ACA International Submits Comments to CFPB Regarding Amendments to the Company Portal Boarding Form

On February 2, 2015, ACA International submitted comments to the CFPB regarding its proposed amendments to the Company Portal Boarding Form.  The Company Portal is a secure, web-based platform that provides the interface between Consumer Responses and the companies who are subject to consumer complaints.    Consumer Response routes complaints to companies through the Company Portal where companies can view and respond to complaints. While companies already have the ability to register with the Company Portal and review and respond to complaints, the CFPB contends the “Company Portal Boarding Form” is necessary to streamline information collection from the companies, resulting in a greatly enhanced and efficient experience from both the consumers’ and companies’ perspective.  The CFPB Notice, proposed form and Supporting Statement can be found here :  http://www.regulations.gov/#!docketDetail;D=CFPB-2014-0032 .

ACA’s comments are directed to the scope of the form.  “ACA is concerned over 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.” Chief among ACA’s concerns is the requirement that companies provide their licensing information, as well as that of their affiliates and subsidiaries.  ACA’s comments make note that requiring state licensing information goes beyond the basic information necessary to identify and contact the company named in a consumer complaint.  ACA believes that requiring companies to provide potentially lengthy and detailed information will likely discourage rather than encourage companies to sign up to receive consumer complaint information.  ACA suggests, instead, that the CFPB consider making the provision of licensing information optional or made part of a different information collection request.