3170-0057 Supporting Statement OMB

30-day Federal Register Notice
BUREAU OF CONSUMER FINANCIAL PROTECTION
PAPERWORK REDUCTION ACT SUBMISSION
INFORMATION COLLECTION REQUEST
SUPPORTING STATEMENT PART A
CONSUMER RESPONSE GOVERNMENT AND CONGRESSIONAL PORTAL
BOARDING FORMS
(OMB CONTROL NUMBER: 3170-0057)

OMB TERMS OF CLEARANCE:
Not applicable.
When the Office of Management and Budget (OMB) approved this collection of information in
December 2015, no terms of clearance were provided.
ABSTRACT
Section 1013(b)(3)(A) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank Act or Act) requires the Bureau of Consumer Financial Protection (“the Bureau”)
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 Bureau and State and Federal
agencies (“Agencies”) and for consumer complaint sharing and reporting to Congress. To fulfill
these mandates, the Bureau 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 Government Portal, Agencies can view consumer-submitted complaint data in a
user-friendly format that allows easy identification of complaints currently active in the Bureau
process, complaints referred to a prudential federal regulator, and other closed/archived
complaints. This portal includes features for Agencies to export selected complaint data and
search by company, consumer name, consumer financial product and more. This portal also
allows Agencies to identify whether a named company has responded to a complaint and view
the company closure response category.
The Congressional Portal has some of the same capabilities as the Government Portal and
provides members of Congress and authorized congressional office staff with the ability to view
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30-day Federal Register Notice
consumer complaints they submit on behalf of their constituents with the consumer’s express
written authorization for the release of their personal information. The Congressional Portal only
displays information about complaints submitted by the individual congressional office.

JUSTIFICATION
1. Circumstances Necessitating the Data Collection
Section 1013(b)(3)(A) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank Act or Act) requires the Bureau to “facilitate the centralized collection of,
monitoring of, and response to consumer complaints regarding consumer financial products or
services.” 1 The Act also requires the Bureau to “share consumer complaint information with
prudential regulators, the Federal Trade Commission, other Federal agencies, and State
agencies.” 2 To facilitate the collection of complaints, the Bureau accepts consumer complaints
submitted by members of Congress on behalf of their constituents with the consumer’s express
written authorization for the release of their personal information.
In furtherance of its statutory mandates related to consumer complaints, the Bureau uses
Government and Congressional Portal Boarding Forms (Boarding Forms) to register users for
access to secure web-based portals. The Bureau has developed separate portals for congressional
users and other government users as part of its secure web portal offerings (the “Government
Portal” and the “Congressional Portal,” respectively). 3
Through the Government Portal, government users can view consumer complaint information in
a user-friendly format that allows easy review of complaints currently active in the Bureau
process, complaints referred to a prudential federal regulator, and other closed/archived
complaints.
Through the Congressional Portal, members of Congress and authorized congressional office
staff can view data associated with consumer complaints they submit on behalf of their
constituents with the consumer’s express written authorization for the release of their personal
1

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

2

Dodd-Frank Act Section 1013(b)(3)(D), codified at 12 U.S.C. § 5493(b)(3)(D).

3

In addition to the boarding forms for congressional and government users, the Bureau utilizes a
separate OMB-approved form to board companies onto their own distinct portal to access
complaints submitted against them, through OMB Control No. 3170-0054 (Consumer Complaint
Intake System Company Portal Boarding Form Information Collection System; expires July 31,
2018).
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30-day Federal Register Notice
information. The Congressional Portal only displays information about complaints submitted by
the individual congressional office.
2. Use of the Information
Information collected from congressional offices and other government users completing the
Government Boarding Form or Congressional Boarding Form will support providing access to
authorized individuals to the appropriate portal.
Government Boarding Form
The Government Portal Boarding Form (“Government Boarding Form”) is used to collect
information from government users to identify the individuals who will have authorization to
access the Government Portal.
Congressional Boarding Form
The Congressional Portal Boarding Form (“Congressional Boarding Form”) is used to collect
information from congressional offices to identify the individuals who will have authorization to
access the Congressional Portal to monitor consumer complaints submitted by that congressional
office.
3. Use of Information Technology
The Government Boarding Form and Congressional Boarding Form provide comprehensive lists
of questions to be posed to the offices’ representatives through collections that will be primarily
web-based (i.e., the representative will submit the completed form by email). Questions are
primarily open-ended.
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 the
congressional offices and other government users have to consumer complaint information. The
Bureau strives to use technology to make the process secure, efficient, and user-friendly for
congressional offices and other government users.
5. Efforts to Minimize Burdens on Small Entities
There will be no impact on small entities.
6. Consequences of Less Frequent Collection and Obstacles to Burden Reduction

