CONSUMER FINANCIAL PROTECTION BUREAU

INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT

Supporting Statement for Consumer Complaint Intake System Company Portal Boarding Form 

Information Collection System

(OMB CONTROL NUMBER: 3170-00XX)
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Table of Contents

Terms of Clearance....................................................................................................................... 2

Abstract.......................................................................................................................................... 2

A. Justification............................................................................................................................ 2

1. Circumstances Necessitating the Data Collection................................................................... 2

2. Use of the Information............................................................................................................. 3

3. Use of Information Technology ............................................................................................. 3

4. Efforts to Identify Duplication ................................................................................................ 3

5. Efforts to Minimize Burdens on Small Entities....................................................................... 3

6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction ................... 4

7. Circumstances Requiring Special Information Collection ...................................................... 4

8. Consultation Outside the Agency........................................................................................... 4

9. Payments or Gifts to Respondents.......................................................................................... 6

10. Assurances of Confidentiality Provided to Respondents ..................................................... 6

11. Justification for Sensitive Questions .................................................................................... 6

12. Estimated Burden of Information Collection ....................................................................... 7

13. Estimated Total Annual Cost Burden to Respondents or Recordkeepers............................. 7

14. Estimated Cost to the Federal Government.......................................................................... 8

15. Program Changes or Adjustments........................................................................................ 8

16. Plans for Tabulation, Statistical Analysis, and Publication.................................................. 8

Tabulation Plans......................................................................Error! Bookmark not defined.

Publication Plans.....................................................................Error! Bookmark not defined.

Project Time Schedule ............................................................Error! Bookmark not defined.

17. Display of Expiration Date................................................................................................... 8

18. Exceptions to the Certification Requirement.......................Error! Bookmark not defined.
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Terms of Clearance

Not applicable. This is a request for a new OMB control number.

Abstract

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

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

CFPB is to facilitate the centralized collection of, monitoring of, and response to complaints 

concerning consumer financial products and services. To support the appropriate routing of 

complaints to the companies that are the subjects of the complaints, the CFPB is developing a 

form which will allow companies to proactively participate in the CFPB’s Company Portal 

(Company Portal), a secure, web-based interface between the CFPB’s Office of Consumer 

Response (Consumer Response) and companies. The Company Portal allows companies to view 

and respond to complaints submitted through the CFPB’s complaint handling system. Many 

companies have sought to register with the Company Portal before consumer complaints have 

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

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

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

(Boarding Form), will serve to streamline information collection from these companies, result in 

a greatly enhanced and efficient experience from both the consumers and companies’ 

perspectives.

A. Justification

1. Circumstances Necessitating the Data Collection

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

of the company that is the subject of the complaint prior to sending the complaint to the 

company. Post-complaint submission gathering of information from a company that is 

specifically named by a complainant in order to review the submitted complaint has not 

presented PRA concerns as a collection of information obtained during an agency complaint 

investigation.1

 However, the current approach to collecting company information, which is 

triggered by a consumer complaint submission, does not take into account companies who wish 

to proactively join the Company Portal to facilitate early notice of complaint submissions, before 

any complaint has been submitted against them. These companies understand that by enrolling 

in the Company Portal proactively, they can greatly reduce the time required to access and 

respond to their first consumer complaint because the needed Internet website link, software, and 

 1 44 U.S.C. § 3518(c)(2); 5 C.F.R. § 1320.4(b).
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security protocols will have already been established. The CFPB's consumer complaint intake 

system Company Portal Boarding Form (Boarding Form) will serve to streamline information 

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

experience.

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

that will help identify the correct company to include organization information, identification of 

company representatives, affiliate relationships, licensure, business identification numbers and 

consumer market presence. Moreover, companies are encouraged to voluntarily provide their 

logos to help consumers identify companies through brand recognition. 

2. Use of the Information

Information collected from companies completing the Boarding Form will support due 

diligence authentication of company identity, inform complaint processing, and give companies’ 

users secure web portal access to complaint information. 

3. Use of Information Technology

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

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

companies’ authorized users secure web portal access to complaint information. The CFPB will 

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

The currently proposed Boarding Form provides a comprehensive list of questions to be 

posed to companies’ representatives through collections that will be primarily mail-in (paper), 

facsimile, and web-based. The form of questions will include open-ended and closed-ended 

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

4. Efforts to Identify Duplication

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

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

improve the processing of individual consumer complaints and inquiries. The CFPB strives to 

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

5. Efforts to Minimize Burdens on Small Entities

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

information collections. For instance, a small business engaging in offering or providing a 

consumer financial product or service or hired by a large financial institution to help process 

consumer complaints may choose to enroll voluntarily in the Company Portal with the idea of 
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future use of the Company Portal to view consumer complaints. However, all of the information 

collections proposed under this request are voluntary and are not anticipated to burden small 

businesses significantly. The CFPB will minimize any burden by requesting readily available 

