The CFPB Effectively Monitors Consumer Complaints but Can Enhance Certain Processes

Source document: The CFPB Effectively Monitors Consumer Complaints but Can Enhance Certain Processes; document type: inspector-general-sigpr-reports.

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2024-MO-C-016
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Audit Report
2024-MO-C-016
June 24, 2024
Consumer Financial Protection Bureau
The CFPB Effectively Monitors Consumer
Complaints but Can Enhance Certain
Processes

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Executive Summary, 2024-MO-C-016, June 24, 2024
The CFPB Effectively Monitors Consumer Complaints but Can Enhance
Certain Processes
Findings
The Consumer Financial Protection Bureau’s Office of Consumer Response
generally followed its processes for reviewing and monitoring the timeliness,
accuracy, and completeness of company responses to consumer complaints.
For each year we reviewed, Consumer Response (1) used a risk-based
approach to select companies for review and prioritized companies with the
most consumer complaints, (2) followed its processes for sampling consumer
complaints from selected companies and conducting quality assurance
reviews, and (3) met its annual Government Performance and Results Act
Modernization Act performance goal to review the response performance of
at least 85 percent of the companies with more than 250 annual complaints.
Consumer complaint volume increased significantly from 2019 to 2022, and
the risk-based processes used by Consumer Response enabled its company
monitoring team to scale up its review of company responses.
Consumer Response’s company monitoring teams generally followed the
office’s procedures for documenting their review of company responses to
consumer complaints in assessment questionnaires; however, 6.5 percent of
the assessment questionnaires completed from 2019 through 2022 had
incomplete determination finding fields. Consumer Response can strengthen
controls to ensure that all required fields are consistently completed.
Consumer Response has piloted the distribution to companies of
discretionary company-specific reports that provide information about their
complaint handling and response performance. Consumer Response’s pilot
process for issuing company-specific reports lacked measurable objectives, a
completion date, and formal written guidance. In addition, Consumer
Response did not develop a procedure to periodically evaluate the pilot
process. To effectively measure the pilot process’s success, Consumer
Response should finalize objectives and conduct periodic monitoring;
developing formal guidance will help Consumer Response establish a
repeatable process.
Recommendations
This report contains three recommendations designed to enhance Consumer
Response’s processes for issuing company-specific reports on response
performance. In its response to our draft report, Consumer Response
concurs with our recommendations and outlines actions to address them.
We will follow up to ensure that the recommendations are fully addressed.
Purpose
We conducted this audit to
assess the effectiveness of
Consumer Response’s processes
for reviewing and monitoring the
timeliness, accuracy, and
completeness of company
responses to consumer
complaints in accordance with its
established directives and
procedures. To accomplish our
objective, we reviewed
Consumer Response’s directives
and procedures for reviewing
and monitoring company
responses to consumer
complaints.
Background
Collecting, investigating, and
monitoring consumer complaints
about consumer financial
products and services is a
primary function of the CFPB. To
address a statutory mandate,
Consumer Response monitors
consumer complaints to
companies. Consumer Response
company monitoring teams
review company responses and
assess whether those responses
timely, accurately, and
completely address a complaint.

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Recommendations, 2024-MO-C-016, June 24, 2024
The CFPB Effectively Monitors Consumer Complaints but Can Enhance
Certain Processes
Finding 1: Consumer Response Generally Followed Its Processes for Reviewing and Monitoring Company
Responses to Consumer Complaints
Number
Recommendation
Responsible office

No recommendations.

Finding 2: Consumer Response Should Ensure Consistent Documentation of Company Response
Performance
Number
Recommendation
Responsible office

No recommendations.