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30-day Federal Register Notice
The Dodd-Frank Act requires the Bureau to “share consumer complaint information with
prudential regulators, the Federal Trade Commission, other Federal agencies, and State
agencies.” 4 The submission of information by government representatives using these forms will
be voluntary. If the proposed Boarding Form collections are not conducted, the Bureau will not
be able to maximize the efficiency of complaint information sharing in partnership with other
government offices. Additionally, the Bureau will be unable to efficiently and securely update
members of Congress and their staffs with information about consumer complaints submitted on
behalf of their constituents.
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), the Bureau has published a Federal Register
notice allowing the public 60 days to comment on this proposed extension and revision of
this currently-approved collection of information. Along with experiential data gathered over
the past several years, feedback from portal users has informed improvements to the
Boarding Forms. The Bureau did not receive any comments that were responsive to the
issues contemplated by this Notice. Further, and in accordance with 5 CFR 1320.5(a)(1)(iv),
the Bureau 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 be conducted in full compliance with the requirements
for the protection of the confidentiality 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
privacy policy further explains the Bureau’s privacy practices. 5 The forms include a Privacy Act
Statement.
4

Dodd-Frank Act Section 1013(b)(3)(D), codified at 12 U.S.C. § 5493(b)(3)(D).

5

See https://www.consumerfinance.gov/privacy/privacy-policy/.
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30-day Federal Register Notice
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.”
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 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 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. The
PIA is currently in the process of being updated.
Additionally, in accordance with the Privacy Act of 1974, as amended, the Bureau published a
Systems of Records Notice (SORN) in the Federal Register (83 FR 32640, July 13, 2018). The
title for the SORN is CFPB.005—CFPB Consumer Response System. The SORN is available
on the Internet at
https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/bcfp_sorn_consumerresponse-system.pdf.
11. Justification for Sensitive Questions
While some information requested in the Government Boarding Form and Congressional
Boarding Form is generally available to the public, some information requested constitutes
personally-identifiable, non-public information. For instance, the forms ask for contact
information. 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
Since OMB approved their use in 2015, 6 Consumer Response has used the Boarding Forms to
register more than 1,300 users.
Government Boarding Form
Respondents will include agencies that are interested in having access to complaint information
collected by the Bureau. The Bureau estimates that approximately 10 agencies will submit a
Government Boarding Form for the first time per year. In addition, an estimated 5 agencies will
submit an updated form per year.
6

Consumer Response Government and Congressional Boarding Forms, OMB No. 3170-0057
(Notice of Action 12/11/15), available at
https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=201509-3170-001#.
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30-day Federal Register Notice
Congressional Boarding Form
Respondents will include congressional offices that are interested in having access to complaint
information collected by the Bureau. The Bureau estimates that about 50 congressional offices
will submit a Congressional Boarding Form for the first time per year. In addition, an estimated
25 congressional offices will submit an updated form per year.
Exhibit 1: Summary of Burden Estimates
Type of Information
Estimated
Frequency Estimated Response Burden
Collection
Number of
of
Number
Time
(Hours)
Respondents Response of Annual (Hours)
Responses
Government Boarding
10
1x
10
.17
2
Form (Initial Intake)
Government Boarding
5
1x
5
.08
1
Form (Revisions)
Sub-total:
10* ///////////////
15
////////////
3
Congressional Boarding
50
1x
50
.17
9
Form (Initial Intake)
Congressional Boarding
25
1x
25
.08
2
Form (Revisions)
Sub-total:
50* ///////////////
75
////////////
11
Total:
60* ////////////////
90
////////////
14
*Offices that submit revised forms are a subset of those that submitted an initial Government Boarding Form or
Congressional Boarding Form; therefore, the estimated total of annual Respondents is approximately 60.

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, respondents will be provided a copy of the form electronically. 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). Beyond that, there will be no costs to the Federal government.
15. Program Changes or Adjustments
The Bureau has made modifications to the form and reassessed the burden on respondents.
Accordingly, the Bureau is reducing the estimated response time from 15 minutes to 10 minutes
for initial intake.
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30-day Federal Register Notice
The Bureau has also re-estimated the annual responses. The Bureau has re-estimated downward
the annual number of congressional offices and other government users who will complete this
form for the first time (i.e., initial intake). Additionally, the Bureau has re-estimated downward
the number of revised Government Boarding Forms submitted annually. These re-estimates are
based on recent experience and information gathered in the course of boarding entities 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 (+/-)

60

90

150
27
150

150
27
187

-90

-97

-90

-97

Program Change
Discretionary
New
Statute
Violation
Adjustment

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Estimated
Burden
Average Response Hours
Time
.17 (Initial Intake)
14
.08 (Revisions)
.25
38
.08
3
.25 (Initial Intake)
41
.08 (Revisions)
-.08 (Initial
-27
Intake)
.00 (Revisions)
-.08 (Initial Intake)
-8
.00 (Revisions)
-.08 (Initial Intake)
-8
.00 (Revisions)

-19

Cost
Burden
(O & M)
$0
$0
$0
$0
$0

30-day Federal Register Notice
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. 7 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 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
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.
###

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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).
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