Subcommittee on 

Insurance, Housing, and Community Opportunity; 

June 26, 2012: Holly Petraeus before the Senate Committee on Banking, Housing and 

Urban Affairs; 

July 19, 2012: Raj Date before the House Financial Services Subcommittee on 

Financial Senrices and Consumer Credit; 

July 24, 2012: Rohit Chopra before the Senate Conunittee on Banking, Housing, and 

Urban Affairs; 

July 24,2012: Richard Cordray before the House Oversight and Government Reform 

Subcommittee on TARP, Financial Services, and Bailouts of Public and Private 

Programs; 

Au!,"USt 1, 2012: Richard Cordray before the House Committee on Small Business; 

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September 13, 2012: Richard Cordray before the Senate Committee on Banking, 

Housing, and Urban Affairs; 

September 20, 2012: Richard Cordray before the House Committee on Financial 

Sen'ices; 

November 15, 2012: Hubert H. Sk ~ Humphrey before the Senate Special 

Committee on Aging; and 

December 19, 2012: Corey Stone before the Senate Banking Subcommittee on 

Financial Institutions and Consumer Protection. 

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APPENDIX G 

Speeches 

Director Richard Cordray or Deputy Director Raj Date spoke at the following public events 

between January 1, 2012 and December 31,2012, which may be found at 

consumerfinance.gov/speeches: 

January 5, 2012: Remarks by Richard Cordray at The Brookings Institution in 

Washington, DC; 

January 17, 2.012: Remarks by Richard Cordray at FDIC Board of Directors in 

Washington, DC; 

January 18, 2.012: Remarks by Richard Cordray at U.S. Conference of Mayors in 

Washington, DC; 

January 19, 2012: Remarks by Richard Cordray at Payday Loan Field Hearing in 

Birmingham, AL; 

February 15, 2012: Remarks by Richard Cordray at League of United Latin American 

Citizens Conference in Washington, DC; 

February 22,2012.: Remarks by Richard Cordray at CFPS Roundtable on Overdraft 

Practices in New York, NY; 

March 6, 2012: Remarks by Richard Cordray at National Association of Attorneys 

General in Washington, DC; 

March 14, 2012: Remarks by Richard Cordray at Independent Community Bankers of 

America National Convention in Nashville, Th'; 

March 16, 2012: Remarks by Richard Cordray at Society of American Business Editors 

and Writers in Indianapolis, IN; 

March 19, 2012: Remarks by Richard Cordray at Credit Union National Association 

Governmental Affairs Conference in Washington, DC; 

March 21, 2012: Remarks by Richard Cordray at Consumer Bankers Association in 

Austin, TX; 

March 28, 2012: Remarks by Richard Cordray at U.S. Chamber of Commerce in 

Washington, DC; 

April 10, 2012: Remarks by Richard Cordray at Operation Hope in Washington, DC; 

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April 11, 2012: Remarks by Richard Cordray on the launch of the Financial Aid 

Comparison Shopper in Sioux Falls, SO; 

April 18, 2012 : Remarks by Richard Cordray at the National Community Reinvestment 

Coalition in Washington, DC; 

April 18, 2012: Remarks by Richard Cordray at Jump$tart in Washington, DC; 

April 20, 201 2: Remarks by Raj Date at Greenlining Institute Conference in Los 

Angeles, CAj 

May 3, 2012: Remarks by Richard Cordray at 2012 Simon New York City Conference in 

New York, NY; 

May 7, 2012: Remarks by Raj Date at Mortgage Bankers Association National 

Secondary Market Conference in New York, NY; 

May 10, 2012: Remarks by Richard Cordray at the White House Financial Summit in 

Washington, DC; 

May 11, 2012: Remarks by Richard Cordray at Michigan State University College of Law 

Commencement in East lansing, MI; 

May 23. 2012: Remarks by Richard Cordray at CFPB Prepaid Cards Field Hearing in 

Durham, NC; 

June 5, 2012: Remarks by Richard Cordray at a White House press briefing on student 

loan transparency in Washington, DC; 

June 11 , 2012: Remarks by Raj Date at Arnerican Bankers Association Conference in 

Orlando, FL; 

June 14. 20.2: Remarks by Richard Cordray at World Elder Abuse Awareness Day 

E\'cnt in Washington, DC; 

June 15, 2012: Remarks by Richard Cordray at American Constitution Society 

Conference in Washington, DC; 

June 21, 2012: Remarks by Richard Cordray at a press conference on Military 

Permanent Change of Station (PCS) Guidance for Mortgage Ser\'icers in Washington, 

DCJune 27, 2012: Remarks by Richard Cordray on Reverse Mortgages Study in 

Washington, DC; 

July 9, 2012: No Mas: Remarks by Richard Cordray to the National Council of La Raza 

in Las Vegas, Nevada ; 

July 16, 2012: Remarks by Richard Cordray on Credit Reporting at the Credit 

Reporting Field Hearing in Detroit, MI; 

September 20, 2012: Remarks by Richard Cordray at the Corporation for Enterprise 

Development Conference in Washington, DC; 

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September 21. 2012: Remarks by Richard Cordray at the Congressional Black Caucus 

Foundation in Washington. DC; 

September 27. 20J2: Remarks by Richard Cordray at the inaugural Consumer 

Advisory Board meeting in Sf. Louis, MO; 

October 24. 2012: Remarks by Richard Cordray at the Public Field Hearing on Debt 

Collection Practices in Seattle, \VA; 

October 25. 2012: Remarks by Richard Cordray at the National Consumer Law Center 

Conference in Seattle, WA; 

November 14. 2012: Remarks by Richard Cordray on Project Catalyst: Stimulating 

Innovation in Financial Products and Services in Mountain Vie','., CA; 

December 5, 2012: Remarks by Richard Cordray at a press conference with Mayor 

Rahm Emanuel in Chicago, IL; and 

December 13, 2012: Prepared remarks by Richard Cordray on a credit reporting white 

paper press call. 

