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_checkerto verify coverage.
Agent: Created
complaint-udaap-program.md. Runningcfpb_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.