Finding 3: Consumer Response Can Strengthen Its Processes for Issuing Company-Specific Reports on
Response Performance
Number
Recommendation
Responsible office
1
Finalize measurable objectives and establish a completion date for the
company-specific reports pilot process.
Division of Consumer
Response and Education
2
Establish written guidance for issuing company-specific reports.
Division of Consumer
Response and Education
3
Periodically monitor the company-specific reports pilot process to measure its
effectiveness in improving company responsiveness.
Division of Consumer
Response and Education

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MEMORANDUM
DATE:
June 24, 2024

TO:
Christopher Johnson
Associate Director, Division of Consumer Response and Education
Consumer Financial Protection Bureau

FROM:
Michael VanHuysen
Associate Inspector General for Audits and Evaluations

SUBJECT:
OIG Report 2024-MO-C-016: The CFPB Effectively Monitors Consumer Complaints but Can
Enhance Certain Processes

We have completed our report on the subject audit. We conducted this audit to assess the effectiveness
of the Consumer Financial Protection Bureau Office of Consumer Response’s processes for reviewing and
monitoring the timeliness, accuracy, and completeness of company responses to consumer complaints in
accordance with its established directives and procedures.
We provided you with a draft of our report for review and comment. In your response, you concur with
our recommendations and outline actions that have been or will be taken to address them. We have
included your response as appendix B to our report.
We appreciate the cooperation that we received from Consumer Response. Please contact me if you
would like to discuss this report or any related issues.
cc:
Jan Singelmann

Darian Dorsey

Adam Martinez

Jean Chang

Marianne Roth

Richard Austin

Ashley Adair

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Contents
Introduction
6
Objective
6
Background
6
Office of Consumer Response
6
Consumer Complaint Process
6
Consumer Complaint Volume, 2019–2022
7
Key Processes and Directives for Reviewing and Monitoring Consumer Complaints
8
Finding 1: Consumer Response Generally Followed Its Processes for Reviewing and
Monitoring Company Responses to Consumer Complaints
11
Management Response
12
Finding 2: Consumer Response Should Ensure Consistent Documentation of Company
Response Performance
13
Consumer Response Should Develop System Controls for All Required Fields
13
Management Actions
14
Management Response
14
Finding 3: Consumer Response Can Strengthen Its Processes for Issuing Company-
Specific Reports on Response Performance
15
Consumer Response Should Finalize Measurable Objectives, Establish Formal Written
Guidance, and Periodically Evaluate Its Company-Specific Reports Issuance Pilot Process
15
Recommendations
16
Management Response
16
OIG Comment
17
Appendix A: Scope and Methodology
18
Appendix B: Management Response
20
Abbreviations
24

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Introduction
Objective
The objective of this audit was to assess the effectiveness of the Consumer Financial Protection Bureau
Office of Consumer Response’s processes for reviewing and monitoring the timeliness, accuracy, and
completeness of company responses to consumer complaints in accordance with its established
directives and procedures. Our scope focused on Consumer Response’s processes for reviewing and
monitoring company responses to consumer complaints and issuing company-specific reports about their
response performance. We reviewed consumer complaints and company responses submitted from
January 2019 through December 2022.
To accomplish our objective, we reviewed Consumer Response’s directives and procedures for reviewing
and monitoring company responses to consumer complaints. We interviewed Consumer Response
officials to obtain an understanding of the office’s company monitoring processes. We also reviewed and
analyzed Consumer Response’s company monitoring data from 2019 to 2022. Additional details on our
scope and methodology are in appendix A.
Background
In accordance with the Dodd-Frank Wall Street Reform and Consumer Protection Act, collecting,
investigating, and responding to consumer complaints is a primary function of the CFPB. Under the
authority granted by the Dodd-Frank Act, the CFPB began its Consumer Response operations in 2011, the
same year the agency was established. Consumer Response receives complaints from consumers about
the challenges they face in the financial marketplace, alerts companies to those concerns, and monitors
company responses. Additionally, in accordance with its reporting requirements, the CFPB publishes a
Consumer Response annual report, which details the complaints received from January 1 through
December 31 of the prior year.1
Office of Consumer Response
Consumer Response is an office within the CFPB’s Division of Consumer Response and Education.
Consumer Response analyzes complaint data to inform the CFPB’s data-driven approach to regulating
consumer financial products and services, identifying trends, and detecting possible instances of
consumer harm. Consumer Response’s Investigations section manages the consumer complaint review
process and monitors company responses to consumer complaints.
Consumer Complaint Process
The consumer complaint process begins with the CFPB receiving a complaint from a consumer through its
website, by telephone, by mail, or by referral. Complaints include information provided by the consumer:

1 The report analyzes information about complaint numbers and complaint types and includes information about complaint
resolution.

