Collector - February 2016 - 27


the Incorrect Company option as the
response category.
According to the CFPB's Complaint Portal
Manual, the Incorrect Company response
provides the consumer information that your
company cannot take action because the
complaint is not related to your company.
However, Ratcliff said she learned through
talking with the CFPB's Office of Consumer
Response that the Alerted CFPB is a better
response if your company suspects fraud.
The CFPB's Complaint Portal Manual
notes that the Alerted CFPB complaint
response gives companies the option to
address that there is a pending legal matter
or that the complaint is submitted by an
unauthorized third party.
"If a company suspects fraud, including
business identity theft or scams, the
company should alert the bureau and the
consumer of the suspected fraud," Steckel
said. "In the CFPB Company Portal, there
is a specific response option, Alerted
CFPB, that companies should select if they
suspect fraud. Companies are encouraged to
include a statement and attach any evidence
supporting this response. Complaints that
receive these alerts are not published in the
Consumer Complaint Database."
The Office of Consumer Response reviews
both Alerted CFPB and Incorrect Company
responses. Neither the responses nor the
category selection are forwarded to the
consumer or displayed in the consumer
portal, according to the CFPB's manual.
Steckel said the bureau only publishes
a complaint in its public database after
the company has had time to consider
the complaint and confirm a commercial
relationship with the consumer.

"Companies can and do notify us about
complaints submitted by noncustomers,
and we do not publish them," Steckel said.
"Companies also have the option in our Web
portal to directly notify the bureau that the
company cannot take action because the
complaint is not related to their company.
The CFPB would then contact the consumer
to get more information in an attempt to
identify and route the complaint to the
correct company."

MOVING FORWARD
While RGS Financial has not received
mistaken identity complaints through
the CFPB portal lately, Ratcliff said it is
important for companies to register to
use the portal to show the CFPB they are
being proactive.
"I think that it's definitely been a great
benefit to our industry for the CFPB to
allow us the opportunity to post a company
response," Ratcliff said. "If you're operating
in the correct manner and you're mitigating
consumer harm, then there is no reason not
to register."
Ratcliff also recommends that if
companies do receive a complaint through
the portal, to let their clients know they are
working through it.
"I definitely recommend for companies to
be proactive," Ratcliff said.
Complaint portal users can also submit
a ticket to report error messages or other
technical issues or ask a specific question
and the CFPB will respond through the
portal.
Katy Zillmer is ACA International's
communications specialist.

more
ONLINE
An In-Depth Analysis of the CFPB
Read up on the CFPB and its functions at
acainternational.org/searchpoint.

COLLECTOR 02.16

KEYNOTES

1

Companies should
register for the CFPB
Consumer Complaint Portal
to have the opportunity
to respond to consumers
and communicate with the
CFPB when a complaint is
the result of possible fraud
or the action of a different
company.

2

If a consumer submits
a complaint about
a company that is not
registered for the portal,
the CFPB will contact
the company to start the
registration process.

3

Selecting the "Alerted
CFPB" option is best if
you suspect fraud, a scam or
business identity theft.

4

ACA urges the CFPB to
normalize raw complaint
data in order to help make
the Consumer Complaint
Database more accurate and
less misleading.
27


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