Government and Congressional Portal Boarding Forms PRA Supporting Statement (30-day FRN)

30 DAY NOTICE
CONSUMER FINANCIAL PROTECTION BUREAU
INFORMATION COLLECTION REQUEST – SUPPORTING STATEMENT
CONSUMER RESPONSE GOVERNMENT AND CONGRESSIONAL PORTAL BOARDING
FORMS

(OMB CONTROL NUMBER: 3170-00XX)

Terms of Clearance
Not applicable. This is a request for a new Office of Management and Budget (OMB)
control number.

Abstract
The Consumer Financial Protection Act of 2010 (the “Consumer Financial Protection
Act” or the “Act”) directs the Consumer Financial Protection Bureau (“CFPB”) to facilitate the
coordinated collection, monitoring, and response to consumer complaints regarding certain
financial products and services. The Consumer Financial Protection Act further provides for
consumer complaint information sharing between the Consumer Financial Protection Bureau
(“CFPB”) and State and Federal agencies (“Agencies”) and for consumer complaint sharing and
reporting to Congress. To fulfill these mandates, the CFPB has developed separate portals for
Agencies and Congressional users as part of its secure web portal offerings (the “Government
Portal” and the “Congressional Portal,” respectively).
Through the portals, Agencies and Congressional offices can view consumer submitted
complaint data in a user-friendly format that allows easy identification of complaints currently
active in the CFPB process, complaints referred to a prudential federal regulator and other
closed/archived complaints. The portals include features for Agencies and Congressional offices
to export selected complaint data and search by company, consumer name, consumer financial
product and more. They also allow Agencies and Congressional offices to identify whether a
named company has responded to a complaint and view the company closure response category.

A.

Justification

1. Circumstances Necessitating the Data Collection
Government Boarding Form
The Government Portal Boarding Form (“Government Boarding Form”) will be used to
collect information from Agencies that will help identify the individuals who will have
authorization to access the CFPB Government Portal.
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Congressional Boarding Form
The Congressional Portal Boarding Form (“Congressional Boarding Form”) will be used
to collect information from Congressional offices that will help identify the individuals who will
have authorization to access the Congressional Portal.

2. Use of the Information
Information collected from Agencies and Congressional offices completing the
Government Boarding Form or Congressional Boarding Form will support due diligence
authentication of individuals who have access to both portals.

3. Use of Information Technology
The CFPB has created, and will continue to improve, a system that gives Agencies’ and
Congressional offices’ authorized users secure web portal access to consumer complaint
information. The CFPB will use enhancements such as drop down menus and error checks when
possible to minimize burden.
The currently proposed Government Boarding Form and Congressional Boarding Form
provide comprehensive lists of questions to be posed to Agencies’ or Congressional offices’
representatives through collections that will be primarily mail-in (paper), facsimile, and webbased. 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 access Agencies and Congressional offices have to consumer complaint information.
The CFPB strives to integrate cutting-edge technology to make the process efficient and userfriendly for Agencies and Congressional offices.
5. Efforts to Minimize Burdens on Small Entities
There will be no impact on small entities.
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6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
The Consumer Financial Protection Act provides for consumer complaint information
sharing between the CFPB and Agencies 1 and sharing and complaint information with and
reporting to Congress. 2 The submission of information by Agencies and Congressional offices
and their respective representatives using these forms will be voluntary. If the proposed
Boarding Form collections are not conducted, the CFPB will not be able to maximize the
efficiency of complaint information sharing in partnership with Agencies and Congressional
offices.

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
In accordance with 5 CFR § 1320.8(d)(1), the Bureau published a Federal Register notice
allowing the public 60 days to comment on this proposed collection of information. In
accordance with 5 CFR § 1320.5(a)(1)(iv), the Bureau has also published a notice in the Federal
Register allowing the public 30 days to comment on the submission of this information
collection request to the OMB.

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
1
2

Codified at 12 U.S.C. § 5493(b)(3)(C) and 12 U.S.C. § 5493(b)(3)(D).
Codified at 12 U.S.C. § 5493(b)(3)(C).

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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). 3 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. 4 The Government and Congressional Portal
systems 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
While the proposed Government Boarding Form and Congressional Boarding Form seek
to gather information generally available to the public, they may request that Agencies’ and
Congressional offices’ representatives provide sensitive information. Sensitive information will
not be disclosed.

12. Estimated Burden of Information Collection
Government Boarding Form
Respondents will include Agencies that are interested in having access to complaint
information collected by the CFPB. Based on current records, the CFPB estimates that about 20
Agencies will submit a Government Boarding Form each year. Initially, the CFPB estimates that
about 50 Agencies will submit a Government Boarding Form.
The CFPB has created a process to allow Agencies that need to make revisions to do so
in an efficient and streamlined manner. If an Agency needs to make substantive revisions to the
Government Boarding Form, the CFPB will provide it with a completed form, allowing the
Agency to only fill out the sections that need to be revised. This was done to reduce the burden
on Agencies that need to make revisions to the Government Boarding Form. The CFPB
estimates that there will be about 12 revisions submitted each year.

3

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
4
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-ResponseSystem.pdf.

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Congressional Boarding Form
Respondents will include Congressional offices that are interested in having access to
complaint information collected by the CFPB. Based on current records, the CFPB estimates that
about 100 Congressional offices will submit a Congressional Boarding Form each year.
The CFPB has created a process to allow Congressional offices that need to make
revisions to do so in an efficient and streamlined manner. If a Congressional office needs to
make revisions to the Congressional Boarding Form, the CFPB will provide it with a completed
form, allowing the Congressional office to only fill out the sections that need to be revised. This
was done to reduce the burden on offices that need to make revisions to the Boarding Form.
Type of Information
Collection

Government Boarding
Form (Initial Intake)
Government Boarding
Form (Revisions)
Congressional Boarding
Form (Initial Intake)
Congressional Boarding
Form (Revisions)
Total:

Estimated
Frequency Estimated
Number of
of
Number
Respondents Response of Annual
Responses

Average
Burden
Hours
per
Intake

50

1x

50

Estimated
Total
Annual
Burden
Hours
Requested
.25
13

12

1x

12

.08

1

100

1x

100

.25

25

25

1x

25

.08

2

150*

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187

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*Agencies and Congressional offices that submit revision are a subset of those that submitted an initial Government Boarding Form or
Congressional Boarding Form; therefore, the estimated total of annual Respondents is about 150.

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
Generally, Agencies and Congressional offices will be provided a copy of the form
electronically. Costs may be incurred for printing and mail distribution of the document is
estimated as follows:

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•

Government Boarding Form: Approximately 10 Agencies at a cost of $0.60 per
document (i.e., 4 pages, copy costs at $0.15 per page, and postage is $1.00), for a total
cost of $6.

•

Congressional Boarding Form: Approximately 20 Congressional offices at a cost of $0.45
per document (i.e., 3 pages, copy costs at $0.15 per page, and postage is $1.00), for a
total cost of $9.
Total Estimated Federal Costs: $15

15. Program Changes or Adjustments
These are new forms; therefore, the entire burden associated with these information
collection requests are considered a program change.

16. Plans for Tabulation, Statistical Analysis, and Publication
Data collected through the Government and Congressional Boarding Forms will be
analyzed and may be provided in annual reports to be issued by the CFPB to Congress.
17. Display of Expiration Date
The expiration dates for OMB approval will be displayed or otherwise provided to
respondents for the proposed forms. 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
These information collections do not employ statistical methods.

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