CONSUMER FINANCIAL PROTECTION BUREAU

INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT

FOR EXTENSION OF

CFPB’S CONSUMER RESPONSE INTAKE FORM

(OMB CONTROL NUMBER 3170-0011)

TERMS OF CLEARANCE: 

When the Office of Management and Budget (OMB) approved this collection of information in 

November 2011, the OMB Notice Action noted, “Collection was modified to address use of information 

collected and whistleblower references provided.” These changes remain in this submission to OMB.

ABSTRACT

The Intake Form is designed to aid consumers in the submission of complaints, questions, and 

comments and to help the CFPB fulfill the CFPB’s statutory requirements.1 Consumers (hereinafter 

"respondents") will be able to complete and submit information through the Intake Form electronically 

on the CFPB's website. Alternatively, respondents may request that the CFPB email a fillable PDF version 

or, by telephone, request a "paper" copy of the Intake Form, and then email, mail, or fax it to the CFPB. 

The questions within the Intake Form prompt respondents for a description of, and key facts about, the 

complaint at issue, the desired resolution, contact and account information, information about the 

 

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

Treasury/Department Offices form (1505-0241), this approved information collection was transferred to the CFPB 

on November 21, 2011. ICR Reference Number 201111-3170-004; see Pub. L. No. 111-203, Title X, Sections 

1013(b)(3), 1021(c)(2), and 1034, codified at 12 U.S.C. §§ 5493(b)(3), 5511, and 5534.
2 | Page CFPB’s Consumer Response Intake Form

institution they are filing a complaint against, and any previous action taken to attempt to resolve the 

complaint. 

INTRODUCTION

On November 18, 2011, the OMB approved the CFPB’s Consumer Response Intake Form (Intake Form), 

an information collection that has helped the CFPB facilitate the centralized collection of, monitoring of, 

and response to consumer complaints and inquiries about consumer financial products or services.2

 

Followed shortly by the launch of the credit card and mortgage consumer complaint forms, the Bureau 

has since expanded its Intake Form to provide for complaints about: bank accounts and services, private 

student loans, other consumer loans, credit reporting, money transfers, debt collection, payday loans, 

and, most recently, prepaid cards.3

 The CFPB has received more than 400,000 consumer complaints to 

date, an achievement for which the Intake Form has been instrumental. 

Two years later, in November 2013, the OMB approved a generic clearance authority for the CFPB’s 

Office of Consumer Response (Consumer Response) and its collections of information including (1) 

testing new and improved Intake Form questions4 and (2) gathering related information needed for 

appropriate referral of complaints, and (3) conducting user experience feedback surveys.5

 

This submission requests that the CFPB be granted (1) approval of revisions to the existing clearance 

that improve upon the form’s clarity and utility (as informed by the CFPB’s three-year information 

collection undertaking and feedback gathered from the generic clearance) and (2) a three-year 

extension. 

 

2 See supra note 1.

3 Web versions of the Intake Form available online at http://www.consumerfinance.gov/complaint/.

4 In particular, the OMB approved Consumer Response’s ability to pilot new and improved questions on the 

Consumer Response Intake Form (Intake Form). OMB Control No. 3170-0011. Originally approved as a 

Department of Treasury form (OMB Control No. 1505-0241), this approved information collection was transferred 

to the CFPB on November 21, 2011. ICR Reference Number 201111-3170-0004.

5 OMB Control No. 3170-0042.
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A. JUSTIFICATION

1. Circumstances Necessitating the Data Collection

Collecting, investigating, and responding to consumer complaints6 are integral parts of the CFPB’s work.7

 

Not only is this work required of the Agency under the Title X of the Dodd-Frank Wall Street Reform and 

Consumer Protection Act (“Dodd-Frank Act”), this work also helps the CFPB fulfill its obligations to: (1) 

monitor for risks to consumers in the offering or provision of consumer financial products or services, 

including developments in the markets for such products or services; and (2) provide an annual report to 

Congress on complaints received in the prior year regarding such products and services, including 

information about complaint numbers, types, and resolution.8

 The Intake Form, the subject of this 

information collection request, provides the vehicle for the information collection by web, telephone, 

mail, email, and fax.