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the consumer financial product or service concerned, the category that best describes the issue, and the
subject company, as well as a complaint narrative describing the issue and the desired resolution. Once
received, the complaint proceeds through several steps designed to help the consumer receive a timely
response to their complaint (figure 1).
Figure 1. Consumer Complaint Process

Source: The CFPB’s 2022 Consumer Response annual report.
When responding through the secure portal, companies select a response category; the substantive
response choices are in progress, closed with explanation, closed with monetary relief, and closed with
non-monetary relief.2
The CFPB’s documented expectations for company responses involve three elements: (1) timeliness—the
company should provide a response within 15 calendar days of the complaint being sent to the
company;3 (2) accuracy—the company selects the most appropriate response category; and
(3) completeness—the company must address every concern raised by the consumer and provide any
relevant documentation.
The CFPB publishes the subject and date of the complaint and the company’s response category
selection, omitting any personal information, in the Consumer Complaint Database on its website.
Complaints are published after the company responds or within 15 days of the CFPB sending a complaint
to the company, whichever comes first. If the complainant consents, the CFPB also publishes the
complaint narrative after removing the consumer’s personal information.
Within 60 days from the date the company responds, the consumer can provide feedback on the
response by completing an optional survey. This survey gives the consumer the option to provide both
positive and constructive feedback. This feedback is made available to the company through the secure
portal.
Consumer Complaint Volume, 2019–2022
The number of consumer complaints submitted to the CFPB has grown significantly since 2019 (figure 2).
Complaints increased by 53.9 percent from 2019 to 2020, by 83.3 percent from 2020 to 2021, and by
29.5 percent from 2021 to 2022. Complaints related to credit or consumer reporting accounted for much

2 Administrative responses that companies may select include alerted CFPB, duplicate CFPB complaint reported, incorrect
company, and sent to regulator.
3 If a complaint cannot be closed within this time frame, the company is responsible for providing an interim explanation to the
consumer and to the CFPB and a final response within 60 calendar days of the complaint being sent to the company.

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of this growth—44 percent of the total complaints received by the CFPB in 2019 (154,500 complaints),
59 percent in 2020 (319,300 complaints), 71 percent in 2021 (710,300 complaints), and 76 percent in
2022 (978,900 complaints).
Figure 2. Consumer Complaint Volume, 2019–2022

Source: CFPB annual reports to Congress, 2019 to 2022.
Key Processes and Directives for Reviewing and Monitoring
Consumer Complaints
To assess whether companies provide consumers with timely, accurate, and complete responses to
complaints, company monitoring teams in Consumer Response’s Investigations section review company
responses. Consumer Response uses the following key processes and directives to review and monitor
company responses to consumer complaints:
•
Company review schedule development. According to Consumer Response’s Company
Monitoring Directive, the Investigations section uses a risk-based approach to selecting
companies for review and creating a company review schedule. Specifically, the Investigations
section prioritizes reviewing companies that received at least 200 annual complaints. The
Investigations section creates its company review schedule by analyzing company complaint data
and identifying companies for review within its internal complaint monitoring system.

