Change Justification - July 2013

Justification for Non-material/Nonsubstantive Change to Currently Approved Collection
Consumer Financial Protection Bureau
Information Collection Request
Consumer Response Intake Form
The Consumer Financial Protection Bureau (CFPB) submits this memorandum to provide justification for
changes to the form associated with information collection 3170-0011 Consumer Response Intake Form
(Intake Form), approved by OMB on November 18, 2011.1 These revisions are reflected on previouslyapproved information collection media (i.e., telephone script, “paper” form, and web form) and do not
represent a new collection instrument. For ease of discussion, all references will be to the provided
screenshots of the web version of the form.
The Intake Form for debt collection complaints reflects overall reformatting to improve usability. Only
minor non-material, nonsubstantive changes have been made and they include appropriately tailored
language for the CFPB’s intake of debt collection complaints. More specifically, the following changes
have been made to the Intake Form and instructions:
1. Description of the Product or Service Complained About. The language prompting the
consumer to describe the issue (i.e., “This is about. . .”) has been replaced with debt collectionspecific language: “What type of debt is this?” This change narrows the scope of the question,
which is to gather information about the product at issue, and is relevant in the context of
consumer debt collection. 2
2. Text Prompting Description of the Complaint. The language that instructs the consumer to
provide a description of the complaint generally has been: “Describe your complaint. Include
facts about what happened and any steps you have taken to resolve the issue.” The requested
revision changes the language to: “Providing facts and details like dates and where transactions
happened help us understand your complaint. For example, did someone call you? Did you visit
a company in person?” This change provides more clearly the type of transactional information
requested from the consumer. 3
3. Text Prompting the Consumer to Provide Information about the Company that is the Subject
of the Complaint. By revising the sub-heading “Information about the Company” to the more
pointed “Who’s contacting you about this debt?” and “Do you know where this debt came
from?”, the intent of the question is made clear as it pertains to companies that engage in debt
collection. The opportunity to identify more than one company has been approved under 31700011. The instructions accompanying these questions allow the consumer to better distinguish
the types of companies that engage in debt collection. 4
1

Originally approved as a Department of Treasury/Department Offices form, the approved information collection
was transferred to the Consumer Financial Protection Bureau on November 21, 2011. ICR Reference Number
201111-3170-004.
2
See Screenshot 1.
3
See Screenshot 1.
4
See Screenshot 2.

4. Last Four Digits of Social Security Number. This optional field is an abbreviation of the
previously approved social security number field. 5
5. Contact Information of Company Representative. The section permitting the consumer to
provide company contact information includes a field allowing the consumer to identify a
company representative. This change clarifies the intent of the question, i.e., to gather
information that allows the CFPB to identify the company at issue. This is important in the
context of debt collection as many consumers may be contacted telephonically. 6
In addition, the Paperwork Reduction Act (PRA) statement will be revised to state as follows:
OMB Control Number 3170-0011
This is how we accept complaints. You’re not required to fill out this form if you don’t want to
submit a complaint. We estimate that it takes about 7 to 10 minutes to finish completing the
form. Our OMB control number for this form is 3170-0011 and expires on 11/30/2014.
Comments or suggestions? Email us at [email protected].
The revision of the PRA statement improves the pre-existing statement and provides a more PRA
compliant statement by (1) stating that the collection is not required and (2) providing how long it takes
to complete the form. 7 There will be no burden increase as a result of these changes.

5

See Screenshot 3 and OMB Control No. 3170-0011 Supporting Statement.
See Screenshot 4.
7
See Screenshot 5.
6