2. Use of Information

The Intake Form is designed to aid the public in the submission of complaints, inquiries, and feedback to 

the CFPB and to help the CFPB fulfill the aforementioned statutory requirements. Individuals who wish 

to submit complaints, inquiries, and feedback (collectively, respondents) may submit relevant 

information using the CFPB’s website where they will find online versions of the Intake Form. 

Alternatively, respondents may submit information by telephone, mail, email, and fax using the Intake 

Form. The Intake Form’s various fields prompt respondents for a description of, and key facts about, 

their complaints, underlying products and issues, the companies that are the subject of their complaints, 

and any previous action taken on their complaints. Responses to the Intake Form’s questions help 

provide the CFPB with the information needed to reach out to the consumer, consumer’s authorized 

representative (if applicable), and company; and to follow-up on the submitted complaint, inquiry, or 

feedback.

3. Use of Information Technology

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

authorized representatives with the ability to submit their complaints, inquiries, and feedback, 

 

6 Consumer complaints are submissions that express dissatisfaction with, or communicate suspicion of wrongful 

conduct by, an identifiable entity related to a consumer’s personal experience with a financial product or service.

7 See Dodd-Frank Act, Pub. L. No. 111-203, Section 1021(c)(2).

8 Id. § 1022(c); Id. § 1013(b)(3)(C). 
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electronically on the Bureau’s website. The CFPB will continue to use enhancements such as drop down 

menus, error checks, and auto-completion when possible to minimize burden. The CFPB’s U.S.-based 

contact centers provide services to consumers in more than 180 languages and to consumers who are 

deaf, have hearing loss, or have speech disabilities via a toll-free telephone number.

4. Efforts to Identify Duplication

This information collection extension request does not seek to duplicate any other Complaint System 

being developed by other Federal or State agencies. The information collections proposed will improve 

the processing of individual consumer complaints and inquiries by the CFPB. Duplication is further 

minimized as all CFPB information collections are considered and reviewed through an internal 

clearance process which includes several offices within the Agency, including the CFPB’s Office of the 

Chief Information Officer. 

5. Efforts to Minimize Burdens on Small Entities

The information collection is voluntary and is not anticipated to burden small businesses significantly. 

The Intake Form does not require information collection from small businesses or other small entities. 

The only potential impact on small entities is that the CFPB, as required by law, will utilize the 

information obtained from respondents to request responses from, and potentially initiate 

investigations of, entities named in the complaints, some of which may be small entities. 

The CFPB is also tasked with enforcing certain Federal laws that are intended to ensure fair, equitable, 

and nondiscriminatory access to credit, such as the Equal Credit Opportunity Act (“ECOA”). In some 

cases, these laws apply to non-consumer, commercial lending. Small business owners may use the 

Intake Form to submit fair lending complaints to the CFPB.

The CFPB will minimize any burden by requesting readily available information and using plain, short, 

easy-to-complete information collection instruments.

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

Under Dodd-Frank, the CFPB is required to facilitate the centralized collection of, monitoring of, and 

response to consumer complaints regarding consumer financial products or services. The proposed 

collection is voluntary and if the proposed collection is not conducted, the CFPB would not be able to 

fulfill its consumer response mandate. 

7. Circumstances Requiring Special Information Collection

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

with the guidelines in 5 CFR § 1320.5(d)(2).
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8. Consultation Outside the Agency

In accordance with 5 CFR § 1320.8(d)(1), the Bureau has published a notice Federal Register allowing the 

public 60 days to comment on the proposed extension of this currently approved collection of 

information. Further and in accordance with 5 CFR § 1320.5(a)(1)(iv), the Bureau [will] publish a notice 

in the Federal Register allowing the public 30 days to comment on the submission of this information 

collection request to OMB.