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•
Government Performance and Results Act Modernization Act performance goal.4 In 2021 and
2022, the Investigations section established a Government Performance and Results Act
Modernization Act, known as GPRA, performance goal to review the response performance of at
least 85 percent of the companies with more than 250 annual complaints.5
•
Sampling company responses. After companies are identified and added to the company review
schedule, the Investigations section generates a random sample of consumer complaints to be
reviewed by company monitoring teams. According to the Company Monitoring Directive, the
number of total complaints selected for a random sample depends on a preidentified confidence
level and margin of error.6
•
Reviewing company responses. Company monitoring teams review components of the sampled
consumer complaints to assess the timeliness, accuracy, and completeness of the company
responses. Company monitoring teams use an assessment questionnaire within Consumer
Response’s internal complaint management system to document these reviews. Assessment
questionnaires consist of questions related to the timeliness, accuracy, and completeness of
company responses.
•
Quality Assurance (QA) reviews. According to Consumer Response’s Investigations Quality
Assurance Directive, the Investigations section has a QA team that selects and reviews a random
sample of assessment questionnaires completed by company monitoring teams from the
preceding month to ensure that they reflect comprehensive and accurate analyses and follow
applicable procedures.
•
Issuing reports to companies about response performance. Consumer Response initiated a
discretionary pilot process in 2021 to share company-specific reports on complaint handling and
response performance with a limited number of companies. This pilot process is not required by
law. Consumer Response compiles the results of several reviews of a single company into a
company-specific report, which is then shared directly with that company to help compliance and
complaint handling personnel better understand their complaint response performance history.
The CFPB issues company-specific reports as part of the company monitoring program. Consumer
Response informed us that its ability to issue these reports depends on various factors, such as
staffing levels, leadership policy priorities, and other factors external to the company monitoring
program.7 In 2021 and 2022, Consumer Response followed informal guiding principles when
determining which companies would receive the reports.8 Consumer Response officials informed
us that in 2023, subsequent to our fieldwork phase, their guiding principles evolved to include

4 The Government Performance and Results Act Modernization Act, enacted in 2010, provides the foundation by which federal
agencies are held accountable for establishing management processes and setting performance goals and objectives.
5 The Investigations section’s GPRA performance goal was 82 percent in 2019 and 83 percent in 2020.
6 Consumer Response uses a 95 percent confidence level with a 5 percent margin of error to select from a company’s population
of consumer complaints over a given period. For example, if a company received 10,000 complaints in a given period, Consumer
Response would select approximately 370 complaints to review.
7 For example, the number of Consumer Response staff members decreased over the last 5 years—from 167 in 2018 to 125 in
2023.
8 Consumer Response’s informal guiding principles for determining which companies received company-specific reports in 2021
and 2022 included, for example, (1) companies with the most significant complaint volume, (2) companies that Consumer
Response had previously reviewed, and (3) depository institutions with greater than $10 billion in assets.

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distributing the reports to nondepository institutions and prioritizing sharing the reports with
companies with lower response performance scores.

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Finding 1: Consumer Response Generally
Followed Its Processes for Reviewing and
Monitoring Company Responses to
Consumer Complaints
We found that Consumer Response generally followed its processes for reviewing and monitoring
company responses to consumer complaints.9 Consumer Response used a risk-based approach to select
companies for review and followed its processes for creating company review schedules. In addition, we
found that Consumer Response met its annual GPRA performance goal for company response analysis
during our review period. Further, Consumer Response followed procedures for sampling company
responses to consumer complaints for review and conducting QA reviews of the company monitoring
teams’ assessment questionnaires.
Consumer complaint volume increased significantly from 2019 through 2022, and following the
applicable processes enabled the company monitoring teams to scale up their review of company
responses. Specifically, the number of companies with 250 or more annual complaints that Consumer
Response reviewed increased each year from 2019 through 2022.
Table 1. Select Consumer Response Processes for Monitoring Company Responses and Actions Taken to
Follow Them
Select Consumer Response processes
Actions taken by Consumer Response
Company review schedule development

According to Consumer Response’s Company Monitoring
Directive, Consumer Response selects companies for
review and creates a company review schedule.
Consumer Response prioritizes selecting companies that
received at least 200 annual complaints.
We reviewed company review schedules and company
complaint data from 2019 through 2022 and found that
Consumer Response generally followed its processes
for selecting companies for review and creating
company review schedules.a We found that companies
that received 200 or more annual complaints were
prioritized and included in the company review
schedules.

9 For the purposes of this finding, we used the term generally to reflect that we found instances of an immaterial deviation from
a Consumer Response process.

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Select Consumer Response processes
Actions taken by Consumer Response
GPRA performance goal

Consumer Response’s GPRA performance goal for 2021
and 2022 was to review the response performance of
85 percent of companies with more than 250 complaints.
The goal for 2019 was 82 percent and for 2020,
83 percent.

