3170-0054 Supporting Statement 8.9.18 v4 (OMB)

30-day Federal Register Notice
BUREAU OF CONSUMER FINANCIAL PROTECTION
PAPERWORK REDUCTION ACT SUBMISSION
INFORMATION COLLECTION REQUEST

SUPPORTING STATEMENT PART A
CONSUMER COMPLAINT INTAKE SYSTEM
COMPANY PORTAL BOARDING FORM
(OMB CONTROL NUMBER: 3170-0054)

OMB TERMS OF CLEARANCE:
Not applicable. The Office of Management and Budget (OMB) provided no terms of clearance
when it last approved this collection of information in July 2015.
ABSTRACT
Section 1013(b)(3)(A) of the Dodd-Frank Wall Street Reform and Consumer Protection Act,
Public Law 111-203, requires the Bureau of Consumer Financial Protection (“the Bureau”) to
“facilitate the centralized collection of, monitoring of, and response to consumer complaints
regarding consumer financial products or services.” 1 In furtherance of its statutory mandates
related to consumer complaints, the Bureau utilizes a Consumer Complaint Intake System
Company Portal Boarding Form (Boarding Form) to sign up companies for access to the secure,
web-based Company Portal (Company Portal). The Company Portal allows companies to view
and respond to complaints submitted to the Bureau, supports the efficient routing of consumer
complaints to companies, and enables a timely and secure response by companies to the Bureau
and consumers. 2 This information collection reflects comments received in response to the May
14, 2018 (83 FR 22254) Notice and Request for Comment, seeking input from the public
regarding renewal of the Boarding Form with modifications to improve efficiency and reduce
company burden.
1

Codified at 12 U.S.C. § 5493(b)(3)(A). See also Dodd-Frank Act, Section 1034 (discussing
responses to consumer complaints), codified at 12 U.S.C. § 5534; Section 1021(c)(2) (noting that
one of the Bureau’s primary functions is “collecting, investigating, and responding to consumer
complaints”), codified at 12 U.S.C. § 5511(c)(2).
2

In addition to the Boarding Form for companies, the Bureau utilizes separate OMB-approved
forms to board government agencies and congressional offices onto their own distinct portals to
access certain complaint information through OMB Control No. 3170-0057 (Consumer
Response Government and Congressional Boarding Forms; expires December 31, 2018).

A. JUSTIFICATION
1. Circumstances Necessitating the Data Collection
Since OMB approved its use in 2015, 3 the Bureau has used the Boarding Form to sign up more
than 1,200 companies. Information collected via the Boarding Form helps the Bureau route
complaints to the correct company. 4 This information includes company name, names of
company representatives, and affiliate/subsidiary relationships. Typically, a company completes
the Boarding Form after the Bureau has received a complaint about a company. Some
companies opt to complete the form in advance of the Bureau receiving a complaint, for
example, when a depository institution attains an asset level that brings it under the Bureau’s
supervisory authority. There are operational efficiencies realized by companies and the Bureau
by having a single OMB-approved form used to board companies to the secure portal.
Companies benefit from being able to join the portal before a complaint has been submitted
about them, receiving their first complaint via the secure portal as soon as it is available. This
also enables users to become familiar with the portal. Using a single OMB-approved form also
provides the public with transparency into and clarity about the nature of the information
collection itself. Additionally, the Bureau realizes operational efficiencies by collecting
consistent information across companies.
With this renewal, and consistent with the Bureau’s efforts to ensure the complaint system’s
ease-of-use and effectiveness for companies, the Bureau carefully reviewed the existing form to
identify opportunities for streamlining the Boarding Form. As a result, the Bureau proposes to
simplify the form’s instructions to provide greater clarity and eliminate several fields to reduce
the burden of completing the form. The Bureau will eliminate the following fields: Financial
Institution Number, whether the company is a web-based business, state business licenses and
the states for which those licenses are valid, portal user information for users other than the main

3

Consumer Complaint Intake System Company Portal Boarding Form Information Collection
System, OMB No. 3170-0054 (Notice of Action 7/10/15), available at
https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201504-3170-003.
4

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 Paperwork
Reduction Act concerns as a collection of information obtained during an agency complaint
investigation. Information Collection Request Supporting Statement for Consumer Complaint
Intake System Company Portal Boarding Form (approved without change) (ICR Reference No.
201504-3170-003, OMB Control No. 3170-0054). See also 44 U.S.C. § 3518(c)(1)(B)(ii)
(information collections during the conduct of an investigation involving an agency against
specific individuals or entities is not subject to the PRA); 5 CFR § 1320.4(a)(2) (stating the
same).
2

company point-of-contact and designee, 5 whether the company uses Bank Identification
Numbers, and company logo information.
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 secure
web-portal access to complaint information.
3. Use of Information Technology
The Boarding Form provides a comprehensive list of questions to be posed to companies’
representatives through collections that will be primarily web-based (i.e., the representative will
submit the completed form by email). The form of questions will include open-ended and
closed-ended (i.e., multiple choice).
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 Bureau 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. However, the information collections proposed under this request are voluntary for
small businesses and are not anticipated to burden small businesses significantly. The Bureau
will minimize any burden by striving to request readily-available information and using plain,
short, easy-to-complete information collection instruments.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction
Collecting, investigating, and responding to consumer complaints is one of the Bureau’s primary
functions. 6 The submission of information by companies using the Boarding Form will be
5