Through the use of a generic clearance, the CFPB has developed customized consumer surveys about 

mortgages, credit cards and student loans, and conducted form usability testing.9

 Along with 

experiential data gathered over the past three years, feedback from the public has informed 

improvements to the Intake Form, including collecting additional information about co-borrowers and 

co-signers, gathering college and university information from student loan complainants, and enhancing 

privacy features through the use of security questions.10

9. Payments or Gifts to Respondents

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

10. Assurances of Confidentiality

All information collection activities will be conducted in full compliance with the requirements for the 

protection of the confidentiality of nonpublic information and personally identifiable information and 

for data security and integrity set forth in the federal privacy laws, including the CFPB’s rules (12 C.F.R. § 

1070 et seq.) of the Privacy Act (5 U.S.C. § 552a).11 At the point of information collection, the CFPB’s 

website will explain that personally identifiable information will be kept confidential to the extent 

permitted by law and CFPB rules. The CFPB website privacy policy will further explain the CFPB’s privacy 

practices. For complaints submitted through a CFPB call center, complainants will be told that their 

personally identifiable information will be kept confidential subject to the law and CFPB rules. 

 

9 Generic Clearance for Consumer Complaint and Information Collection System (Testing and Feedback), OMB 

Control Number 3170-0042.

10 See Attachment “Inventory of Questions for the Consumer Financial Protection Bureau’s Consumer Assistance 

Form.”

11 For the related System of Record Notice (SORN), see 

https://www.federalregister.gov/articles/2014/04/16/2014-08555/privacy-act-of-1974-as-amended.
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Telephone complainants who so elect will be read the CFPB’s Privacy Act statement12 or will be guided 

to the CFPB website for the same. 

The CFPB will implement the appropriate security measures to ensure data is safeguarded including the 

use of locked file storage, confidentiality stamping, restricted system access, data encryption, restricted 

print options and disposal by cross-cut shredding. The information system will be fully compliant with 

the Federal Information Security Management Act of 2002 with the security category of “Moderate, 

Moderate, Low.”

On March 20, 2013, CFPB published a Privacy Impact Assessment (PIA) for the Consumer Response 

System. Pursuant to Office of Management and Budget (OMB) Memorandum 07-16, Safeguarding 

Against and Responding to the Breach of Personally Identifiable Information, May 22, 2007, CFPB uses 

PIAs to document how the personally identifiable information (PII) it collects is used, secured, and 

destroyed in a way that protects each individual’s privacy. Each PIA is broken out into sections that 

reflect the CFPB’s Privacy Principles. The CFPB’s Privacy Principles are a set of nine rules the CFPB 

follows when it collects or uses PII. The PIA is posted on CFPB’s website at 

http://files.consumerfinance.gov/f/201303_CFPB_PIA-Consumer-Response-System.pdf. 

 

12 Privacy Act Statement quote: 

The information you provide will permit the Consumer Financial Protection Bureau to process your 

complaint or inquiry Information about your complaint or inquiry (including your personally identifiable 

information) may be shared:

• with the entity that is the subject of your complaint;

• with third parties as necessary to get information relevant to resolving a complaint;

• with a court, a party in litigation, a magistrate, an adjudicative body or administrative tribunal in the 

course of a proceeding, or the Department of Justice;

• with other federal or state agencies or regulatory authorities for enforcement and statutory purposes; 

and

• with contractors, agents, and others authorized by the CFPB to receive this information.

We may also share your complaint or inquiry (but not your personally identifiable information) with the 

public through a public complaint database.

This collection of information is authorized by 12 U.S.C. § 5493.

You are not required to file a complaint or share any identifying information, including your Social Security 

number, and you may withdraw your complaint at any time. However, if you do not include the requested 

information, the CFPB may not be able to process your complaint.
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Additionally, in accordance with the Privacy Act of 1974, as amended, published a Systems of Records 

Notice (SORN) in the Federal Register (79 FR 21440, April 16, 2014). The title for the SORN is CFPB.005—

Consumer Response System. The SORN is available on the Internet at 

https://www.federalregister.gov/articles/2014/04/16/2014-08555/privacy-act-of-1974-as-amended.