We reviewed the CFPB’s annual performance plans and
reports and the Investigations section’s company
monitoring data from 2019 through 2022. We found
that Consumer Response met its GPRA performance
goal by reviewing the response performance of at least
85 percent of companies with more than 250 annual
complaints.
Sampling company responses

According to Consumer Response’s Company Monitoring
Directive, company monitoring teams use a random
sample of consumer complaints to review selected
company responses.
We reviewed 40 company monitoring teams’ company
scorecards from 2019 through 2022 and conducted a
walk-through with Consumer Response officials to
confirm the use of a random sample of complaints. We
found that Consumer Response followed its procedures
for sampling consumer complaints from selected
companies.
QA reviews

According to the Investigations section’s Investigations
Quality Assurance Directive, the QA team reviews the
company monitoring teams’ completed assessment
questionnaires to ensure that they reflect comprehensive
and accurate analyses and are conducted in accordance
with procedures.
We reviewed QA reports from eight monthly periods
from 2019 through 2022. We found that Consumer
Response followed its procedures for conducting QA
reviews of the company monitoring teams’ completed
assessment questionnaires, including documenting
QA’s analyses and reasons for disagreements with
determinations made in the assessment questionnaires
and identifying potential deviations from Consumer
Response’s procedures.
Source: OIG analysis of Consumer Response datasets for 2019–2022 and interviews with Consumer Response officials.
a For 2022, Consumer Response deviated from its process to create its company review schedule by using data fields that
differed immaterially from those outlined in its Company Monitoring Directive.
Management Response
In response to our draft report, the associate director of consumer response and education states that he
is pleased that the audit found that the office generally followed its processes for reviewing and
monitoring company responses to consumer complaints.

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Finding 2: Consumer Response Should
Ensure Consistent Documentation of
Company Response Performance
Consumer Response’s company monitoring teams generally followed procedures for documenting their
review of company responses to consumer complaints in assessment questionnaires; however, we found
that the teams did not consistently complete one specific required field of the assessment questionnaire.
Consumer Response’s procedures specify that company monitoring teams must use the determination
finding field when documenting their review. In addition, the U.S. Government Accountability Office’s
(GAO) Standards for Internal Control in the Federal Government highlights the importance of application
controls, such as system controls, which are incorporated directly into computer systems to ensure the
completeness of data. According to Consumer Response, the determination finding field is not a
mandatory field in the complaint management system. During our fieldwork, Consumer Response
informed us of its plans to implement a system change that would make the determination finding field
mandatory. Developing system controls for all required fields would help to ensure the consistent
completion of company response performance assessment questionnaires, which would give Consumer
Response a clear picture of how companies are responding to consumer complaints.
Consumer Response Should Develop System
Controls for All Required Fields
Consumer Response generally has controls to prevent company monitoring teams from submitting
incomplete assessment questionnaires. We found, however, that company monitoring teams did not
consistently document their review in the determination finding field of the assessment questionnaire.
According to Consumer Response’s Company Monitoring CRI (Consumer Response Investigation) User
Support Tool, company monitoring teams must use the determination finding field to document (1) a brief
synopsis of the consumer complaint and company response and (2) an explanation as to why any
responses were deemed to be unsatisfactory. Further, the GAO’s Standards for Internal Control in the
Federal Government highlights the importance of application controls, such as system controls, which are
incorporated directly into computer systems to ensure the completeness of data.
According to Consumer Response, the determination finding field is not a mandatory field within
Consumer Response’s internal complaint management system, and some company monitoring staff use
the complaint specific finding field instead of the determination finding field in the assessment
questionnaire.10 As a result, 9,360 of the 143,742 (6.5 percent) assessment questionnaires completed
from 2019 through 2022 had incomplete determination finding fields.

