CFPB — Consumer Complaint Response & UDAAP Compliance

Overview

Draft and validate consumer complaint management programme and UDAAP compliance documentation for CFPB-supervised entities. Covers complaint response timelines, UDAAP risk assessment, fair lending, and board reporting.

Example Conversation

You: We need a complaint programme with 15-day and 60-day CFPB portal response timelines, UDAAP risk assessment with the three-part unfairness test, complaint taxonomy, root cause analysis, fair lending, and board reporting cadence.

Agent: I’ll draft the programme using the CFPB/UDAAP checklist and template, then run cfpb_complaint_program_checker to verify coverage.

Agent: Created complaint-udaap-program.md. Running cfpb_complaint_program_checker…

Agent: FAIL — three_part_test and board_reporting missing. I’ve added the three-part test (substantial injury, not reasonably avoidable, not outweighed by benefits) and quarterly board reporting. Re-running…

Agent: PASS — all required CFPB complaint and UDAAP elements are present. Ready for compliance or exam preparation.

What the Tools Validate

cfpb_complaint_program_checker scans the complaint/UDAAP document:

• Required areas: Complaint response timeline (15-day / 60-day for CFPB portal), UDAAP risk assessment with three-part unfairness test (substantial injury, not reasonably avoidable, not outweighed by benefits), complaint taxonomy (CFPB product categories), root cause analysis procedure, fair lending (ECOA/Reg B), board-level reporting cadence.
• Rule: Each area must be clearly addressed.
• Output: PASS if all elements are present; FAIL with a list of missing areas. Add content and re-run until PASS.

Output Excerpt

Complaint/UDAAP programme (excerpt):

## CFPB portal response
Standard complaints: response within 15 days. Complex: up to 60 days with extension notice.

## UDAAP risk assessment — three-part unfairness test
We assess whether a practice: (1) causes or is likely to cause substantial injury, (2) is not reasonably avoidable by the consumer, (3) is not outweighed by benefits to consumers or competition.

## Board reporting
Complaint metrics, trends, and remediation reported to the board quarterly.

cfpb_complaint_program_checker report (excerpt):

=== CFPB COMPLAINT PROGRAM CHECKER ===
Result: PASS

Document: complaint-udaap-program.md
All required CFPB complaint/UDAAP elements present.
Documentation meets CFPB supervisory expectations.

Getting Started

Add your source materials to the project workspace, then activate the CFPB — Consumer Complaint Response & UDAAP Compliance skill. The agent will guide you through the process step by step.