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APPENDIX H: 

Financial and Budget Reports 

The CFPS has published the following financial reports from January I, 2012 through December 

31,2012, which are all available at consumerfinance.govjhudget: 

January 20, 2012: CFO llpdatefor the first quarter of fiscal year 2012; 

May 11, 2012: CFO update for the second quarter of fiscal year 2012; 

July 27, 2012: CFO update for the third quarteroffiscai yea r 2012; 

November 15, 2012: Financial RCjX)rt of the CFPS Fiscal Year 2012; and 

December 15, 2012: CFO Update for the fourth quarter offlScal year 20 12 

The CFPB has published the following Budget Documents, which are all available at 

consumerfinance.gov/budget: 

Fiscal Year 2013 Budget Justification; 

Fiscal Year 2013 Budget in Brief; 

Fiscal Year 2012 Congressional Budget Justification; and 

Fiscal Year 2012 Budget in Brief. 

The CFPB has published the following funding reque<its to the Federal Reserve Board, from 

January 1,2012 through December 31, 2012, which are all available at 

consumerfinance.gov/budget: 

January 6, 2012: Funding Acknowledgement from the Federal Reserve Board; 

March 30, 2012: Funding Request to the Federal Reserve Board; 

AprilS, 2012: FundingAcknowledgementfrom the Federal Reserve Board; 

July 2, 2012: Funding Requcst to the Federal Resen'e Board; 

July 9, 2012: Funding Acknowledgement from the Federal Reserve Board; 

October 2, 2012: Funding Request to the Federal Resen'e Board; and 

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October 18, 2012: Funding Acknowledgement from the Federal Reserve Board. 75 

75Addilional quarterly funding r€Quests 10 the Federal Reserve Boord and the corresponding funding 

acknowledgemenls from Ihe Federal Resel'\'e Board will be made available al ronsumerfinance.gov,ibudgel. 

110 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013 
518 


APPENDIX I: 

CFPB Organizational Chart 

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=--

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111 SEIoIhIoIIIIU'I. REPOIU OFTHE CFPS. MAAO! 2013 

r 

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519 


APPENDIX J 

Defined Terms 

ACRONYM Defined Term 

APR Annual Percentage Rate 

ARC Academic Research Courcil 

ATM Automated Teller Machine 

BUREAU The Consumer Financial Protection Bureau 

CAB Consumer Advisory Board 

CARD ACT The Credit Card Act 

CBAC Community Bank Act .... isory Council 

CE The (;FP8's Office of Consumer Engagement 

CFPB The Consumer Financial Protection Bureau 

COO Chief Operating Officer 

CUAC Credit Union Advisory Council 

DEP Delayed Entry Program 

DaDD·FRANK ACT The D:ldd-Frank Wall Street Reform and Consumer Protection Act 

EeOA Equal Credit Opportunity Act 

EFTA Electronic Fund Transfer Act 

FCRA Fair Credit Reporting Act 

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FDIC 

FEDERAL RESERVE 

BOARD 

FHFA 

FIRREA 

FTC 

FY 

GAO 

GPR 

HMDA 

HOEPA 

HUD 

MOU 

NCUA 

OA 

OCA 

OCC 

ODEP 

OEED 

OFE 

OHC 

OMWl 

OSA 

The Federal Depos~ Insurance Corporation 

The Board of Governors of the Federal Reserve System 

The Federal Housif)J Finarx:e Agerx;y 

The Finarx:iallnstitulions Reform, Recovery, and Enforcement Act 

The U.s. Federal Trade Commission 

Fiscal year 

Government Accountability Office 

General Purpose Reloadable 

Home Mortgage Disclosure Act 

Home ONnership and Equity Protection Act 

The U.s. Department of Housing aoo Urban Development 

Memoraooum of Understanding 

The National Credit Union Administration 

The CFPB's Office of Older Americans 

The CFPB's Office of Community Affairs 

The U,S. Office of the Com~roller of the Currerx:y 

The U.S. Department of Lat)x's Office of Disability Em~oyment 

Policy 

The CFPB's Office of Equal Employment Opportunity 

The CFPB's Office of Finarx:ial Education 

The CFPB's Office of Human Capital 

The CFPB's Office of Minority aoo Women Inclusion 

The CFPB's Office of Service Member Affairs 

113 SEMI·ANNUAl REPORT OF THE CFPB, MARCH 2013 
521 


PLDS Payday Loan Debt Solutions 

RESPA Real Estate Settlement Procedures Act 

RFI Request for Information 

SAFE ACT The Secure and Fair Enforcement for Mortgage Ucensing Act 

SEC The U.s. Securities and Exchange Commission 

TARP The rou~ed Asset Relief Program 

TILA The Truth in Lending Act 

TISA The Truth in Savil"{ls Act 

TREASURY The U,S. Department of the Treasury 

114 SEMI·ANNUAl REPORT OF THE CFPB. MARCH 2013