Collector - February 2016 - 24


ROOM FOR IMPROVEMENT

ACA International continues to advocate for a well-rounded
Consumer Complaint Database that is fair to the credit and
collection industry and meaningful to consumers. In August
2015, ACA submitted comments to the Consumer Financial
Protection Bureau urging it to normalize raw complaint data in
order to help make the complaint database more accurate and
less misleading.
In fall 2015, the Office of the Inspector General identified
opportunities for the CFPB to improve its information system
security and management controls related to the public-facing
Consumer Complaint Database.
According to its report, the OIG "found security control
deficiencies related to configuration management, access
control, and audit logging and review in the Data Team Complaint
Database, which supports the Consumer Complaint Database."
Although the report notes that the CFPB has "taken steps to
improve the reliability and timeliness of the data in the Consumer
Complaint Database and the related secure information
systems," it largely echoes the findings the OIG made in a
separate audit report released earlier in September 2015.
According to both reports, while the CFPB has implemented
some controls to track the accuracy of complaint data in the
internal case management system, separate management
controls to ensure the accuracy of data on the public-facing
Consumer Complaint Database are not in place.
The September 2015 OIG audit report contained findings from
a comprehensive audit focusing on the Consumer Complaint
Database with analysis of more than 250,000 complaints in the
system and spanned processes performed from Jan. 1, 2014,
through June 30, 2014. 
In the audit report, the OIG identified areas in which
management controls should be improved to promote the
accuracy and completeness of the Consumer Complaint
Database. The OIG concluded that "enhancing existing controls
would help ensure that as the number and types of complaints
published increase, overall reliability of the data is maintained."

Register for the Consumer
Financial Protection Bureau Company Portal at
www.consumerfinance.gov/company-signup.

24

company responses to complaints through the
portal and 98 percent of consumers get timely
responses from companies.
What does that mean for debt collection
agencies registered with the Consumer
Complaint Database? For one, it's important
to note that the increased complaint volume
prompted the CFPB to make an operational
shift. It's now focusing on the "continued
success of its efforts surrounding complaint
intake, company response and consumer
review cycle times," according to the CFPB's
fiscal year 2015 report.
"Companies play a key role in helping to
ensure the accuracy of the information in
the database," said Scott Steckel, the CFPB's
senior financial industry liaison in the
Office of Consumer Response. "Through
the CFPB Company Portal, companies
have multiple response options to alert the
bureau to situations where they cannot
validate a commercial relationship with the
complaining consumer."
The CFPB's database and portal also
serve as a primary interface for companies
and the CFPB's Office of Consumer
Response if they have questions or
concerns. It's important for companies to
register to use the complaint portal to be
able to communicate with consumers, as
well as to identify if a consumer's complaint
made it to the right place.
"In order to receive consumer complaints
submitted to the bureau, companies must
be boarded onto the CFPB Company
Portal," Steckel said. "We use this portal to
forward consumer complaints to companies
and for companies to securely communicate
with consumers and the CFPB. To ensure
consumers get quick responses to their
complaints, companies are encouraged to
reach out to the bureau to board rather
than wait until the bureau has received
a complaint. When a consumer submits
a complaint about a company that isn't
yet boarded into our system, the bureau
reaches out to the company to begin the
boarding process."

ACAINTERNATIONAL.ORG


http://www.consumerfinance.gov/company-signup http://www.ACAINTERNATIONAL.ORG

Table of Contents for the Digital Edition of Collector - February 2016

Collector - February 2016 - Cover1
Collector - February 2016 - Cover2
Collector - February 2016 - 1
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