Section 1057 of the Dodd-Frank Act provides additional protections for “whistleblowers” who work for 

covered persons or service providers and who experience employer retaliation after providing certain 

information about their employers to the CFPB. The CFPB will take all reasonable steps as permitted by 

law during this information collection process to provide distinct, alternative paths for their complaint 

submissions. Whistleblowers who are employees of the financial institution they are complaining about 

will receive a copy of the relevant Dodd-Frank Act anti-retaliation provision, Section 1057, and will be 

provided with a set of Section 1057 FAQs which explain the whistleblower retaliation protections.13

11. Justification for Sensitive Questions

Complaint intake questions may prompt the respondents for sensitive information such as credit card 

account or other financial account numbers only to facilitate complaint resolution and to minimize the 

burden of follow-up contact with the respondents. For instance, for credit card inquiries or complaints, 

certain account information such as a credit card number may be the most effective way to accurately 

identify the company. For inquiries directed to the national credit reporting bureaus and other financial 

services providers that use Social Security numbers as primary identifiers, consumers will be asked to 

provide their Social Security numbers (SSNs) in order to process their complaint. Oftentimes, it is the 

only effective way for certain respondents to accurately locate the consumer’s relevant financial 

information. Consumers’ SSNs, along with other sensitive financial account identifiers, will be held in an 

encrypted system for their protection.

The CFPB is tasked with enforcing fair lending laws such as the Equal Credit Opportunity Act (“ECOA”). 

ECOA prohibits unlawful discrimination by any creditor against an applicant in a credit transaction based 

on race, color, religion, national origin, sex, marital status, or age. ECOA also prohibits such unlawful 

discrimination by a creditor based on the fact that all or part of the applicant’s income derives from any 

public assistance program or based upon the applicant’s good faith exercise of any right under the 

Consumer Credit Protection Act. For these reasons, complaint intake questions may inquire about these 

factors.

In addition, Section 1013(e)(1)(A) of the Dodd-Frank Act specifically charges the CFPB with the task of 

monitoring complaints by servicemembers and their families. Thus, the Intake Form includes a series of 

questions to help identify and correctly route such complaints. 

 

13 Attachment 2.
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Finally, the Intake Form includes an optional question which prompts the respondent for his or her age. 

Pursuant to the Credit Card Accountability Responsibility and Disclosure Act of 2009 (“CARD Act”), there 

are several statutory protections extended to underage credit card applicants and account holders.14 

Eliciting the respondent’s age will help identify issues related to young consumers and legal competency 

to give consent. Furthermore, the Equal Credit Opportunity Act (“ECOA”) makes it unlawful for any 

creditor to discriminate against an applicant for credit on the basis of age. Collecting information about 

the respondent’s age will help identify instances where Older Americans have been discriminated 

against when applying for credit.

12. Estimated Burden of Information Collection

Type of Information

Collection

Estimated 

Number of 

Respondents

Estimated 

Number of 

Intakes per 

Respondent

Average Burden 

per Intake

Estimated 

Total Annual 

Burden Hours 

Requested

Web 2,250,000 1 7 minutes 262,500

Paper/Telephone 750,000 1 10 minutes 125,000

Total 3,000,000 ////////////// ////////////// 387,500

The web-based Intake Form will take approximately seven minutes to complete. Complaints from 

respondents who wish to provide additional details and more complicated complaints may take longer 

to complete. 

13. Estimated Total Annual Cost Burden to Respondents

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

information.

14. Estimated Cost to the Federal Government

Based on an independent government cost estimate, including the cost of call center operations, 

software, and hardware, the estimated annualized cost for this information collection is $16,035,342.

 

14 15 U.S.C. § 1637(c).
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15. Program Changes or Adjustments

None. 

16. Plans for Tabulation, Statistical Analysis, and Publication

Data collected through complaint intake, inquiry and feedback collections will be analyzed and may be 

disclosed through the CFPB’s Consumer Complaint Database15 and provided in annual reports to be 

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

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

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

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

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

characteristics, and financial management behavior.

17. Display of Expiration Date

The expiration dates for OMB approval will be displayed on the complaint intake instruments as well as 

in OMB’s public-facing docket at www.reginfo.gov.