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

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

The collection of complaints from consumers and crafting appropriate agency responses 

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

submission of company information by companies and their representatives using the Boarding 

Form will be voluntary. If the proposed Boarding Form collections are not conducted, the CFPB 

will not be able to maximize the efficiency of complaint handling in partnership with proactive 

companies. The Bureau is directed by the Dodd-Frank Act to “establish... reasonable 

procedures to provide a timely response to [consumer complaints] against, or inquiries 

concerning” companies.3

7. Circumstances Requiring Special Information Collection

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

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

8. Consultation Outside the Agency

The CFPB submitted the Company Boarding Form to be piloted under the Generic 

Clearance in November 2014. OMB provided approval to pilot the Company Boarding Form for 

a six month period. The CFPB has incorporated changes it learned during the course of this pilot 

period into the new form.

On December 4, 2014, the CFPB published a Notice and Request for Comment (“the 

notice”) on the proposed Boarding Form. In accordance with 5 CFR 1320.5(a)(1)(iv), the 

Bureau has published a notice in the Federal Register allowing the public 30 days to comment on 

the submission of this information collection request to the Office of Management and Budget. 

The Bureau received 5 comments in response to the notice, 4 of which were responsive. 

Comments included the following entities: The Association of Credit and Collection 

Professionals (ACA International); CashAmerica International Inc.; American Land Title 

Association; and American Financial Services Association. The commenters were generally 

supportive of this type of information collection. Several commenters stated that the Boarding 

Form would make the consumer complaint handling process more streamlined and efficient. 

Commenters also indicated that this information would ensure that complaints are routed to the 

appropriate companies. 

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

3 12 U.S.C. § 5534(a). 
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Commenters stated that companies should not be required to list every subsidiary or 

affiliate, particularly those who do not provide consumer financial products or services. The 

Bureau asks that companies only list subsidiaries and affiliates that provide consumer financial 

products or services, and whose businesses would impact CFPB’s routing of consumer 

complaints. 

Several commenters stated that the Boarding Form should be revised to only require 

basic questions that are essential to routing complaints to companies. These commenters 

suggested that information that goes beyond these basic questions, including providing a point of 

contact at the parent company; the tax ID and state license information for the company’s 

subsidiaries and affiliates; and the name of the individual for which the license is registered;

should be categorized as optional. Currently, the CFPB only requires information that would 

allow it to authenticate companies and route consumer complaints to them. The information that 

is cited by these commenters is essential to routing consumer complaints to companies. The 

Bureau uses this information to authenticate and validate companies to ensure that they receive 

complaints that are actually meant for them. The Bureau uses industry standards for business-tobusiness authentication to determine what information is required on the Boarding Form. 

Gathering this information decreases the operational burden to companies by ensuring that they 

only receive complaints that are meant for them.

One commenter voiced concerns about its ability to inform the CFPB of on-going 

business identity fraud. The Bureau has established processes for companies who experience 

business identity fraud. For example, if a company receives a complaint that is the result of 

fraud, it has the option of sending the complaint back to the CFPB with an administrative 

response. This administrative response allows the company to provide a substantive explanation 

of the fraud to the CFPB. One commenter also inquired as to whether the CFPB would provide 

training on how to fill out the Boarding Form. The CFPB provides companies with clear 

instructions on how to fill out the Boarding Form. The Bureau also provides on-going support 

for companies who have questions about the boarding process. Additionally, companies can 

seek further guidance by sending questions to CFPB _StakeholderSupport@cfpb.gov.

CashAmerica suggested that they would like an opportunity to add additional information 

to the Boarding Form, including (1) a place for businesses to list different licenses for various 

products that they have in different states and (2) the ability to provide multiple logos for 

companies that operate with more than one. The Bureau agrees with these comments, and asks 

that these companies provide this additional information as attachments to the Boarding Form. 

Several commenters also noted that the list of company products in Section E, Question 21, is 

too restrictive. These commenters suggested that a box for “other” should be included, with an 

opportunity to write in the primary product. The CFPB agrees with these commenters, and in 

response to these comments, has added an “other” category to the list of primary products that 

companies can choose from. Furthermore, the CFPB has changed the question and now instead 

asks companies to choose as many products as applicable to their business. This is to ensure that 

companies with several different products can correctly and easily fill out the Boarding Form. 
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American Financial Services Association (“AFSA”) inquired as to whether companies 

that have already boarded need to re-register using the new Boarding Form. The Bureau plans to 

periodically update the information for all companies over time. This will involve re-sending the 

Boarding Form to ensure that complaints are routed to the appropriate company. AFSA also 

inquired as to what happens if a company does not provide either all or parts of the information 

on the Boarding Form. In instances where all the required information is not provided on the 

Boarding Form, the Bureau will follow up with the company to ensure that it has had an 

opportunity to provide the necessary information needed to board. Companies that fail to 

provide all the required information on the Boarding Form will not be boarded onto the company 

portal, and will not receive consumer complaints that are filed against them.