10 The complaint specific finding field is an optional field designed to highlight common issues and identify trends.

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Updating system controls to make all required assessment questionnaire fields mandatory will help to
ensure that Consumer Response completely and consistently documents its company response
performance assessments. Complete assessments will give Consumer Response a clear picture of how
companies are responding to consumer complaints.
Management Actions
After our preliminary findings meeting, Consumer Response implemented a change to its complaint
management system. The determination finding field is now a mandatory field in the system and must be
completed before the assessment questionnaire can be saved. Based on our review of documentation
evidencing this change, we are not making a recommendation to address this item.
Management Response
In response to our draft report, the associate director of consumer response and education states that he
is pleased with our audit’s recognition of the office’s efforts to implement a system change to make the
determination finding field mandatory and of the office’s commitment to maintaining proper controls to
ensure the completeness of the data.

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Finding 3: Consumer Response Can
Strengthen Its Processes for Issuing
Company-Specific Reports on Response
Performance
Consumer Response’s pilot process to issue discretionary company-specific reports lacked measurable
objectives, a pilot completion date, and formal written guidance for selecting certain companies to
receive company-specific reports. In addition, Consumer Response did not have a process to periodically
evaluate the effectiveness of its pilot process. GAO’s Standards for Internal Control in the Federal
Government emphasizes the need for establishing policies and procedures and highlights the importance
of periodically reviewing processes for their effectiveness in achieving objectives. Instead of establishing
formal objectives and documenting its process for issuing company-specific reports, Consumer Response
developed informal guiding principles that can vary year to year. Finalizing objectives, conducting periodic
monitoring, and establishing a completion date for the pilot process will help Consumer Response
effectively assess the value of the process and identify potential improvements. In addition, developing
formal guidance for issuing company-specific reports will help Consumer Response establish a repeatable
process.
Consumer Response Should Finalize Measurable
Objectives, Establish Formal Written Guidance,
and Periodically Evaluate Its Company-Specific
Reports Issuance Pilot Process
In 2021, Consumer Response initiated a pilot process to share company-specific reports on response
performance with a limited number of companies.11 We found that Consumer Response’s pilot process
lacked measurable objectives and a completion date. Further, Consumer Response did not develop
formal written guidance for its company selection process. For example, in 2021 and 2022, we could not
determine why some companies were chosen to receive reports and others were not. In addition,
Consumer Response did not have a procedure to periodically evaluate the effectiveness of its pilot
process against measurable objectives.
GAO’s Standards for Internal Control in the Federal Government sets internal control standards for federal
entities and outlines the importance of establishing and maintaining effective internal control activities
through policies and procedures. In addition, it states that federal entities should periodically review
policies, procedures, and related control activities for their relevance and effectiveness in achieving
objectives and addressing risks.

11 Consumer Response issued 12 company-specific reports in 2021 and 22 in 2022.

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A Consumer Response official informed us that the office did not establish formal objectives to allow for
flexibility within the report issuance process. In addition, Consumer Response did not develop formal
guidance for selecting companies to receive company-specific reports, and instead developed informal
guiding principles. According to a Consumer Response official, the informal guiding principles for issuing
company-specific reports can vary year to year.
Because Consumer Response did not establish specific parameters for its pilot process, certain
components of the pilot process changed over time. For example, although our audit review period did
not include Consumer Response’s processes in 2023, Consumer Response informed us that in 2023 its
approach for issuing company-specific reports evolved to begin distributing such reports to
nondepository institutions as well as continuing to employ risk-based prioritization for the sharing of such
reports with companies.
Finalizing measurable objectives for the pilot process, conducting periodic monitoring, and establishing a
specific duration for the pilot process can help Consumer Response assess the lessons learned from the
pilot and determine whether to implement the process more permanently. In addition, developing formal
guidance for issuing company-specific reports, including identifying which companies receive them, will
help Consumer Response establish a repeatable process.
Recommendations
We recommend that the associate director of consumer response and education
1. Finalize measurable objectives and establish a completion date for the company-specific reports
pilot process.
2. Establish written guidance for issuing company-specific reports.
3. Periodically monitor the company-specific reports pilot process to measure its effectiveness in
improving company responsiveness.
Management Response
In response to our draft report, the associate director of consumer response and education concurs with
our recommendations. Specifically, regarding recommendation 1, the response states that Consumer
Response has begun to finalize the pilot process, including specifying a completion date and defining
measurable objectives; the office plans to finalize the pilot process by the second quarter of fiscal year
2025.
Regarding recommendation 2, the response states that Consumer Response has prepared a formal
procedure for issuing company-specific reports and plans to finalize the procedure by the second quarter
of fiscal year 2025.
Regarding recommendation 3, the responses notes that Consumer Response has started taking steps to
monitor and measure the company-specific reports pilot process by developing a dashboard and plans to
finalize the dashboard by the second quarter of fiscal year 2025.