To streamline ease of use, instead of supplying additional portal user information via the
Boarding Form, company point-of-contacts or their designees instead will provide that
information online directly in the portal.
6

Dodd-Frank Act § 1021(c)(2), codified at 12 U.S.C. § 5511(c)(2). See also Section 1034
(discussing responses to complaints), codified at 12 U.S.C. § 5534.
3

voluntary. If the proposed Boarding Form is not used, the Bureau will not be able to maximize
the efficiency of complaint handling in partnership with companies. There are operational
efficiencies realized by companies and the Bureau by having a single OMB-approved form used
to board companies to the secure portal. Companies benefit from being able to join the portal
before a complaint has been submitted about them, receiving their first complaint via the secure
portal as soon as it is available. This also enables users to become familiar with the portal. Using
a single OMB-approved form also provides the public with transparency into and clarity about
the nature of the information collection itself. Additionally, the Bureau realizes operational
efficiencies by collecting consistent information across companies.
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 CFR § 1320(5)(d)(2).
8. Consultation Outside the Agency
In accordance with 5 CFR § 1320.8(d)(1), on May 14, 2018, the Bureau published a notice in the
Federal Register allowing the public 60 days to comment on the proposed revision and extension
of this currently-approved collection of information. In accordance with 5 CFR 1320.5(a)(1)(iv),
the Bureau is publishing 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.
This information collection reflects comments received in response to the May 14, 2018 (83 FR
22254) Notice and Request for Comment, seeking input from the public regarding renewal of the
Boarding Form with modifications to improve efficiency and reduce company burden. The
Bureau received eleven comments in response to the Notice and Request for Comment. These
comments were from: Credit Union National Association, the Otoe-Missouria Tribe of Indians,
Flipkart, an executive editor from BankersOnline.com, a compliance industry professional, and six
other individuals.
Some comments discussed the complaint system as a whole or aspects of the complaint system
other than the Boarding Form. The Bureau is constantly looking for ways to improve its
complaint system and processes, including ways to minimize burden on companies and utilize
electronic collections. The revised, streamlined Boarding Form exemplifies those efforts.
Comments about the underlying complaint process and publication of complaint data are not
responsive for the purposes of this information collection. Moreover, the Bureau has previously
addressed such concerns. 7

7

E.g., 2015 Notice of Final Policy Statement, 80 FR 15572 (March 24, 2015).
4

One commenter discussed the Bureau’s relationship with Indian tribes. The Bureau remains
committed to working effectively with tribal partners. This discussion of tribal activities,
however, is not responsive for the purposes of this information collection.
One commenter pointed out typos in the original notice. The Bureau has already identified those
errors and published a corrected notice on June 15, 2018 (83 FR 27975).

One commenter sent information about a consumer complaint, and another commenter wrote
about a personal financial issue. One commenter wrote about engineering, and four commenters
wrote about environmental and/or energy issues. These six comments do not appear related to
the subject of this collection and, therefore, are not responsive for purposes of this information
collection.
9. Payments or Gifts to Respondents
The proposed information collections do not provide any payment or gift to respondents.
10. Assurances of Confidentiality
All information collection activities will be conducted in full compliance with the requirements
for the protection of nonpublic information and personally identifiable information and for data
security and integrity set forth in the federal privacy laws, including the Bureau’s rules (12 CFR
§ 1070.50 et seq.) pursuant to the Privacy Act (5 U.S.C. § 552a). At the point of information
collection, the Bureau’s website explains that personally identifiable information will be kept
private to the extent permitted by law and Bureau rules. The Bureau website privacy policy
further explains the Bureau’s privacy practices. 8 The form includes a Privacy Act Statement and
the website privacy policy will be located on the bottom of the web-form page.
The Bureau has in place 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. The information system
is fully compliant with the Federal Information Security Management Act of 2002 security
category of “Moderate, Moderate, Low.”
On March 20, 2013, the Bureau published a Privacy Impact Assessment (PIA) for the Consumer
Response System. The Bureau uses PIAs to document how the personally identifiable
information (PII) it collects is used, secured, and destroyed in a way that protects each
individual’s privacy. The PIA is broken out into sections that reflect the Bureau’s Privacy
Principles. The Bureau’s Privacy Principles are a set of nine rules the Bureau follows when it