18. Exceptions to the Certification Requirement 

The Bureau certifies that this collection of information is consistent with the requirements of 5 CFR 

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

certification requirements.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

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

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

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

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

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

 

15 78 Fed. Reg. 21218, available at https://www.federalregister.gov/articles/2013/04/10/2013-07569/disclosureof-consumer-complaint-data.
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Attachment 2 - Section 1057 FAQs for Whistleblowers 

If you perform work related to a bank or other consumer financial service provider and you report a 

possible violation of consumer financial protection laws, you may be protected from employment 

retaliation under Section 1057 of the Dodd-Frank Act Wall Street Reform and Consumer Protection Act 

(the “Dodd-Frank Act”). Anti-retaliation provisions such as Section 1057 are commonly referred to as 

“whistleblower” protections. 

Who is entitled to protection under Section 1057? 

Section 1057 protects from retaliation persons who perform work related to a bank, credit card 

company or other consumer financial service provider and who, in the course of their work or on their 

own initiative, “blow the whistle” on their employers in any of the following ways: 

• By providing to their employer, the Consumer Financial Protection Bureau (CFPB), or any other 

state, local, or federal law enforcement or regulatory agency information relating to potential 

violations of any law subject to the jurisdiction of the CFPB; 

• By testifying or agreeing to testify in any proceeding resulting from the administration or 

enforcement of the Consumer Financial Protection Act (Title X of the Dodd-Frank Act) or any 

other law subject to the jurisdiction of the CFPB, or any rule, order, standard, or prohibition 

established by the CFPB; 

• By filing, instituting, or causing to be filed or instituted any lawsuit, arbitration, or other 

proceeding under any federal consumer financial law; or 

• By objecting to or refusing to participate in any activity, policy, practice, or assigned task that 

the employee reasonably believes may violate any law subject to the jurisdiction of the CFPB. 

How do I know if I am an employee protected by Section 1057? 

Section 1057 defines protected employees as individuals who perform tasks related to offering or 

providing a consumer financial product or service. Such products or services may include, but are not 

limited to, loans, refinancing, check-cashing, credit cards, and debt or credit rating, counseling or 

assistance. 

What protections does Section 1057 provide? 

Section 1057 prohibits employer retaliation against employees or representatives for reporting potential 

violations of consumer financial protection laws. Specifically, Section 1057 prohibits employers from 

terminating or otherwise retaliating against whistleblowers who alert law enforcement or regulators to 

their companies’ potential violations. 
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Will the CFPB keep my identity confidential? 

If you do not wish to disclose your identity to the CFPB when reporting your information, you may 

remain anonymous. However, disclosing your identity and contact information will facilitate the CFPB’s 

investigation of your concerns and successful remediation and/or correction of any illegal conduct.

What are examples of illegal retaliation against an employee who is a “whistleblower”? 

Your employer may be found to have violated Section 1057 by retaliating against you if your 

whistleblowing was a contributing factor in your employer’s decision to take adverse action against you. 

Such actions may include: 

• Firing or laying off 

• Blacklisting 

• Demoting 

• Denying overtime or promotion 

• Disciplining 

• Denying benefits 

• Failing to hire or rehire 

• Intimidation 

• Making threats 

• Reassignment affecting promotion prospects 

• Reducing pay or hours 

What should I do if I believe my employer retaliated against me? 

You have a right to file a complaint with the U.S. Department of Labor through your local Occupational 

Safety and Health Administration (OSHA) Regional Office within 180 days after your termination or other 

adverse action. Visit the Department of Labor’s website, www.whistleblowers.gov, for instructions on 

how to file a complaint and find the address of the federal OSHA Regional Office nearest you. You may, 

if you wish, also consult a private attorney, who can advise you of additional rights you may have. 
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What compensation is available if I win a retaliation claim against my employer? 

Your possible remedies under Section 1057 include reinstatement to your former position, recovery of 

any back pay, compensatory damages, and attorney and expert witness fees. 

As a condition of employment, I had to sign a waiver of my right to file a retaliation claim or agree to 

submit to mandatory arbitration. Do I still have a right to file a retaliation claim? 

Generally, yes. You should consult a private attorney to find out more about your rights.