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OIG Comment
The planned actions described by the associate director of consumer response and education appear to
be responsive to our recommendations. We will follow up to ensure that the recommendations are fully
addressed.

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Appendix A: Scope and Methodology
Our audit objective was to assess the effectiveness of Consumer Response’s processes for reviewing and
monitoring the timeliness, accuracy, and completeness of company responses to consumer complaints in
accordance with its established directives and procedures.
To accomplish our objective, we reviewed Consumer Response’s directives and procedures for reviewing
and monitoring company responses to consumer complaints. We interviewed Consumer Response
officials to obtain an understanding of the office’s company monitoring processes. We also reviewed and
analyzed Consumer Response’s company monitoring data from January 1, 2019, to December 31, 2022.
We assessed the reliability of Consumer Response’s company monitoring data by reviewing existing
information about the data and the system that produced them, interviewing CFPB officials
knowledgeable about the data, and conducting a walk-through of certain data processes. We determined
that the data were sufficiently reliable for the purposes of this report.
Using information obtained during interviews with Consumer Response officials and our review of
Consumer Response’s directives and procedures, we identified select Consumer Response processes for
review to assess the effectiveness of Consumer Response’s company response monitoring. Specifically,
we
•
examined Consumer Response’s annual company review schedules from 2019 through 2022 to
determine whether Consumer Response followed procedures for analyzing company complaint
data, selecting companies for review, and creating company review schedules
•
reviewed Consumer Response’s GPRA performance goal and company monitoring data to verify
that all companies that received 250 or more annual complaints from 2019 through 2022 were
reviewed
•
reviewed a nonstatistical sample of 40 company scorecards for companies reviewed by company
monitoring teams from 2019 through 2022 to ensure that Consumer Response followed
procedures for sampling company responses
•
analyzed all assessment questionnaires completed by Consumer Response’s company monitoring
teams from 2019 through 2022 to verify that all fields were completed in accordance with
procedures
•
reviewed a nonstatistical sample of eight monthly QA reviews of completed assessment
questionnaires from 2019 through 2022 to determine whether Consumer Response completed
QA reviews according to procedures
•
reviewed Consumer Response’s notification process for issuing company-specific reports to
companies in 2021 and 2022 to determine whether Consumer Response had procedures to guide
its process for identifying and issuing reports to companies
We conducted this performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We

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believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on
our audit objectives. We conducted this work from May 2023 to May 2024.

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Appendix B: Management Response

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Abbreviations
GAO
Government Accountability Office
GPRA
Government Performance and Results Act Modernization Act
QA
Quality Assurance

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Report Contributors
Brian Maloney, Project Lead
Katrina Jenkins, Auditor
Laura King, Auditor
Andrew Luckman, Forensic Auditor
Nick Stefaniak, Forensic Auditor
Lindsay S. Mough, OIG Manager, Management and Operations
Victor Calderon, OIG Manager for Data Analytics
Andrew Gibson III, Senior OIG Manager for Management and Operations
Cynthia Gray, Deputy Associate Inspector General for Audits and Evaluations
Michael VanHuysen, Associate Inspector General for Audits and Evaluations
Contact Information
General
Office of Inspector General
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue NW
Mail Center I-2322
Washington, DC 20551
Phone: 202-973-5000
Fax: 202-973-5044
Media and Congressional
OIG.Media@frb.gov
OIG Hotline

Hotline
Report fraud, waste, and abuse.
Those suspecting possible
wrongdoing may contact the
OIG Hotline by mail,
web form, phone, or fax.
OIG Hotline
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue NW
Mail Center I-2322
Washington, DC 20551
Phone: 800-827-3340
Fax: 202-973-5044

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