8

See https://www.consumerfinance.gov/privacy/privacy-policy/.
5

collects or uses PII. The PIA is posted on the Bureau’s website at
https://files.consumerfinance.gov/f/201303_CFPB_PIA-Consumer-Response-System.pdf.
Additionally, in accordance with the Privacy Act of 1974, as amended, the Bureau published a
Systems of Records Notice (SORN) in the Federal Register (79 FR 21440, April 16, 2014). The
title for the SORN is CFPB.005—Consumer Response System. The SORN is available on the
Internet at https://www.federalregister.gov/articles/2014/04/16/2014-08555/privacy-act-of-1974as-amended.
11. Justification for Sensitive Questions
While much of the information requested in the Boarding Form is commercial information
generally available to the public, some fields do ask for sensitive, nonpublic information. For
instance, the form asks for the company’s point-of-contact and a designee, and also asks for the
company’s tax ID number. Nonpublic information will not be disclosed to the public and will
be held in an encrypted system for their protection.
12. Estimated Burden of Information Collection
Respondents 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. The Bureau
estimates that approximately 500 companies will submit the Boarding Form for the first time per
year. The Bureau’s earlier Supporting Statement for this renewal included an estimate of 300,
but that estimate is now being changed to 500 to better reflect recent available boarding
information. In addition, an estimated 50 companies will submit an updated form per year.
Exhibit 1: Summary Burden Estimates
Collection of
Number of
Frequency
Information
Respondents

Number of
Responses

Response Burden
Time
(Hours)
(Hours)
500
0.17
85

Company Portal
500
1x
Boarding Form (Initial
Intake)
Revised Form
50
1x
50
0.17
9
Total
500*
////////////////
550
////////////
94
*Companies that submit a revised form are a subset of those that submitted an initial Boarding
Form; therefore, the estimated total of annual Respondents is about 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.

6

14. Estimated Cost to the Federal Government
Generally, companies will submit the form electronically. The Bureau anticipates that no
companies will request a paper copy of the form. However, should a paper form be requested,
costs would be incurred for printing and mail distribution at a cost of approximately $2.05 per
document (i.e., 7 pages, copy costs at $0.15 per page, and postage at $1.00). Other than that,
there will be no costs for the federal government.
15. Program Changes or Adjustments
As explained above, the Bureau is proposing streamlining the Boarding Form, including
eliminating many fields. Additionally, because companies can now update user information
easily in the Company Portal—rather than needing to submit a revised form—we anticipate that
in situations where a revised form is needed (such as mergers and subsidiary updates),
submitting a revised form will take approximately the same amount of time as submitting a form
for the first time (i.e., initial intake). To better reflect these changes and how the form will be
utilized, the Bureau is changing the estimated response time to 10 minutes for both initial intake
and revisions.
The Bureau has also re-estimated the annual responses. The Bureau has re-estimated downward
the annual number of unboarded companies who will complete this form for the first time (i.e.,
initial intake). Additionally, the Bureau has re-estimated downward the number of revised forms
submitted annually. These re-estimates are based on recent experience and information gathered
in the course of boarding companies and utilizing this form.
Exhibit 2: Summary of Burden Changes
Total
Annual
Respondents Responses
Total Annual
Burden
Requested
Initial Intake
Revised Form
Current OMB
Inventory
Difference (+/-)
Program
Change
Discretionary

500

550

1,500
5,000
1,500

1,500
10,000
11,500

-1,000

Estimated
Burden
Average
Hours
Response Time
.17
94

Cost
Burden
(O & M)
$0

.25
.08
.25 (Initial Intake)
.08 (Revisions)

375
800
1,175

$0
$0
$0

-10,950 -.08 (Initial Intake)
+.09 (Revisions)
-.08 (Initial Intake)
+.09 (Revisions)
-.08 (Initial Intake)
+.09 (Revisions)

-1,081

$0

7

-1,081
-1,081

New
Statute
Violation
Adjustment

-1,000

-10,950

16. Plans for Tabulation, Statistical Analysis, and Publication
Data collected through the Boarding Form will be analyzed and certain information may be
provided in reports to be issued by the Bureau to Congress, as required by the Dodd-Frank Act.
In particular, Section 1013(b)(3)(C) of the Dodd-Frank Act requires the Bureau to provide
annual reports to Congress containing information and analysis about complaint numbers, types,
and where applicable, resolution. 9 The Bureau 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 date for OMB approval will be displayed on the form. 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
CFR §1320.9 and the related provisions of 5 CFR §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.

9

Codified at 12 U.S.C. § 5493(b)(3)(C). See also Section 1016(c)(4) (requiring that the
Bureau’s semi-annual reports to Congress include “an analysis of complaints about consumer
financial products or services that the Bureau has received and collected in its central database
on complaints during the preceding year”), codified at 12 U.S.C. § 5496(c)(4).
8