Justification for Change - Credit Reporting Intake Form

Justification for Non-material/Nonsubstantive Change to Currently Approved Collection
Consumer Financial Protection Bureau
Information Collection Request
Consumer Response Intake Form
OMB No. 3170-0011

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.
Currently, the consumer credit reporting Intake Form requires consumers to indicate that they have
disputed their issues with a credit reporting agency prior to submitting a complaint to the CFPB when
their issues involve inaccurate or incomplete credit reporting. 2 In revising the consumer credit reporting
form, hundreds of processed credit reporting complaints were reviewed. It was discovered that
consumers will “push through” the Intake Form and complain to the CFPB notwithstanding not having
first contacted the credit reporting agency that is the subject of their complaints. The proposed changes
to the Intake Form involve removing the requirement that consumers dispute their issue with a credit
reporting agency prior to CFPB’s acceptance of their complaints. Issues relating to inaccurate or
incomplete credit reporting will no longer direct consumers to first contact their credit reporting
agencies and will follow the same query path as the other issues on the form. 3
There will be no substantive impact on credit reporting agencies receiving the complaints from the
CFPB as a result of the revision because credit reporting agencies review and respond to all consumer
complaints received from the CFPB regardless of whether the consumer submitted a prior complaint
directly to the agency.

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 Attachment A, pages 1 & 2.
3
See Attachment A, page 3.
1