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CFPB Report:  September 28, 2012

Evaluation of the Consumer Financial Protection Bureau's Consumer Response Unit


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The Dodd-Frank Act mandated that the CFPB "establish a unit whose functions shall include establishing a single, toll-free telephone number, a website, and a database . . . to facilitate the centralized collection of, monitoring of, and response to consumer complaints regarding consumer financial products or services" offered by the companies under its jurisdiction. The Dodd-Frank Act also requires that the CFPB coordinate with other federal agencies to appropriately process complaints. To satisfy the Dodd-Frank Act's requirements for processing consumer complaints, the CFPB created the Consumer Response unit. Our objectives were to (1) evaluate the process the CFPB has established to receive, respond to, and track consumer complaints; (2) assess the CFPB's coordination with federal and state agencies regarding the processing and referral of complaints; and (3) determine the extent to which the CFPB is assessing its effectiveness and timeliness in responding to consumer complaints.

Our analysis determined that the CFPB has a reasonable process to receive, respond to, and track consumer complaints. In addition, the CFPB's consumer response process generally complies with Dodd-Frank Act requirements, the Privacy Act, and industry best practices. The CFPB has a comprehensive manual of standard operating procedures for processing complaints. The manual includes internal controls to mitigate risk in processing consumer complaints. Further, no issues came to our attention to indicate noncompliance with or internal control weaknesses related to the size and nature of the Consumer Response unit's organizational structure, oversight of its contracted contact centers, communication within the Consumer Response unit and throughout the CFPB, coordination with other regulatory agencies for complaint referrals, and the CFPB's schedule for the incremental acceptance of complaints by financial product.

However, our review did note areas in which the CFPB can improve processes and strengthen controls in the Consumer Response unit. Our report contained recommendations to address (1) the inaccurate manual data entry of consumer complaints, (2) the inconsistency of complaint management system data, (3) the lack of a finalized agency-wide privacy policy, (4) the lack of a comprehensive quality assurance program, and (5) the lack of a centralized tracking system for quality assurance reviews. The Assistant Director of the Consumer Response unit agreed with our recommendations and specified actions that have been taken, are underway, or are planned to implement them.