Comments received in response to the above referenced 60-day Federal Register notice 

are available on regulations.gov at 

http://www.regulations.gov/#!docketDetail;D=CFPB-2014-0032

9. Payments or Gifts to Respondents

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

10. Assurances of Confidentiality Provided to Respondents

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

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

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

§1070 et seq.) and the Privacy Act (5 U.S.C. § 552a).4

 At the point of information collection, 

individuals will be provided with the CFPB’s Privacy Act statement. The CFPB will implement 

the appropriate security measures to ensure data is safeguarded including the use of locked file 

storage, confidentiality stamping, restricted system access, data encryption, restricted print 

options and disposal by cross-cut shredding.5

 The Company Portal system will be fully 

compliant with the Federal Information Security Management Act of 2002 with the security 

category of “High, Moderate, Low.”

11. Justification for Sensitive Questions

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

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

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

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

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

http://files.consumerfinance.gov/f/201303_CFPB_PIA-Consumer-Response-System.pdf. 
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While the proposed Boarding Form seeks to gather commercial information generally 

available to the public, the proposed Boarding Form may request that companies and their 

representatives provide sensitive information. For instance, some companies may use social 

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

likely social security numbers used as business identification numbers may be accessed by the 

public, company representatives’ SSNs will not be disclosed and will be held in an encrypted 

system for their protection.

12. Estimated Burden of Information Collection

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

that are service providers of the companies that are the subjects of consumer complaints. Based on current 

records, CFPB estimates that during the first 5 years of the new company boarding process about 1,500 

companies will submit an initial Company Boarding Form each year. We also anticipate sending a 

revision form to each of these companies on an annual basis. Further, there are currently 3,000 

companies boarded (See OMB No. 3170-0042) and CFPB estimates that that on average each 

company will submit two revisions per year for the 5,000 companies we will have boarded for a 

total of 10,000 revisions per year.

The CFPB has created a process to allow companies that need to make revisions to do so in an 

efficient and streamlined manner. If a company needs to make revisions to the Boarding Form, the CFPB 

will provide it with a completed form, allowing the company to only fill out the sections that need to be 

revised. This was done to reduce the burden on companies that need to make revisions to the Boarding 

Form. 

Type of Information

Collection

Estimated 

Number of 

Respondents

Frequency 

of 

Response

Estimated 

Number 

of Annual 

Responses 

Average 

Burden 

Hours 

per 

Intake

Estimated 

Total 

Annual 

Burden 

Hours 

Requested

Company Portal Boarding 

Form (Initial Intake)

1,500 1x 1,500 .25 375

Revisions 5,000 2x 10,000 .08 800

Total: 1,500* //////////////// 11,500 //////////// 1,175

*Companies that submit revision are a subset of those that submitted an initial Company Boarding Form; therefore, the estimated total of annual 

Respondents is about 1,500.

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.
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14. Estimated Cost to the Federal Government

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

incurred for printing and mail distribution of the document for approximately 2,500 companies at 

a cost of $2.20 per document (i.e., 8 pages, copy costs at $0.15 per page, and postage is $1.00), 

for a total cost of $5,500.

15. Program Changes or Adjustments

This is a new form; therefore, the entire burden associated with this information 

collection request is considered a program change.

16. Plans for Tabulation, Statistical Analysis, and Publication

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

annual reports to be issued by the CFPB to Congress. In particular, under Section 1013(b)(3)(c) 

of the Dodd-Frank Act, the CFPB provides reports to Congress containing information and 

analysis about complaint numbers, types, and where applicable, resolution. The CFPB may 

publish trend reports based on aggregate data in summaries, reports, and briefings. Presentations 

of analyses may include frequency, classification, and cross-tabulation across consumer financial 

products or services, demographic and economic characteristics, and financial management 

behavior.

17. Display of Expiration Date

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

respondents for all information collections proposed. Further, the OMB control number and 

expiration date will be displayed on the Federal government’s electronic PRA 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 C.F.R. §1320.9, and the related provisions of 5 C.F.R. §1320.8(b)(3) and is not seeking an 

exemption to these certification requirements.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

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

the proposed voluntary information collections, most importantly the absence of randomized 

sample selections, the responses will not be representative of any larger group. Because any 
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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.