ACA Submits Comments Urging the CFPB to Revise Proposed Company Portal Boarding Form

On Feb. 2, 2015, ACA International submitted comments in response to a new Consumer Financial Protection Bureau collection request related to the CFPB’s Company Portal, the Web-based interface between the bureau’s Office of Consumer Response and companies. Although companies already have the ability to register with the Company Portal to review and respond to any complaints, according to the CFPB, the proposed Company Portal Boarding Form “will serve to streamline information collection from these companies, result[ing] in a greatly enhanced and efficient experience from both the consumers and companies’ perspectives.”

While ACA is very supportive of the bureau’s efforts to improve the consumer complaint handling process, ACA is concerned about the broad information the bureau proposes to be “required” from companies in order for them to be able to proactively participate in the “voluntary” portal.

In its comments, ACA pointed out that certain information—such as listing all state business licenses for a parent company, all affiliates and all subsidiaries—seems to go well beyond what would be necessary to identify and contact a company named in a consumer complaint. As a result, by making the provision of such broad information mandatory, ACA believes the boarding process will be unnecessarily burdensome and may even dissuade some companies from proactively participating in the portal altogether.

In order to address these issues and ensure maximum company participation in the portal, ACA strongly urged the bureau to revise the boarding form so that only those basic questions that are essential to make the complaint process work are required. While other information, such as state business licenses, may be helpful in the company identification process, provision of such detailed information should either be optional or made part of a different information collection request altogether.

ACA’s comments in response to the CFPB’s proposed boarding form are part of its ongoing efforts to ensure the CFPB’s policies affecting the credit and collection industry are balanced, well-reasoned and designed to avoid unintended negative consequences. Please visit ACA’s CFPB Web page for more information on CFPB advocacy efforts, compliance materials and news.