The Pilot Intake Form was designed to
aid consumers in the submission of a complaint, question, or
comment relating to credit cards. The pilot implementation will
inform future improvements to the permanent version of the Consumer
Response Intake Form and technical assistance.
The Department of the
Treasury (Treasury), on behalf of itself and the Consumer
Financial Protection Bureau (CFPB), respectfully requests
emergency processing and approval of the collection of information
discussed below because normal clearance procedures are reasonably
likely to prevent or disrupt the collection of information.
Emergency clearance of an information collection request is needed
for piloting the Credit Card Specific Consumer Response Intake Form
(Pilot Intake Form), a web-based, consumer intake data collection
form, which will inform the development and implementation of the
permanent consumer contact intake form (Consumer Response Intake
Form). The pilot is scheduled to begin on June 21, 2011. The CFPB
initiated a timely review of a comprehensive intake form for the
permanent data collection system under normal clearance procedures
pursuant to 5 C.F.R. 1320, with an initial 60-day comment period
beginning on March 9, 2011. See 76 Fed. Reg. 13018 (March 9, 2011).
However, with the formal comment period for the permanent system
collection request likely expiring in early July 2011, the CFPB
will not have the benefit of the Office of Management and Budget
approval by the anticipated pilot launch date. As with any
exploratory program, an adequate timeframe must be provided to test
the Pilot Intake Form and related processes and obtain the results
which may inform the development of the permanent system. The
CFPBs designated transfer date is July 21, 2011, at which time
certain consumer financial protection functions of seven federal
agencies will transfer to the CFPB. An inadequate timeframe for
testing the Pilot Intake Form may preclude the meaningful
assessment needed to ensure the timely implementation of the
consumer response intake infrastructure contemplated by Title X of
the Dodd-Frank Wall Street Reform and Consumer Protection Act, Pub.
L. 111-2013, 124 Stat. 1376 (Dodd-Frank). See Dodd-Frank
§§1013(b)(3)(A), 1021(c)(2), and 1034.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.